CALIFORNIA AIR RESOURCES BOARD 

NOTICE OF PUBLIC MEETING TO CONSIDER APPROVAL OF THE IMPERIAL 

COUNTY 2009 1997 8-HOUR OZONE MODIFIED AIR QUALITY MANAGEMENT 

PLAN AND 2009 REASONABLY AVAILABLE CONTROL TECHNONOLGY STATE 

IMPLEMENTATION PLAN 

The Air Resources Board (ARB or Board) will conduct a public meeting at the time and 

place noted below to consider the approval of the proposed lmperial County 2009 1997 

8-Hour Ozone Modified Air Quality Management Plan (2009 Ozone Plan) and 2009 

Reasonably Available Control Technology State Implementation Plan (2009 RACT SIP) 

for the lmperial County Nonattainment Area. If approved by the Board, ARB will submit 

the 2009 Ozone Plan and 2009 RACT SIP to the United States Environmental 

Protection Agency (U.S. EPA) for approval as a revision to the California State 

Implementation Plan (SIP). 

DATE: November 18,2010 

TIME: 9:00 a.m. 

PLACE: California Environmental Protection Agency 

. Air Resources Board 

Byron Sher Auditorium 

1001 1 Street 

Sacramento, California 95814 

This item may be considered at a two-day Board meeting, which will commence at 

9:00 a.m., November 18, 2010, and may continue at 8:30 a.m., on November 19, 2010. 

This item may not be considered until November 19, 2010. Please consult the agenda 

for the meeting, which will be available at least ten days before Noverr~ber 18, 2010, to 

determine the day on which this item will be considered. 

Backaround 

The federal Clean Air Act (CAA) establishes planning requirements for areas that 

exceed the health-based National Ambient Air Quality Standards (NAAQS) and have 

been designated as nonattainment based on monitored exceedances of the NAAQS. 

Nonattainment areas must develop and implement SIPS that demonstrate how they will 

attain the NAAQS by specified dates. 

In 2004 U.S. EPA identified lmperial County as a "marginal" nonattainment area for the 

8-hour ozone IVAAQS promulgated in 1997. On February 13, 2008, U.S. EPA found 

that lmperial County had not attained the 1997 8-hour ozone NAAQS by the marginal 

area attainment deadline of June 15, 2007, and reclassified it as a "moderate" 

nonattainment area. Under the CAA, this action requires California to submit as a SIP 
revision a moderate area ozone plan for lmperial County, demonstrating attainment of 

the 8-hour ozone NAAQS by June 15,2010. 

On February 19, 2009, ARB submitted a clean data finding request for lmperial County 

to U.S. EPA. The request was based on certified air monitoring data recorded from 

2006 through 2008 that indicated attainment of the 1997 8-hour ozone NAAQS. In 

response to ARB'S request, on December 3, 2009, U.S. EPA published in the Federal 

Register its determination that lmperial County attained the 1997 8-hour ozone 

standard. This action suspended some CAA nonattair~ment area plan requirements. 

However, California is still required to submit revisions to the SIP to address remaining 

elements required for moderate ozone nonattainment areas, including rule review and 

adoption relative to the reasonably available control technology (RACT) requirements, 

emission inventories, and new source review requirements. 

On July 30, 2010, the lmperial County Air Pollution Control District adopted the 2009 

Ozone Plan and 2009 RACT SIP to address the CAA moderate area plan requirements. 

Proposed Action 

ARB staff has reviewed the lmperial County 2009 Ozone Plan and 2009 RACT SIP, and 

consulted with District staff during its review. ARB staff finds that the lmperial County 

2009 Ozone Plan and 2009 RACT SIP meet all applicable CAA requirements for a 

moderate nonattainment area. Staff recommends that the Board approve the lmperial 

County 2009 Ozone Plan and 2009 RACT SIP and direct the Executive Officer to 

submit them to U.S. EPA as revisions to the California SIP. 

Availability of Documents 

Copies of staffs written report may be obtained from ARB's Public Information Office, 

1001 1 street, First Floor, Environmental Services Center, Sacramento, California, 

95814, (916) 322-2990, beginning October 19, 2010. The report may also be obtained 

from ARB's website at http://www.arb.ca.qov/plannin~/sip/sip.htm. 

