NATURAL RESOURCES DEFENSE COUNCIL
June 29. 2013 Rene M. Bermudez, Principle AirQuality Instrument Specialist Jason Low, Atmospheric Measurements Manager South Coast

### AirQuality ManagementDistrict 21865 Copley Drive Diamond Bar, CA 91765 rbermudcz(aaqmd.uov

Re: Comments oii the 2013 SCAQMD AnnualAir Quality MonitoringNetworkPlan Dear

### Mr. Bermuclez and Mr. Low, On behalfofthe Natural Resources Defense Council, Communities fora Better

### Environment, East

### Yard Communities for Environmental Justice, and ourthousands 

### ofmembers who live 

### in the South CoastAir Basin. we submitthese comments on the South Coast

### AirQuality Management District’s (SCAQMD” 

### orDistrict”) 2013 

### Annual Air Quality Monitoring 

### Network Plan (‘Plan”). We appreciatethe District’s effortsto engage the public 

### inthe near-road NO 2 site selection process and the thorough documentation of

### howthe Districtfollowed EPA’s Near-RoadNO 2 Technical Assistance Document. In particular, we are pleased thatthe District has chosen to have public workshops 

### onthe 

### important issue ofsiting monitors in the region. We supportthe District’s choices ofnear-roadway NO 2 sites, particularlythe location along highway 710 at Del Arno. The Districtshould collocate PM 2 and CO monitors with each near—roadNO 2 site, 

### and do this when eachN02 

### monitorbecomes operational. In addition, we are concerned thatthe District seeking a waiverfrom EPA

### to avoid comparing PM 2

. 5 data from its Federal EquivalentMethod (‘FEM”) monitors to federal Clean AirAct standards. 1. TheDistrictshould plan to startoperating 

### two near-roadway NO 2 sites in the Los Angeles-Long Beach-Anaheim CBSA by January 1, 2014. 

### The District’s top picks 

### forthe near-roadNO 2 site 

### in the Los Angeles-Long Beach-SantaAna Core Based Statistical Area(CBSA”) are along Interstate 5 in Anaheim and Route 57/60 

### in Diamond Bar. During theJune 25, 2013 public workshop, the Districtexplained that it is 

### in the process ofsecuring leases forthese sites. We supportthe District’s choice ofthose two sites. www.nrdc.org 1314 Second Street NEW YORK

. WASHINGTON, DC SAN FRANCISCO BEIJING CHICAGC SantaMonica. CA 90401 TEL310 434-2300 FAX 310 434-2399 ?‘ycsd 

# NRDC

THE EARTH’S BEST DEFENSEWe urge the District to choose one of these sites for the first NO 2 monitor, and establish a near— road NO 2 monitor on the 7 10 at Del Amo as the second site. The 710 freeway site should become operational by .January 1. 2014. at the same time that the first near-road NO 2 site becomes operational. During the public workshop. the District confirmed that it already has a lease at the 710 freeway site and would he able to establish an NO 2 monitor by January 2014. As the District is well aware, the 710 freeway has among the highest percentage of trucks in the air basin. Communities around the 710 freeway are populated by low—income or minority groups, who face air pollution from freeways as well facilities and port activities. As we discussed in the public workshop on Juiie 25. 2013. the 710 freeway site is an ideal place for a second near-road NO2 monitor. The second near-road NO 2 site should be different from the first by factors including fleet mix, geographic location, among others. Mr. Low expressed during the workshop that the District would like to select the 710 segment because the percentage of trucks there, over 14 percent, is much higher than on the other two candidate roads. The 710 segment’s unique characteristics make it an excellent choice for the second nearroad monitoring site. We strongly support the District’s selection of the 710 freeway site. II. The District should collocate PM 25 and CO monitors at each neat--road NO 2 site. SCAQMD should collocate PM 2 . 5 and CO monitors at every neai--roadNO 2 site, and do so when each site becomes operational. Other air districts around the country are taking this initiative.

