Response to Comments:

State Implementation Plan Revision

for Spokane County Second 10-Year 

Limited Maintenance Plan for PM10

December 2015

Publication no. 15-02-023
Publication and Contact Information

This report is available on the Department of Ecology’s website at 

https://fortress.wa.gov/ecy/publications/SummaryPages/1502023.html

For more information contact:

Air Quality Program

P.O. Box 47600 

Olympia, WA 98504-7600 

Phone: 360-407-6800

Washington State Department of Ecology - www.ecy.wa.gov

o Headquarters, Olympia 360-407-6000

o Northwest Regional Office, Bellevue 425-649-7000

o Southwest Regional Office, Olympia 360-407-6300

o Central Regional Office, Yakima 509-575-2490

o Eastern Regional Office, Spokane 509-329-3400

To request ADA accommodation, call (360) 407-6800, 711 (relay service), or 877-833-6341 

(TTY).
Response to Comments:

State Implementation Plan Revision

for Spokane County Second 10-Year 

Limited Maintenance Plan for PM10

Air Quality Program

Washington State Department of Ecology

Olympia, Washington
Spokane PM10 LMP i December 2015

Table of Contents

Page

Acknowledgements............................................................................................................. ii

Executive Summary........................................................................................................... iii

Reasons for Adopting SIP Revision ....................................................................................1

Differences Between the Proposed SIP Revision and Adopted SIP Revision.....................1

Summary of Public Involvement Process............................................................................2

Affidavit of Publication, Legal Notice, Spokesman Review, October 2, 2015.....3

News Release or Blog, October 1, 2015................................................................4

Ecology website, October 1, 2015 ........................................................................5

Ecology Public Involvement Calendar Notices.....................................................6

Spokane Regional Clean Air Agency News Release, October 1, 2015 ................8

Spokane Regional Clean Air Outreach,...............................................................10

September 28 and 29 Email and Stakeholder List...............................................10

Ecology Listserv Message, October 1, 2015 .......................................................12

Message ...............................................................................................................12

Memo Certifying No Hearing Was Requested....................................................13

Hearing Cancellation Notice/Public Involvement Calendar, October 26, 2015 .14

Response to Comments......................................................................................................16

Comment Received from Fred Greef, November 8, 2015 ..................................16

Ecology’s Response.............................................................................................19
Spokane PM10 LMP ii December 2015

Acknowledgements

The authors of this report would like to thank the following people for their contribution to this 

document:

 Washington State Department of Ecology

o Laurie Hulse-Moyer

o Diane Butorac

o Farren Herron-Thorpe

o Stephanie Summers

 Spokane Regional Clean Air Agency

o Ron Edgar

o Margee Chambers

o Julie Oliver
Spokane PM10 LMP iii December 2015

Executive Summary

Spokane Regional Clean Air Agency has prepared a second 10-year limited maintenance plan 

(LMP) for Spokane County PM10 Maintenance area. Ecology is submitting it to Environmental 

Protection Agency (EPA) for inclusion in Washington’s State Implementation Plan (SIP).

The Spokane County Maintenance Area (SCMA) includes the cities of Spokane, Spokane 

Valley, Millwood, and surrounding unincorporated areas. In the 1980’s, the SCMA violated the 

24-hour standard for PM10. At that time, EPA designated the area as nonattainment. Windblown 

dust, re-entrained road dirt and sanding material, unpaved road dust, and smoke from 

woodstoves and fireplaces all contributed to the violations.

Ambient air monitoring data shows that the SCMA has been in attainment of the PM10 standard 

since 1994. In 2005, an attainment SIP revision and maintenance plan was approved and the area 

was re-designated to attainment. When an area is being re-designated to attainment, the Clean 

Air Act (CAA) requires the development of two EPA-approved maintenance plans. These plans 

show how the area will continue compliance with the standard that was violated. 

The SCMA’s first plan ran from 2005-2015. The second plan will run from 2015-2025. The 

updated plan does not add rules or change requirements, but continues the same control 

strategies developed in 2005. PM10 levels have dropped in the area and pollution levels from 

population growth and increases in vehicle use are not expected to exceed the standard. Due to 

this expectation, Ecology is able to submit a simplified plan called a Limited Maintenance 

Plan—or LMP, to revise the SIP. 

