Air Pollution Control Board

San Diego County Air Pollution Control District

AGENDA ITEM

Governing Body

GREG COX

First District

DIANNE JACOB

Second District

PAM SLATER-PRICE

Third District

RON ROBERTS

Fourth District

BILL HORN

Fifth District

Documentum Version 3.1

DATE: December 5, 2012 AP01

TO: Air Pollution Control Board

SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF PROPOSED 

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 

1997 NATIONAL OZONE STANDARD (DISTRICT: All)

SUMMARY: 

Overview

San Diego County has attained the 1997 National Ambient Air Quality Standard for 

ground-level ozone, a common air pollutant. Attainment is a significant air quality and 

public health achievement resulting from a long-standing program to cost-effectively 

reduce air pollutant emissions from nearly every source in the region. San Diego 

County is now eligible to be redesignated under federal law from a "moderate 

nonattainment area" to an "attainment area" for this standard. Today's action to approve 

the Ozone Redesignation Request and Maintenance Plan will initiate the process for 

redesignation to attainment.

If adopted by your Board, the Ozone Redesignation Request and Maintenance Plan will 

be forwarded to the California Air Resources Board for approval and submittal to the 

U.S. Environmental Protection Agency. The federal agency may issue a ruling to 

redesignate the region to an attainment area for the 1997 ozone standard after 

evaluating the request and verifying that the criteria for redesignation have been met.

Redesignation to attainment of the 1997 ozone standard primarily requires 

demonstrating that all applicable federal requirements associated with the standard have 

been met, and demonstrating that the region will maintain compliance with the standard 

in future years. The proposed Ozone Redesignation Request and Maintenance Plan 

fulfill these requirements. Ozone-forming emissions are projected to further decline 

through the next decade due to the existing program to control emissions and no future 

violations of the standard are anticipated.

Redesignation to attainment of the 1997 national ozone standard is effectively an 

administrative process that will not result in any regulatory relief to the region. 

Nevertheless, it will serve as acknowledgement of the region’s substantial efforts and 
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF PROPOSED 

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 1997 

NATIONAL OZONE STANDARD (DISTRICT: All)

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progress in reducing ozone air pollution. Moreover, the corresponding Maintenance 

Plan will help ensure the compliance with the standard is maintained in future years.

Recommendation(s)

AIR POLLUTION CONTROL OFFICER

1. Find that the adoption of the Ozone Redesignation Request and Maintenance Plan is 

exempt from the provisions of the California Environmental Quality Act pursuant 

to California Code of Regulations Title 14, Section 15061(b)(3), since it can be 

seen with certainty that there is no possibility that the activity in question may have 

a significant adverse effect on the environment, and pursuant to California Code of 

Regulations, Title 14, Section 15308, as an action taken to assure the protection of 

the environment, where the regulatory process involves procedures for protection of 

the environment.

2. Adopt the Resolution entitled RESOLUTION ADOPTING A REDESIGNATION 

REQUEST AND MAINTENANCE PLAN FOR THE 1997 NATIONAL OZONE 

STANDARD FOR SAN DIEGO COUNTY.

3. Direct the Air Pollution Control Officer to submit the resolution and the 

accompanying Ozone Redesignation Request and Maintenance Plan to the 

California Air Resources Board for expeditious approval and submittal to the U.S. 

Environmental Protection Agency.

Fiscal Impact

Adoption of the proposed Ozone Redesignation Request and Maintenance Plan will 

initiate an administrative process that has no fiscal impact on the Air Pollution Control 

District. The Maintenance Plan will be implemented with existing staffing and 

resources identified in the Fiscal Year 2012-13 Operational Plan in the Air Pollution 

Control District. There will be no change in net General Fund cost and no additional 

staff years.

Business Impact Statement

Adoption of the proposed Ozone Redesignation Request and Maintenance Plan will 

initiate an administrative process that has no impact on businesses. The Maintenance 

Plan imposes no new or modified air pollution control requirements on businesses.

Advisory Board Statement

At its meeting on October 10, 2012, with a quorum present, the Air Pollution Control 

District Advisory Committee unanimously voted in support of the Air Pollution Control 

District’s recommendations.