Submittal of Comments 

Interested members of the public may present comments orally or in writing at the 

meeting and may be submitted by postal mail or by electronic submittal before the 

meeting. To be considered by the Board, written comments submissions not physically 

submitted at the meeting must be received no later than 12:OO noon, 

November 17,2010, and addressed to the following: 

Postal mail: Clerk of the Board, Air Resources Board 

1001 1 Street, Sacramento, California 95814 

Electronic submittal: http://www.arb.ca.qovllispub/comm/bclist.~hp 
Please note that under the California Public Records Act (Government Code 

section 6250 et seq.), your written and oral comments, attachments, and associated 

contact information (e.g., your address, phone, email, etc.) become part of the public 

record and can be released to the public upon request. Additionally, this information 

may become available via Google, Yahoo, and any other search engines. 

The Board requests, but does not require 20 copies of any written submission. Also, 

ARB requests that written and email statements be filed at least ten days prior to the 

meeting so that ARB staff and Board members have time to fully consider each 

comment. Further inquiries regarding this matter should be directed to Mr. Dmitri Smith, 

Air Pollution Specialist, at (916) 323-1537. 

Special Accommodation Request 

Special accommodation or language needs can be provided for any of the following: 

An interpreter to be available at the hearing; 

Documents made available in an alternate format (i.e., Braille, large print, etc.) or 

another language; 

A disability-related reasonable accommodation. 

To request these special accommodations or language needs, please contact the Clerk 

of the Board at (916) 322-5594 or by facsirr~ile at 916) 322-3928 as soon as possible, 

but no later than 10 business days before the scheduled Board hearing. 

TTYrTDDlSpeech to Speech users may dial 71 1 for the California Relay Service. 

Comodidad especial o necesidad de otro idioma puede ser proveido para alguna de las 

siguientes: 

Un interprete que este disponible en la audiencia 

Documentos disponibles en un formato alterno (por decir, sistema Braille, o en 

impresion grande) u otro idioma. 

Una acomodacion razonable relacionados con una incapacidad. 

Para solicitar estas comodidades especiales o necesidades de otro idioma, por favor 

llame a la oficina del Consejo al (916) 322-5594 o envie un fax a (916) 322-3928 lo mas 

pronto posible, per0 no menos de 10 dias de trabajo antes del dia programado para la 

audiencia del Consejo. TNITDDlPersonas que necesiten este servicio pueden marcar 

el 71 1 para el Servicio de Retransmision de Mensajes de California. 

CALIFORNIA AIR RESOURCES BOARD 

James N. Goldstene 

Executive Officer 

Date: October 13, 201 0 

STAFF REPORT 

Analysis of the Imperial County 2009 1997 8-Hour Ozone 

Modified Air Quality Management Plan and 

Reasonably Available Control Technology Plan 

State of California 

AIR RESOURCES BOARD 

Date of Release: 

Scheduled for Consideration: Noverr~ber 18, 201 0 

California Environmental Protection Acrencv 

Air Resources Board 
This report has been reviewed by the staff of the California Air Resources Board 

and approved for publication. Approval does not signify that the contents 

necessarily reflect the views and policies of the Air Resources Board, nor does 

mention of trade names or corr~mercial products constitute endorsement or 

recommendation for use. 
Table of Contents 

1 . Introduction .................................................................................................... 1 

II . Background ................................................................................................... -2 

Ill . Moderate Area Requirements ........................................................................ 4 

IV . Evaluation of the Imperial County Modified Plan ........................................... 6 

A . Attainment of the 1997 &Hour Ozone Standard .................................................. 6 

B . Moderate Nonattainment Area Requirements ...................................................... 8 

V . 2009RACTSIP ........................................................................................... I1 

VI . Staff Recommendations .............................................................................. I I 

This staff report reviews plans adopted by the lmperial County Air Pollution 

Control District to address federal Clean Air Act (CAA) nonattainment area plan 

requirements applicable to moderate ozone nonattainment areas. 

With the promulgation of the 1997 8-hour ozone National Ambient Air Quality 

Standard (NAAQS) in April 2004, the United States Environmental Protection 

Agency (U.S. EPA) classified lmperial County as a marginal nonattainment area. 