The PM10 LMP SIP revision explains how the SCMA will continue to meet the PM10 standard 

through 2025. Ecology is adopting the SIP revision and will submit it to EPA for approval into 

Washington’s SIP.

Ecology provided public notice of its proposed adoption of the PM10 LMP and SIP revision. 

Comments were accepted from October 1 through November 9, 2015. One comment was 

received. There were no requests for a public hearing.

The purpose of this Response to Comments is to:

 Meet the federal CAA requirements that agencies prepare a response to comments.

 Provide reasons for adopting the SIP revision.

 Describe any difference between the proposed SIP revision and the adopted SIP revision.

 Provide Ecology’s response to comments.

To see more information related to this SIP revision, please visit our Maintenance SIP site

(http://www.ecy.wa.gov/programs/air/sips/plans/maintenancesip.htm).
Spokane PM10 LMP 1 December 2015

Reasons for Adopting SIP Revision

In the 1980s, Spokane was designated as being in nonattainment for the federal health-based 

NAAQS for coarse particle pollution, PM10. Not meeting this standard puts people’s health at 

risk and triggers strict federal requirements that impose economic constraints on the area in order 

to bring the area back into attainment.

Ambient air monitoring shows that the Spokane County Maintenance Area (SCMA) has been in 

attainment of the PM10 standard since 1994. The CAA requires an area being re-designated to 

attainment have an EPA-approved maintenance plan that provides for the area’s continued 

compliance with the PM10 standard for 10 years. A second 10-year plan must follow the first. 

This SIP revision is for the Spokane County Washington, Second 10-year Limited Maintenance 

plan for PM10. This plan:

 Meets the requirement for a second 10-year plan,

 Covers the period through 2025, and

 Fulfills the final maintenance plan requirement of the CAA.

Ecology is adopting this SIP revision to:

 Improve air quality and help the area continue to meet health-based federal air quality 

standards for PM10.

 Fulfill the CAA maintenance planning requirements.

Differences Between the Proposed SIP Revision 

and Adopted SIP Revision

There are no differences between the proposed and adopted SIP revision.
Spokane PM10 LMP 2 December 2015

Summary of Public Involvement Process

Ecology posted a notice of the public comment period and the request for hearing on its public 

involvement calendar and web site. A legal notice was published in The Spokesman Review on 

October 2, 2015. A notice was sent to Ecology’s Air Quality Rule and State Implementation Plan 

Updates email list (listserv), as well as other social media outreach including Facebook and Twitter 

posts. A joint news release was issued by Ecology and Spokane Regional Clean Air Agency 

(SRCAA) on October 1, 2015. SRCAA assisted with outreach efforts by posting information on 

their website, sending a notice to their regulatory update list serve, and stakeholder outreach 

emails. Copies of these documents are included. 

Ecology accepted comments from October 1, 2015 through November 9, 2015. There were no 

requests for a public hearing.
Spokane PM10 LMP 3 December 2015

Affidavit of Publication, Legal Notice, Spokesman Review, October 2, 

2015
Spokane PM10 LMP 4 December 2015

News Release or Blog, October 1, 2015
Spokane PM10 LMP 5 December 2015

Ecology website, October 1, 2015
Spokane PM10 LMP 6 December 2015

Ecology Public Involvement Calendar Notices

Announcing Opportunity to Comment and Request a Hearing
Spokane PM10 LMP 7 December 2015
Spokane PM10 LMP 8 December 2015

Spokane Regional Clean Air Agency News Release, October 1, 2015

Home

Public comment sought on Spokane County’s updated air quality plan

View All News

The Washington Department of Ecology and Spokane Regional Clean Air Agency invites the public to 

review and comment on this draft second ten-year plan, called the PM10 Limited Maintenance Plan. 

This plan shows how Spokane County will stay in compliance with the National Ambient Air Quality 

Standard (NAAQS) for Particulate Matter 10 microns or less (PM10.) The public can review and 

comment on the plan now through November 9, 2015.

The updated plan does not add rules or change requirements for controlling PM10, but continues the 

same control strategies that are in place from the county’s first maintenance plan developed to 

address air quality from 2005 through 2015. These control strategies include street cleaning inside the 

maintenance area, paving requirements for parking lots, temporary bans on woodstove use during 

periods of poor air quality, emission requirements for new stoves, limits on some major industrial 

sources and air quality monitoring.