BACKGROUND:
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF PROPOSED 

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 1997 

NATIONAL OZONE STANDARD (DISTRICT: All)

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Ozone occurs naturally and is beneficial in the upper atmosphere, shielding the earth from the 

sun's harmful ultraviolet rays. However, ground-level ozone is a highly reactive and harmful air 

pollutant, formed in the air by reactions of other air pollutants—namely volatile organic 

compounds (VOC) and oxides of nitrogen (NOx)—in the presence of sunlight and heat. When 

inhaled, ozone can irritate and inflame the lining of the lungs and trigger a variety of health 

problems including chest pain, coughing, throat irritation, and congestion.

The U.S. Environmental Protection Agency (EPA) established a National Ambient Air Quality 

Standard (NAAQS or standard) for ozone in 1997. The standard is attained when, at each ozone 

monitor in the region, the three-year average of the annual fourth-highest daily maximum 8-hour 

average ozone concentration is no more than 84 parts per billion. (Stated differently, in a billion 

units of air there can be no more than 84 units of ozone present.)

The EPA designated areas as either attainment or nonattainment for the 1997 national ozone 

standard based on monitoring data collected over the 2001-2003 period. EPA further classified 

nonattainment areas as marginal, moderate, serious, severe, or extreme nonattainment based on 

the severity of ozone pollution in the area. Currently San Diego County is designated a moderate 

nonattainment area for the 1997 national ozone standard based on a monitored ozone level of 93 

parts per billion over the 2001-2003 period.

However, ozone monitoring data for 2009-2011 show that San Diego County has attained the 

1997 ozone standard with an ozone value of 82 parts per billion over the recent three-year period. 

Available monitoring data for 2012 show the region continues to attain the standard. In fact, so 

far this year 2012 has been the cleanest year on record.

The District has reviewed the statutory criteria and federal guidance documents addressing 

redesignation to attainment, and concludes redesignation to attainment of the 1997 national 

ozone standard is warranted. Accordingly, an Ozone Redesignation Request and Maintenance 

Plan have been prepared (Attachment B) for consideration of approval by your Board and 

submittal to EPA through the California Air Resources Board (CARB).

Comprehensive Program to Reduce Ozone Air Pollution

Air pollution control in San Diego County is a shared responsibility among local, state, and 

federal agencies pursuant to state and federal laws. The District regulates emissions from nonmobile (stationary) sources, such as stationary industrial and commercial sources, and some areawide sources such as coatings and industrial solvents. At the state level, the CARB adopts 

measures to reduce emissions from on-road motor vehicles, off-road vehicles and equipment, 

fuels, and consumer products. At the national level, the EPA regulates off-road equipment and 

interstate sources such as ships, trains, aircraft, and out-of-state vehicles.

The District—under the leadership of your Board and in collaboration with federal, state, and 

local agencies and the residents, businesses, and civic groups of San Diego County—has worked 

hard to efficiently and cost-effectively reduce ozone-forming emissions from nearly every source 

to ensure cleaner air for all San Diegans. The resulting long-term, downward trend in ozone 
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF PROPOSED 

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 1997 

NATIONAL OZONE STANDARD (DISTRICT: All)

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levels is illustrated below in Figure 1. The air quality improvement has occurred despite 

substantial growth in population and motor vehicles, reflecting the effectiveness of the emissions 

control program.

Figure 1

Ozone Improvement Despite Growth

Criteria for Redesignation to Attainment

The Clean Air Act identifies the five basic requirements that must be met before EPA can 

redesignate a nonattainment area to attainment for a particular standard. A full demonstration of 

compliance with each requirement is presented in the proposed Redesignation Request and 

Maintenance Plan for the 1997 national ozone standard. In summary: (1) San Diego County has 

attained the 1997 national ozone standard based on current air quality data; (2) implementation 

requirements under the Clean Air Act have been met; (3) no submittals to EPA are currently 

disapproved, conditionally approved, or partially approved; (4) the region's improvement in air 

quality is due to permanent and enforceable emission reductions resulting from air pollution 

control regulations; and (5) a Maintenance Plan meeting federal requirements has been prepared, 

demonstrating how the region will maintain compliance with the standard for 10 or more years.

