NATURAL RESOURCES DEFENSE COUNCIL

June 29. 2013

Rene M. Bermudez, Principle Air Quality Instrument Specialist

Jason Low, Atmospheric Measurements Manager

South Coast Air Quality Management District

21865 Copley Drive

Diamond Bar, CA 91765

rbermudcz(aaqmd.uov

Re: Comments oii the 2013 SCAQMD Annual Air Quality Monitoring Network Plan

Dear Mr. Bermuclez and Mr. Low,

On behalf of the Natural Resources Defense Council, Communities for a Better Environment,

East Yard Communities for Environmental Justice, and our thousands of members who live in

the South Coast Air Basin. we submit these comments on the South Coast Air Quality

Management District’s (SCAQMD” or District”) 2013 Annual Air Quality Monitoring

Network Plan (‘Plan”). We appreciate the District’s efforts to engage the public in the near-road

NO2site selection process and the thorough documentation of how the District followed EPA’s

Near-Road NO2Technical Assistance Document. In particular, we are pleased that the District

has chosen to have public workshops on the important issue of siting monitors in the region. We

support the District’s choices of near-roadway NO2sites, particularly the location along highway

710 at Del Arno. The District should collocate PM2 and CO monitors with each near—road NO2

site, and do this when each N02 monitor becomes operational. In addition, we are concerned

that the District seeking a waiver from EPA to avoid comparing PM2.5data from its Federal

Equivalent Method (‘FEM”) monitors to federal Clean Air Act standards.

1. The District should plan to start operating two near-roadway NO2sites in the

Los Angeles-Long Beach-Anaheim CBSA by January 1, 2014.

The District’s top picks for the near-road NO2site in the Los Angeles-Long Beach-Santa Ana

Core Based Statistical Area (CBSA”) are along Interstate 5 in Anaheim and Route 57/60 in

Diamond Bar. During the June 25, 2013 public workshop, the District explained that it is in the

process of securing leases for these sites. We support the District’s choice of those two sites.

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We urge the District to choose one of these sites for the first NO2 monitor, and establish a near—

road NO2 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 NO2site 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

NO2 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 NO2site 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 PM25 and CO monitors at each neat--road NO2site.

SCAQMD should collocate PM2.5and CO monitors at every neai--roadNO 2site, 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 PM2.5and CO monitors at all their near—

road NO2sites, and will do so for their first two required near—road NO2 monitors by January 1.

2014. Similarly. the New Jersey Department of Environmental Protection plans to collocate

their near—road PM2.5and CO monitors by January 1, 2014. We Lit-ge the District to establish the

PM2 5and CO monitors and begin collecting data early, even though the District has more time

to implement the PM2.5and CO near—roadway air monitors than for the collocated NO2 monitors.

Last year, we submitted comments urging the District to monitor PM2.5emissions near freeways.

Areas near freeways have higher concentrations of PM25 from traffic. The District confirmed in

its 2012 study on air pollutants near a freeway with heavy-duty diesel traffic that PM2.5

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. 2Neat-—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).

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unique source and are often representative of many similar situations, particularly in the South

Coast Air Basin, where fifty percent of residents live within 500 meters ofa road with greater

than 25,000 Annual Average Daily Traffic (AADT”). 3Air districts are required to collocate

one PM75 monitor at a near—road NO7site within each CBSA with one million people or more.

The Los Angeles-Long Beach-Santa Ana CBSA is home to over 13 million people 4and has the

two busiest container ports in the nation. Approximately 1.2 million Los Angeles County

residents live within 100 meters of a road with greater than 25,000 AADT. Given the high

populations in theses roadway adjacent areas, microscale PM25 monitoring is required because

they represent many such locations throughout a metropolitan area are considered to represent

area-wide air quality.” 5

In fact, given the seriousness of the health threat from freeways, we recommend more than the

minimum number of PM25 near—roadway monitors be put in the places in the South Coast Air

Basin.

As N RDC and Communities for a Better Environment commented in 2011 and 201 2, not

locating PM25 monitors near freeways violates section 107(a) of the Clean Air Act, which

requires that the State demonstrate its plan for attainment will meet NAAQS “within the entire

geographic area comprising suc[’i state.” The District’s 2013 Plan still fails to monitor

transportation facilities identified by EPA as ofair quality concern.” 6EPA found that

highway and transit projects that involve significant levels of diesel vehicle emissions have the

potential to increase local PM2.5concentrations.” 7Failure to monitor PM2.5in the impact zone of

such facilities where EPA determined that incremental PM25 concentrations occur means that

NAAQS violations caused by emissions from such facilities are not remedied by the next SIP for

PM2.5

EPA and the District can eliminate these violations by monitoring near—roadway PM2.5

emissions, or by applying highway scale monitoring as described in EPA’s Guidance on the

Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals lbr the 8—

I-Tour Ozone and PM2 NAAQS and Regional Haze.” If the District does not commit to

commencing local scale modeling, then adequate near—road PM2.5monitors must be included in

the monitoring network. For these reasons, the 2013 Plan fails to comply with the Clean Air Act

and applicable regulations.

Draft N RDC Report. Near Roathi’ay Emissions: Measurement, Exposure, and Mon ilorimig 1 9

(20 1 2) [attached here as “Attachment A”].

SCAQMD 2013 Draft Monitoring Network Plan at 22.

40 C.F.R. 58 Appx. D subpart 4.7.1(b).

671 Fed. Reg. 12,472 (Mar. 10, 2006).

7 Id.

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III. 1)ata from FEM PM2.5monitors show higher concentrations of PM2,5than 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 PM25

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 ofthese 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 NO2sites 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 PM25 and CO monitors at each near-road NO2 monitor, when the NO2

monitor becomes operational. The District needs to site PM2.5near-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.

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Moreover, the District must provide evidence to demonstrate that the continuous FEM monitors

do not provide accurate results to avoid comparing FEM-gathered data to NAAQS. Since these

comments are forwarded to EPA, if the District fails to address these comments, we respectfully

request that EPA disapprove the Plan and request that the agency provide a response to the

comments provided. We are happy to work with the District and EPA to address these concerns.

Please do not hesitate to contact LIS if you have questions about these comments.

Sincerely,

Melissa Lin Perrella Xiao Zhang

Senior Attorney Legal Fellow

Natural Resources Defense Council Natural Resources Defense Council

Maya Golden-Krasner

Staff Attorney

Communities for a Better Environment

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