Cleaning up and maintaining clean air

In the 1980s, the urbanized areas of Spokane County violated the NAAQS for PM10. This area includes 

the cities of Spokane, Spokane Valley, Millwood and surrounding unincorporated areas. The violations 

led to the area being designated a non-attainment area by the U.S. Environmental Protection Agency 

(EPA) in 1990. Ecology and Spokane Regional Clean Air Agency had to develop an initial plan to clean 

up air quality and keep it clean.

Spokane County has shown that PM10 levels have dropped to a point that the population and vehicle 

use growth are not expected to cause pollution levels to exceed the national standard. Due to this, the 

area qualifies for a streamlined plan, called a Limited Maintenance Plan, to fulfill the requirements. The 

updated plan is the final federal requirement for areas once in violation of the standard. Learn more 

about the process on Ecology’s Air Quality webpage.
Spokane PM10 LMP 9 December 2015

Submitting comments

The plan is available for review. The deadline to submit comments is November 9, 2015. Citizens may 

also request a hearing. Hearing requests must be received no later than October 23, 2015.

To submit public comments on the plan, or request a hearing, please email Laurie Hulse-Moyer or mail 

Ecology at:

Laurie Hulse-Moyer

Washington State Department of Ecology

P.O. Box 47600

Olympia, WA 98504-7600

If a hearing request is received by the deadline, two hearings will be held November 5, 2015 at 9:30 

a.m. and 6:00 p.m., at Spokane Regional Clean Air Agency offices, 3104 E. Augusta Avenue, Spokane, 

WA 99207. If a hearing request is not received, Ecology will announce a cancellation online on its 

public involvement calendar.

Ecology will review and consider all comments before submitting the plan to EPA. All comments will be 

summarized and published along with Ecology’s responses.

3104 E Augusta Ave, Spokane, WA 99207 · (509) 477-4727 · working with you for 

clean air 

File an Air Quality Complaint | Terms of Use | Privacy Policy 

Spokane Web Design by Switch Up Web | Print Page
Spokane PM10 LMP 10 December 2015

Spokane Regional Clean Air Outreach, 

September 28 and 29 Email and Stakeholder List

SRCAA Stakeholder Outreach - from Margee Chambers, SRCAA

9/28/15 & 9/29/15, emails sent to local stakeholders:

City of Millwood

 Tom Richardson, Tom.richardson@millwoodwa.us

City of Spokane

 Mark Serbousek, Director of Street Department 232-8810

mserbousek@spokanecity.org

901 N Nelson

Spokane, WA 99202

City of Spokane Valley

 Art Jenkins, Stormwater Engineer 720-5018

ajenkins@spokanevalley.org

11707 E Sprague, Suite 106

Spokane Valley, WA 99206

Spokane County

 Greg Baldwin, Road Department phone #

gbaldwin@spokanecounty.org

Public Works Building

1026 W Broadway

Spokane, WA 99260

 Bob Keneally, Operations & Maintenance Superintendent 477-3600

rkeneally@spokanecounty.org

1026 W Broadway

Spokane, WA 99260

 John Pederson, Planning Director 477-7212

Jpederson@spokanecounty.org

Public Works Building

1026 W Broadway

Spokane, WA 99260

Washington State Department of Transportation

 Doug Bierce, Assistant Maintenance Superintendent, Spokane Area 1 324-6591

bierced@wsdot.wa.gov

2714 N Mayfair

Spokane, WA 99207

CAPR-Spokane Chapter

 John nwgrassroots@gmail.com

 Cindy Zapotockey, chapter president zapox6@afo.net
Spokane PM10 LMP 11 December 2015

Sample Email:

Hello _____,

I wanted to let you know about an upcoming public comment period for the Second 10-Year 

Limited Maintenance Plan for PM10. The public comment period for the draft plan runs 10/1-

11/9. The draft plan will be posted on our website (under hearings and notices) on October 1 and 

will provide information on where to send comments. 

Some background on why we developed the Second 10-Year Limited Maintenance Plan for 

PM10:

 Many years ago, our area was violating the federal, health based standards for PM10. As 

a result, in 1990, we were designated as non-attainment for the PM10 standards.

 That set forth the process of developing an attainment plan and cleaning up our air so we 

could be redesignated as in- attainment of the standard.

 In 2005 we were designated as in attainment. With this designation we were required to 

develop two, 10-year maintenance plan to show how we will continue to keep our air 

clean. The first plan ran from 2005-2015. The second plan will run from 2015-2025. 