The proposed Maintenance Plan demonstrates that total regionwide ozone-forming emissions are 

projected to continue declining through the next 10 years due to the existing emissions control

program. In fact, much of the emissions reduction benefit of currently adopted rules and 

regulations has yet to be realized and is projected to occur in future years due to the continued 

replacement of older vehicles, engines, and equipment with newer units subject to more stringent 
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF PROPOSED 

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 1997 

NATIONAL OZONE STANDARD (DISTRICT: All)

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emission control requirements. Therefore no future violations of the 1997 national ozone 

standard are anticipated.

No Regulatory Implications of Redesignation

The proposed Ozone Redesignation Request is effectively an administrative process and the 

Maintenance Plan, if approved, would impose no new or modified air pollution control 

requirements. Moreover, the Redesignation Request, if granted, would not impact the region's 

nonattainment status and ongoing efforts to attain the more health-protective 2008 national ozone 

standard (8-hour average of 75 parts per billion) and state ozone standards (8-hour average of 70 

parts per billion and 1-hour average of 94 parts per billion). These standards are subject to 

planning and implementation requirements that are well underway and attaining them will 

require additional emission reductions. Nevertheless, the region has made expeditious progress 

toward meeting these standards, further demonstrating the effectiveness of the emissions control 

program.

Environmental Statement

The California Environmental Quality Act (CEQA) requires environmental review for certain 

actions. The District conducted a preliminary review of whether CEQA applies to the adoption 

of the proposed Ozone Redesignation Request and Maintenance Plan. The proposed actions will 

initiate an administrative process and will not result in new or the relaxation of existing air 

pollution control requirements. Therefore, the adoption is exempt from the provisions of CEQA 

pursuant to California Code of Regulations, Title 14, Section 15061(b)(3) since it can be seen 

with certainty that there is no possibility that the activity in question may have a significant 

adverse effect on the environment, and pursuant to Section 15308 as an action taken to assure the 

protection of the environment, where the regulatory process involves procedures for protection of 

the environment. Pursuant to Section 15062, a Notice of Exemption will be prepared and filed 

upon the Board’s adoption of the proposed Ozone Redesignation Request and Maintenance Plan.

Linkage to the County of San Diego Strategic Plan

Today’s proposed actions support the Sustainable Environments Initiative in the County of San 

Diego’s 2012-2017 Strategic Plan with an objective to promote an environment where residents 

can enjoy clean air. The Maintenance Plan provides for ongoing reductions in ozone-forming 

emissions and helps ensure that County residents will continue to have cleaner air to breathe for 

years to come.
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF PROPOSED 

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 1997 

NATIONAL OZONE STANDARD (DISTRICT: All)

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ATTACHMENT(S)

Attachment A - Resolution Adopting the Ozone Redesignation Request and Maintenance Plan

Attachment B - Ozone Redesignation Request and Maintenance Plan

Attachment C – Workshop Report
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF PROPOSED 

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 1997 

NATIONAL OZONE STANDARD (DISTRICT: All)

AGENDA ITEM INFORMATION SHEET

REQUIRES FOUR VOTES: [] Yes [X] No

WRITTEN DISCLOSURE PER COUNTY CHARTER SECTION 1000.1 REQUIRED

[] Yes [X] No

PREVIOUS RELEVANT BOARD ACTIONS:

May 23, 2007 (AP01), Adopted Eight-Hour Ozone Attainment Plan for San Diego County; 

December 11, 2002 (AP02), Adopted Ozone Redesignation Request and Maintenance Plan.

BOARD POLICIES APPLICABLE:

N/A

BOARD POLICY STATEMENTS:

N/A

MANDATORY COMPLIANCE:

N/A

ORACLE AWARD NUMBER(S) AND CONTRACT AND/OR REQUISITION 

NUMBER(S):

N/A

ORIGINATING DEPARTMENT: Air Pollution Control District

OTHER CONCURRENCE(S): N/A

CONTACT PERSON(S):

ROBERT J. KARD ROBERT REIDER

Name Name

(858) 586-2700 (858) 586-2640

Phone Phone

(858) 586-2701 (858) 586-2701

Fax Fax

O-176 O-176

Mail Station Mail Station
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF PROPOSED 

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE 1997 

NATIONAL OZONE STANDARD (DISTRICT: All)

Robert.Kard@sdcounty.ca.gov Robert.Reider@sdcounty.ca.gov

E-mail E-mail