For instance, the Bay Area AQMD committed to siting PM 2 . 5 and CO monitors at all their near— road NO 2 sites, and will do so for their first two required near—road NO 2 monitors by January 1. 2014. Similarly. the New Jersey Department of Environmental Protection plans to collocate their near—road PM 2 . 5 and CO monitors by January 1, 2014. We Lit-ge the District to establish the PM2 5 and CO monitors and begin collecting data early, even though the District has more time to implement the PM 2 . 5 and CO near—roadway air monitors than for the collocated NO 2 monitors. Last year, we submitted comments urging the District to monitor PM 2 . 5 emissions near freeways. Areas near freeways have higher concentrations of PM 25 from traffic. The District confirmed in its 2012 study on air pollutants near a freeway with heavy-duty diesel traffic that PM 2 . 5 concentrations near the 710 freeway can be up to 23.5% higher than on average in the South Coast. EPA states that heavily-travelled roadways should not be considered unique and unrepresentative of other near—road situations. 2 Neat-—road, or ‘traffic corridors.” are not a South Coast Air Quality Management District. Ambient Concentrations Of Criteria And Air

Toxic Pollutants In Close Proximity To A Freeway With Heavy-Duty Diesel Traffic A-b (Apr. 20 12). available al

2 Fed. Reg. 39,008 (Jun. 29. 2012). Page 2 of 5unique source and are often representative ofmany similar situations, particularly in the South CoastAir Basin, 

### where fifty percentofresidents live within 

### 500 meters ofaroad 

### with greater than 25,000 Annual Average Daily Traffic (AADT”). 3 Airdistricts are requiredto collocate 

### one PM 75 

### monitorat anear—roadNO 7 site within each CBSA with 

### one million people 

### ormore. The Los Angeles-Long Beach-SantaAnaCBSA is hometo over 13 million people 4 

### and has the two busiestcontainerports 

### in the nation. Approximately 1.2 million Los Angeles County residents live within 100 meters ofaroad with greaterthan 25,000 AADT. Given the high populations 

### intheses roadway adjacent areas, microscale PM 25 monitoring is required because they represent

### many such locations throughoutametropolitan areaare consideredto represent area-wide 

### airquality.” 5 In fact, given the seriousness of

### the health threat

### from freeways, we recommend 

### morethan the 

### minimum numberofPM 25 

### near—roadway monitors beput 

### inthe places 

### in the South CoastAir Basin. As NRDC and Communities fora BetterEnvironmentcommented in 2011 and 201 2, not locating PM 25 monitors 

### nearfreeways violates section 107(a) of

### the Clean AirAct, which requires thatthe State demonstrate its plan forattainmentwill meetNAAQS “within the entire geographic areacomprising suc[’istate.” The District’s 2013 Plan still fails to monitor transportation facilities identifiedby EPA as ofairquality concern.” 6 EPA found that highway 

### and transitprojects that involve significant levels ofdiesel vehicle emissions have the potential to increase local PM 2

. 5 concentrations.” 7 Failure to monitor PM 2

. 5 

### in the impact

### zone of such facilities 

### where EPA determinedthat incremental PM 25 concentrations occurmeans that NAAQS violations caused by 

### emissions from such facilities are notremedied by the next SIP for PM 2

. 5 EPA and the District can eliminate these violations by monitoring near—roadway 

### PM 2

. 5 emissions, 

### orby applying

### highway scale monitoring as described 

### in EPA’s Guidance 

### on the Use ofModels 

### and OtherAnalyses for

### Demonstrating Attainmentof

### Air Quality Goals lbrthe 8— I-Tour Ozone and PM 2 NAAQS and Regional Haze.” 

### Ifthe District does notcommitto 

### commencing local scale modeling, then adequate near—road PM 2

. 5 monitors mustbe included 

### in the 

### monitoring network. Forthese reasons, the 2013 

### Plan fails 

### to comply with the Clean AirAct and applicable regulations.

DraftNRDC Report. 