 No new rules, requirements, or changes to existing state or local rules are being proposed.

 This updated plan is the final step to complete federal requirements for areas once in 

violation of the standard.

Thank you for your time and your interest in air quality.
Spokane PM10 LMP 12 December 2015

Ecology Listserv Message, October 1, 2015

Message 

From: Ecology's Air Quality Rule and State Implementation Plan Updates [mailto:ECY-AQRULE-AND-SIP-UPDATES@LISTSERV.WA.GOV] On Behalf Of Laurie Hulse-Moyer

Sent: Thursday, October 01, 2015 3:18 PM

To: ECY-AQ-RULE-AND-SIP-UPDATES@LISTSERV.WA.GOV

Subject: Washington SIP Notice: Public comment period and opportunity to request a hearing 

on a SIP revision

 Ecology is accepting comments through November 9, 2015 on a proposed State 

Implementation Plan (SIP) revision to include Spokane Regional Clean Air 

Agency’s (SRCAA) updated particulate matter maintenance plan in the 

Washington SIP. Two public hearings, at 9:30 and 6 pm, will be held 

November 5, if one is requested by October 23. 

 Visit Ecology’s Maintenance Plans webpage to see the plan and find out how to 

comment or request a hearing. Also, see the SRCAA/Ecology joint news 

release.

Visit us on the web or social media.

Subscribe or Unsubscribe 

Message sent to subscriber list of 155 people.
Spokane PM10 LMP 13 December 2015

Memo Certifying No Hearing Was Requested
Spokane PM10 LMP 14 December 2015

Hearing Cancellation Notice/Public Involvement Calendar, October 26, 

2015 

CALENDAR



Public Hearings, 

Meetings, Workshops, 

Open Houses



Public Comment Periods

 More Ecology

Events

Public Involvement Calendar

The Public Involvement Calendar is designed to engage the public in our 

decision-making process. We encourage you to read Frequently Asked 

Questions about Effective Public Commenting. 

Activities that are educational only or are co-sponsored by Ecology may be found 

under the "More Ecology Events" link in the left column of this page. We invite 

your feedback about this Public Involvement Calendar.

Public Hearings, Meetings, Workshops, Open 

Houses

(Next 21 days. Use the search feature (right) for events beyond 21 

days.)

Nov 5 2015 9:30AM Public Hearing - Spokane

------------------------- HEARING CANCELLED: Update to Air Quality 

Maintenance Plan for Spokane Area

Ecology proposes to submit to EPA an updated air quality plan for Spokane 

County. The plan, which will be included in the state's air quality plan, ensures 

the area will maintain the particle standard through 2025. If the public requests 

a hearing by October 23, two public hearings will be held in Spokane. If not 

requested by October 23, the hearings will be cancelled and a cancellation notice 

will be posted on Ecology's Public Involvement Calendar. There are no new rules 

or requirements proposed.

More Information: More Information

Location: Spokane Regional Clean Air Agency 

3104 East Augusta Avenue

Spokane , WA 

Sponsor: Ecology 

ECY HQ

Contact: Laurie Hulse-Moyer 

(360) 407-6783 / laurie.hulse-moyer@ecy.wa.gov 

Public Comment Period - Oct 1 2015 - Nov 9 2015

Public Hearing - Nov 5 2015 6:00PM
Spokane PM10 LMP 15 December 2015

Nov 5 2015 6:00PM Public Hearing - Spokane

------------------------- HEARING CANCELLED: Update to Air Quality 

Maintenance Plan for Spokane Area

Ecology proposes to submit to EPA an updated air quality plan for Spokane 

County. The plan, which will be included in the state's air quality plan, ensures 

the area will maintain the particle standard through 2025. If the public requests 

a hearing by October 23, two public hearings will be held in Spokane. If not 

requested by October 23, the hearings will be cancelled and a cancellation notice 

will be posted on Ecology's Public Involvement Calendar. There are no new rules 

or requirements proposed.