On February 13, 2008, U.S. EPA found that lmperial County had not attained the 

1997 8-hour ozone NAAQS by the marginal area deadline of June 2007, and 

reclassified the County as a moderate nonattainment area. U.S. EPA's action 

also required the State to submit a moderate area SIP for the lmperial County 

nonattainment area, by December 31, 2008, that demonstrates attainment of the 

8-hour ozone standard by June 15,2010. 

On February 19, 2009, ARB requested that U.S. EPA make a "clean data" finding 

for lmperial County. The request demonstrated that the area's 2008 design 

value for the 8-hour ozone NAAQS, which was based on monitoring data 

collected from 2006 through 2008, showed attainment of the standard. U.S. EPA 

issued its clean data finding on December 3, 2009. 

A clean data finding does not constitute a redesignation to attainment under the 

national CAA, so lmperial County remains a moderate nonattainment area. The 

clean data finding suspended some CAA nonattainment area plan requirements. 

However, the State is still required to subrr~it revisions to the SIP to address 

remaining elements required for moderate ozone nonattainment areas, including 

rule review and adoption relative to the reasonably available control technology 

(RACT) requirements, emission inventories, and new source review 

requirements. 

On July 30, 201 0, the lmperial County Air Pollution Control District adopted the 

2009 1997 &Hour Ozone Modified Air Quality Management Plan (2009 Ozone 

Plan) and 2009 Reasonably Available Control Technology State Implementation 

Plan (2009 RACT SIP) to address the CAA moderate area plan requirements. 

ARB staff reviewed the lmperial County 2009 Ozone Plan and RACT SIP and 

find that both plans meet all applicable CAA requirements for a moderate 

nonattainment area. Staff recommends that the Air Resources Board adopt the 

lmperial County 2009 Ozone Plan and the 2009 RACT SIP and direct the 

Executive Officer to submit the plans to U.S. EPA as proposed revisions to the 

California SIP. 
II. Background 

Profile of lmperial County 

lmperial County is part of the Salton Sea Air Basin. The lmperial County Ozone 

Nonattainment Area consists of the entire county, and is under the jurisdiction of 

the lmperial County Air Pollution Control District (District). 

lmperial County covers 4,482 square miles of mostly arid lands in the 

southeastern corner of California. It is bordered by Mexico to the south, Arizona 

on the east, San Diego County on the west, and Riverside County on the north. 

lmperial County's elevation ranges from more than 2,800 feet on the mountain 

summits to the east to 230 feet below sea level in the Salton Sea. Winters are 

mild and dry with daily average temperature ranges between 65 and 75OF, 

although daily high terr~peratures of up to 80°F are not uncommon. Summers are 

extremely hot with daily average temperature ranges between 104 and 11 5OF 

and daily high temperatures of up to 120°F. The County has an annual rainfall of 

approximately 3 inches, occurring mostly from late summer to midwinter. 

lmperial County has a population of approximately 180,000 people. The 

County's major population centers include the cities of El Centro (25 percent of 

the county population), Calexico (22 percent), and Brawley (I 5 percent). 

Approximately 22 percent of the population resides in unincorporated areas. 

Mexicali, Mexico - a city of approximately 900,000 people - spreads southward 

from the CaliforniaIMexico border at lmperial County. Mexicali's residential and 

industrial centers begin less than 5 miles from Calexico and 15 and 25 miles, 

respectively, from El Centro and Brawley. Because the New River is the only 

geographical feature separating lmperial County from Mexicali, air pollution 

transport between the two areas is possible. ARB'S June, 1993 transport 

assessment report identified Mexico as the source of emissions that caused or 

contributed to some of the exceedances of the state ozone standard recorded in 

Imperial County from 1989 to 1991 '. 

Air Quality History 

Ozone air quality has improved significantly in lmperial County in recent years as 

shown by both the number of days in which ozone values exceed the 8-hour 

ozone NAAQS (exceedance days) and the recorded daily high ozone 

concentrations. In 1997, lmperial County exceeded the 1997 8-hour ozone 

NAAQS of 0.085 parts per million (0.085 ppm), also expressed as 85 parts per 

billion (85 ppb), on 50 days. In 2009, the number of exceedance days declined 

to 2. Table 1 shows the progressive decrease in exceedance days at each 

routine monitoring site in lmperial County. 