### NearRoathi’ayEmissions: Measurement, Exposure, andMonilorimig 19 

### (201

### 2) [attached here as “AttachmentA”].

SCAQMD 2013 Draft MonitoringNetwork Plan at

### 22. 40 C.F.R. 58 Appx. D subpart4.7.1(b). 671 Fed. Reg. 12,472 (Mar. 10, 2006). 7Id. Page 3 of5III. 1)ata from FEM PM 2 . 5 monitors show higher concentrations of PM 2 , 5 than data from FRM monitors, and should be used for comparison to NAAQS. The purposes of the monitoring plan are threefold: “(a) Provide air pollution data to the general public in a timely manner. . . (b) Support compliance with ambient air quality standards and emissions strategy development... (c) Support for air pollution research studies....” EPA sets out specific location and data quality requirements so that a monitoring plan will meet these three criteria. “Monitoring sites must be capable of informing managers about many things including the peak air pollution levels, typical levels in populated areas, air pollution transported into and outside ofa city or region. and air pollution levels near specific sources.” 9 The District’s monitoring network includes 15 FEM monitors, which provide continuous PM 25 information. 0 The District intends to use FEM monitoring data to satisfy public notification requirements, hut seeks a waiver from EPA to avoid comparing FEM-gathered data to NAAQS. The District’s stated concern is that FEM-gathered data includes “semi-volatile” PM- 5 . According to the District, “[t]he measurement of these PM components (ammonium nitrate. organic compounds. water) are highly dependent on temperature, humidity, sample handling, and thus method.” 12 Indeed, the District explained that results are up to 60% greater at FEM monitors than at traditional, Federal Reference Method (“FRM”) monitors. The District does not explain in this plan or presentation, however, why continuous monitoring would not, in fact, be yielding more accurate results than the FRM monitors, which can take several weeks to process. We urge the District to include FEM monitor data both for air pollution data purposes and to compare regional air quality with NAAQS.

IV. Conclusion For the reasons above, we respectfully request that the District place two near-road NO 2 sites in the Los Angeles-Long Beach-Anaheim CBSA by January 1. 2014, one at Interstate 5 in Anaheim or Route 57/60 in Diamond Bar, and the second along the 710 freeway at Del Amo. We also ask the District to collocate PM 25 and CO monitors at each near-road NO 2 monitor, when the NO 2 monitor becomes operational. The District needs to site PM 2 . 5 near-roadway monitors now to

ensure that residents in the entire air basin breathe air that meets federal clean air standards. 840 C.F.R 58 Appx. D subpart 1.1. 40 C.F.R 58 Appx. D subpart 1.1.1. 10 SCAQMD 2013 Draft Monitoring Network Plan at 15. Id. 12 SCAQMD June 25, 2013 Monitoring Workshop Presentation, slide 25, available cit http://www.aqmd.gov/tao/AQ-Reports/AQMon itoringNetworkPlan/ Workshop-Presentation DraftNetworkP lan.pdf. Page 4 of 5

### Moreover, the Districtmustprovide evidenceto demonstratethatthe continuous FEM monitors do notprovide accurate results to avoid comparing FEM-gathered datato NAAQS. Since these 

### comments are forwardedto EPA, ifthe District fails to address these comments, we respectfully requestthatEPA disapprove the Plan and requestthatthe agencyprovide aresponseto the comments provided. We are happyto workwiththe Districtand EPAto address these concerns. Please do nothesitateto contact LIS 

### ifyou have questions aboutthese comments. 

### Sincerely,

Melissa Lin Perrella Xiao Zhang SeniorAttorney Legal Fellow Natural Resources Defense 

### Council Natural Resources Defense Council Maya Golden-Krasner StaffAttorney Communities fora Better

### Environment

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### 5 of5