More Information: More Information

Location: Spokane Regional Clean Air Agency 

3104 East Augusta Avenue

Spokane , WA 

Sponsor: Ecology 

ECY HQ

Contact: Laurie Hulse-Moyer 

(360) 407-6783 / laurie.hulse-moyer@ecy.wa.gov 

Public Comment Period - Oct 1 2015 - Nov 9 2015

Public Hearing - Nov 5 2015 9:30AM

Oct 01 2015 Public Comment Period - Spokane

Nov 09 2015 HEARING CANCELLED: Update to Air Quality Maintenance 

Plan for Spokane Area

Ecology proposes to submit to EPA an updated air quality plan for Spokane 

County. The plan, which will be included in the state's air quality plan, ensures 

the area will maintain the particle standard through 2025. If the public requests 

a hearing by October 23, two public hearings will be held in Spokane. If not 

requested by October 23, the hearings will be cancelled and a cancellation notice 

will be posted on Ecology's Public Involvement Calendar. There are no new rules 

or requirements proposed.

More Information: More Information

Location:

Spokane , WA 

Sponsor: Ecology 

ECY HQ

Contact: Laurie Hulse-Moyer 

(360) 407-6783 / laurie.hulse-moyer@ecy.wa.gov 
Spokane PM10 LMP 16 December 2015

Public Hearing - Nov 5 2015 6:00PM

Public Hearing - Nov 5 2015 9:30AM

Last



 Copyright © Washington State Department of 

Ecology

Contact Us | Privacy Notice | Site Info

Response to Comments

Ecology received one comment from the public on the proposed SIP revision. This section 

includes the comment and Ecology’s response. Below is a copy of the original, unaltered text for 

the comment received.

Comment Received from Fred Greef, November 8, 2015
Spokane PM10 LMP 17 December 2015

Spokane PM10 Air Quality Attainment Plan Comments from Fred Greef November 8, 2015

PM10 Plan for Spokane (2015)

Thank you for this opportunity to comment on your 10-year PM10 Attainment Plan.

I have only one real concern, and that is the particulate and the diesel emissions from the huge 

potential increase in unit-train traffic through Spokane. Because there is much uncertainty as to the 

total number of additional unit trains passing slowly through Spokane over the next ten years, each 

one with about one hundred plus cars using multiple huge dirty diesel engines, there really needs to 

be some worst-case emissions modeling for locomotive traffic routes through Spokane residential 

areas. 

At least a seven to 10-fold increase in trains per week passing through Spokane is possible (if not 

likely) based on several current proposals to transport Bakken crude oil from North Dakota and 

Montana, Canadian oil-sand bitumen from Alberta, and open coal cars from Powder River Basin of 

Wyoming. The recent Ecology oil train safety study projected about a seven-fold increase, but that 

study was flawed and did not include all the likely transport increases, nor potential additional 

increases if ports open in Oregon. Three of the primary authors of Ecology’s “Rail Safety” study, 

David Hatzenbuhler, Robert G. Patton, Eric Lymanused of the Texas-based company MainLine 

Management—all held senior positions with Burlington Northern Sante Fe railroad company for 

decades. Worst-case impacts and maximum unit-train numbers were not fairly considered. Air 

quality monitoring was definitely not well addressed. 

Spokane needs to consider both PM-10 24-hour monitoring and PM-2.5 one-hour monitoring, in at 

least one or two residential neighborhoods, near the unit-train rail routes through the Spokane 

area. Some initial pilot studies should be conducted as a starting point to multiply by the worst-case 

likely potential increases in locomotive and coal dust emissions over the next ten years.

There may be no big threat, but based on similar studies in the Gorge, and in Seattle, there may be 

real reason for concern, with even a 200 % increase in emissions, let alone a 1000% potential 

increase over ten years. See: Diesel particulate matter emission factors and air quality implications 

from in–service rail in Washington State, USA, by Daniel A. Jaffe, Atmospheric Pollution Research 

5 (2014) 344‐351. Jaffe said a 50% increase in unit-train rail traffic in Seattle could cause a national 

ambient air quality one-hour PM 2.5 air quality violation. The rail traffic increases through Spokane 

will be far larger than the anticipated increases through Seattle. 

Please at least do enough locomotive diesel emission and coal dust emission modeling to document 

that Spokane residents, nursing home residents, and school children that are close to the primary unit 

train routes will not die prematurely because you failed to investigate this documented potential 

threat to their health and their very lives. Please at least establish one new PM10 24-hour, and two 

new PM 2.5 one-hour monitors near railroad line adjacent communities in Spokane for a pilot study 

to help demonstrate that Spokane residents are protected from this new and growing health threat.

