- From:
- Margee Chambers
- To:
- 'Zickefoose, Graham'; 'henning@gonzaga.edu'; 'kbernie1@outlook.com'; 'mikeppetersen@gmail.com'; 'meg'; 'Conrad,Mark'; 'victor.ramos@spokanetribe.com'; 'mtresidder@spokanetransit.com'; 'mheller@ktea.com'; 'katy@spokaneriverkeeper.org'; 'Sumner, AmyL.'; 'Hayes, Jami'; 'dkbb1@msn.com'; 'lcallen@spokanecity.org'; 'Michael Redlinger'; 'ccorbin@inlandnwland.org'; 'garrett.lacivita@dfw.wa.gov'; 'mcrabtree@inlandnwland.org'; 'Amanda Parrish'; 'W Thomas Soeldner'; 'Eric Grabowski'; 'adam@renewablenw.org'; 'Jeff Nolting'; 'Yamamoto,LeAnn'; 'Waldref, Amber'; 'Bagwell, Jenny'; 'Paul Kropp'
- Cc:
- 'Dombrowski, Mary'
Hi Graham,
I am a good/green once the below changes are made to page 28 and 127:
Page 28 still has typos to be addressed, see below proposed edits.
CE 1.5 Commit to meeting or exceeding the vehicle miles traveled per capita target established in Spokane Regional
Transit Commission’s Transportation Council (SRTC) Vehicle Miles Traveled Reduction Framework. Coordinate with
Spokane Regional Transit Commission SRTC, Spokane Regional Clean Air Agency, WA Department of Ecology, and WA Department of Transportation to meet state requirements to reduce transportation-related GHG emissions and vehicle miles traveled
and to establish tracking and reporting programs for five-year reporting requirements.
SRCAA is involved with criteria air pollutants (PM2.5, PM10, CO, O3, SO2, NO2, lead), not GHG emissions. See EPA table on criteria pollutants and their air quality standards,
https://www.epa.gov/criteria-air-pollutants/naaqs-table
Mobile sources (cars, trucks, etc) contribute to over half of the air pollution in our community and reduction in VMT will help reduce criteria air pollution (PM, CO, etc) and GHG. Ecology has GHG reduction programs including the Climate Commitment Act.
SRCAA is not directly involved with mobile sources and state requirements to reduce VMTs, although we support the effort and advocate for VMT reduction and alternatives to driving alone. Spokane County’s CTR office has a VMT tracking mechanism through their
online commute calendar. WSDOT has a tracking mechanism through their CTR surveys. And SRTC includes VMT information on their modeling and reporting.
Page 127
Figure 44: Number of poor air quality days (those exceeding the exceeding the EPA threshold (9.0 µg/m³), in Spokane County, from 2006–2023. Note that this date uses NOAA smoke plume/hazard mapping and attempts to isolate Pm2.5 from wildfire smoke, and is not
based on air quality monitoring, so shows different information than in the previous figure (Cascadia Consulting Group, 2025).
The figure #44 is not communicating air quality data correctly. 9.0 µg/m³ is the annual standard for PM2.5. The daily standard is 35 µg/m³for PM 2.5.
To accurately show the air quality data, if you stay with 9.0 as the value, it would show
# of years over 9.0. And that would be zero. If you want the figure to communicate # of bad air days, then it would need to show
the # of days over the daily (24-hour) standard of 35. From 1999-2025 we have had 104 days over the federal health-based standard. See link to spreadsheet:
https://spokanecleanair.org/wp-content/uploads/PM2.5-AQI-over-moderate-since-1999-2.pdf If you want to stay with 2006-2023 time frame, the # would be 88 days.
Thank you for the opportunity to review the draft and appendicies.
Margee Chambers, Air Resource Specialist
Spokane Regional Clean Air Agency
1610 S Technology Blvd, #101
Spokane, WA 99224
509-477-4727x114 office
509-862-8255 cell
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