Finally, if there are any intersections in Spokane where huge increases in very slow 100-car unit train 

traffic will temporarily block vehicular traffic, and result in large increases in traffic idle times, I 

hope that you have also incorporated this kind of worst case traffic modeling estimates into your 10-

year plans for both PM10 and PM 2.5. Please let me know if you have done this already, and if you 
Spokane PM10 LMP 18 December 2015

have done this already, and if you have any PM monitors in rail-adjacent locations that can give 

you surety of health safety for at least the most susceptible populations (children, schools, 

elderly, hospitals, nursing homes) and the densest rail-adjacent residential areas.

There are many other communities throughout this state at great risk from a ten-fold increase in 

unit train traffic, for many other reasons. These include derailment and giant fires and 

explosions. Please do your part and help at least protect all of us from the potential worst-case air 

quality threats, by monitoring and modeling to help establish the actual emissions and the future 

10-year worst-case emission growth from big diesel engines and open-car coal dust. I know 

Ecology has excellent air quality modeling staff that can do the requested air quality emission 

modeling. Your Plan will be far more credible if you can add at least a small demonstration and 

explanation as to why PM NAAQS will not be violated over the next ten years by huge increases 

in locomotive coal dust and diesel engine emissions. If this is not done, I hope you can at least 

share with me your immediate commitment to a science-based inquiry that can truly demonstrate 

whether these public health air-quality concerns are justified, and whether your air quality plan is 

fatally flawed.

Thank you very much for this opportunity to comment.

Sincerely,

Fred Greef (private Washington citizen)
Spokane PM10 LMP 19 December 2015

Ecology’s Response

Thank you for your comment. You expressed concern over proposed increases in rail activity, 

particularly coal and oil cars. Impacts of new facilities serviced by rail are beyond the scope of 

this Limited Maintenance Plan. However, the following information is provided for your

reference.

Environmental Reviews: Ecology is a co-lead agency with other federal, state and local agencies 

for several environmental reviews of separate coal and oil proposals that involve rail 

transportation. These proposals include the Gateway Pacific Terminal in Whatcom County, the 

Millennium Bulk Terminals Longview, the Shell rail unloading facility in Anacortes and crude 

oil export terminals proposed in Grays Harbor (Westway, Imperium and Grays Harbor Rail 

Terminal). 

Potential air quality and rail transportation impacts will be identified in the environmental 

reviews for each of these proposals, through the State Environmental Policy Act (SEPA) and 

National Environmental Policy Act (NEPA) processes. Each environmental review has 

opportunities for public comment. 

Below are websites with further information on the status of the environmental review process 

and opportunities for public comment on each project. If you would like to be notified, sign up 

on the email lists (listserv) for each review to receive announcements. 

 Environmental review of Westway Terminal and Imperium Terminal 

http://www.ecy.wa.gov/geographic/graysharbor/terminals.html These Draft 

Environmental Impact Statements are available for public comment until Nov 30, 2015

 Environmental review of Gateway Pacific Terminal 

http://www.eisgatewaypacificwa.gov/ and 

http://www.ecy.wa.gov/geographic/gatewaypacific/

 Environmental review of Millennium Bulk Terminals Longview 

http://www.millenniumbulkeiswa.gov/ and 

http://www.ecy.wa.gov/geographic/millennium/index.html

 Environmental review of Grays Harbor Rail Terminal 

http://www.ecy.wa.gov/geographic/graysharbor/ghrt.html

 Environmental review of Shell Anacortes Rail Unloading Facility 

http://shellraileis.com/ and http://www.ecy.wa.gov/geographic/anacortes/shelloil.html

Proposed increases in rail traffic: The Washington State Department of Transportation’s 

“Washington State Rail Plan Integrated Freight and Passenger Rail Plan 2013-2035” forecasts 

that at the current 3.4% growth rate for routes in and out of Spokane, the rail lines will be at 

150% to 170% of capacity by 2035. These levels cannot be reached without operational changes 

and/or capital improvements to manage anticipated freight rail volumes. The number and capital 
Spokane PM10 LMP 20 December 2015

costs of the needed improvements will likely constrain the growth in rail traffic through 

Spokane. 

Based on current capacity it is not possible for a 1,000% increase in rail traffic as was mentioned 

in the comment letter. The Washington State Department of Transportation (WDOT) 2014 

Marine and Rail Oil Transportation Study (oil train safety study) predicts the maximum possible 

increase in rail traffic in Spokane through 2025 would be closer to 50%. 

Newer trains (Tier 3 and 41) have stricter emission standards and would achieve a 50% or 90% 

reduction in diesel particulate emissions respectively, compared to older trains. Without taking 

the additional reductions from the stricter standards into account, a 50% increase from Ecology 

2011 locomotive emissions would increase annual railroad PM10 emissions from 42 tons per year 

to 63 tons per year. In addition, locomotive emissions from fuel use are estimated to be just 

.22% of overall PM10 emissions in Spokane County and even a 50% increase for this source 

category would not cause concern. Fugitive dust emissions from locomotives are not estimated 

by Ecology, but are not expected to contribute enough for the area to be at risk for violating the 

PM10 standard. Lead agencies will determine how individual proposed project SEPA reviews will 

address fugitive emissions.

The introduction of Tier 4 locomotives and current restrictions in rail infrastructure throughout 

Idaho and Spokane County, as well as other capacity restrictions along these routes, should 

minimize any increase in rail traffic through the area for a least the next 10 years, limiting its 

impact on Spokane’s compliance with the PM10 standard.

Jaffe Study estimates: Increase in emissions from rail traffic would be highly unlikely to threaten 

particulate standards: The Jaffe study was specific to the Tacoma area. Impacts from 

locomotives are very localized and vary due to area meteorology, terrain and proximity to the 

tracks. Currently the locomotive emissions for Spokane County from fuel use are about 1% of 

the fine particle (PM2.5 or particulate matter 2.5 microns or less) emissions in Spokane. Fugitive 

emissions are not estimated, but not expected to threaten the area’s compliance with particulate 

matter standards.

Concerns over blocked crossings: Increases in vehicle idling emissions at crossings would be 

more likely to increase carbon monoxide (CO) levels than PM10. However, there should be no 

issues with CO either because most crossings with major arterials in the central business district 

of Spokane are grade separated, meaning they are at a different levels, like an overpass or a 

bridge. So there should be no problem with buildup of vehicle emissions, as there would be few 

blocked crossings. Those few street level crossings in the valley are in open areas with little 

chance of a buildup of CO emissions.

Oil train safety study: You also expressed concerns with the WDOT Department of 

Transportation’s recent oil train safety study. This study was conducted with the Washington 

Utilities and Transportation Commission, Emergency Management Division and others and was 

published in March this year. The oil train safety study was intended to assess the environmental 

impact of an accident and not the long term impact of increased rail traffic. For questions on rail 

 

1http://www3.epa.gov/otaq/standards/nonroad/locomotives.htm
Spokane PM10 LMP 21 December 2015

transportation studies, contact the Washington Department of Transportation Freight Rail office. 

Contact information is available at http://www.wsdot.wa.gov/Freight/Rail/default.htm. 

Future projections using modeling not required: In order to qualify for the LMP (Limited 

Maintenance Plan), Ecology and SRCAA had to show that PM10 levels have dropped to a point 

that population growth and increases in vehicle use are not expected to cause pollution levels to 

exceed the standard in Spokane. The area qualified to submit a LMP. Since it is highly unlikely 

PM10 emissions will increase significantly, the LMP option does not require future year 

projections emissions. It is assumed that currently monitored levels are low enough that an 

emissions increase in any source category will not cause a violation of the standard in the next 

ten years. Continued monitoring for PM10 in the out years will alert us if that should prove to not 

be the case. 

Other efforts: Several years ago, SRCAA entered into a voluntary partnership with Burlington 

Northern Santa Fe (BNSF) to have BNSF retrofit up to eleven locomotives with idle reduction 

technology to reduce air emissions and conserve fuel in Washington. The pool of locomotives 

retrofitted operates out of the BNSF rail yards in Spokane and Pasco, Washington. Also, in 2012

SRCAA Board directed staff to try to find funding for additional monitoring of PM2.5 near 

railways. Any such study would be expensive, requiring both sampling and speciation lab work. 

A special modeling project is not in the current budgets of the SRCAA or Ecology, and no 

outside funding is currently available. 

We appreciate your compliment of Ecology’s modeling staff. 

Since the Spokane area measured monitored values are far below the PM10 standard, this area is 

at little risk of violating this standard. SRCAA commits to continuing to monitor in the Spokane 

area through 2025.