' Air Resources Board, Assessment and Mitigation of the Im~acts of Transported Pollutants on Ozone 

Concentrations in California, June 1993 

-2- 
Table 1 

lmperial County Exceedance Days, 8-Hour Ozone NAAQS 

2001 - 2009 

Westmorland 1 0 0 0 10 5 5 2 1 

Figure 1 shows the federal design value trend in lmperial County from 2001 to 

2009 and the respective 1997 8-hour ozone standard. The SIP design value is 

based on the fourth highest value recorded each year, averaged over three 

consecutive years. lmperial County's 8-hour ozone design value has decreased 

by ten percent since 2001, and now meets the 1997 federal NAAQS. 

When compared to other indicators such as peak concentrations, the design 

value is a more stable indicator for evaluating year to year changes resulting 

from emission control programs, and is the only indicator that can be used to 

determine compliance with the NAAQS. Peak concentrations measure the 

severity of ozone exposure but not the frequency, and can be influenced by year 

to year weather variations. 

The U.S. EPA is in the process of revising the 8-hour ozone NAAQS, and is 

expected to promulgate its revised standard in late 201 0. The range of values 

the agency is considering for the new NAAQS -from 0.070 ppm to 0.060 ppm 

(70 ppb to 60 ppb) - is from 29 percent to 17 percent more stringent than the 

current 8-hour ozone NAAQS of 0.085 ppm. Recent monitoring data suggests 

that lmperial County will be designated as nonattainment for the new standard. 
Figure 1 

Imperial County Design Value 

- s . -8-Hour Ozone Design Value 

8-Hour Ozone Standard 

Year 

Ill. Moderate Area Requirements 

On December 3, 2009, U.S. EPA published its finding that Imperial County 

attained the 1997 8-hour ozone standard. U.S. EPA's "clean data finding" 

suspends certain SIP elements including the attainment demonstration, 

reasonable further progress demonstration, and contingency measures 

requirements. However, some SIP requirements remain, and some were added 

when U.S. EPA reclassified Imperial County from marginal to moderate. Table 2 

shows SIP elements required for marginal and moderate area plans, and identify 

the SIP elements suspended by the clean data finding. 
Table 2 

Marginal - and Moderate Ozone Nonattainment Area SIP Requirements and 

Clean Data Finding Elements 

requirement suspended with 

.-- clean data finding 

x 

x 

x 

x 

Note: N/A in Imperial County 

because of population (<200,000) 

moderate 

area 

x 

x 

x 

x 

x 

Ozone Part D SIP 

Requirement 

marginal 

area 

Note: Stage 2 GVR no longer required in 

moderate ozone areas per Onboard Refueling 

Vapor Recovery rule. CAA 202(a)(6); 59 FR16262 

(April 6, 1994). 

x 

x 

x 

x 

x 

x 

1.15 to 1 

Stage 2 Gasoline Vapor 

Recovery (1 82(b)(3)) 

Emissions Inventory 

(1 72(c)(3), 182(a)(l) 

New Source Review 

(1 72(c)(4) and (5); 

182(a)(2)(C)) 

Infrastructure SIP (1 72(c)(7)) 

Subpart 2 Reasonably 

Available Control Technology 

for VOCs and NOx (1 82(b)(2), 

182(f)) 

Periodic Inventory 

(1 82(a)(3)(A)) 

Emissions Statement Rule 

(1 82(a)(3)(B)) 

Offset Ratio (1 82(a)(4); 

182(b)(5)) 

x 

x 

x 

x 

x 

1.1 to 1 

Attainment demonstration 

(1 82(b)(l)) 

Subpart 1 Reasonably 

Available Control Measures 

(172(c)(l)) 

Reasonable Further Progress 

(1 72(c)(2), 182(b)(l)) 

Contingency measures 

(1 72(c)(9)) 

Vehicle 

InspectionIMaintenance 

(1 82(a)(2)(B), (b)(4)) 

x 

x 
IV. Evaluation of the lmperial County Modified Plan 

ARB staff has reviewed the lrnperial County 2009 Ozone Plan and the District's 

supporting technical analysis, and determined that the plan meets CAA SIP 

requirements for moderate ozone nonattainment areas. The following sections 

describe the major elements of the plan. 

A. Attainment of the 1997 8-Hour Ozone Standard 

On February 19, 2009, ARB requested that U.S. EPA make a "clean data" finding 

for lmperial County. The request demonstrated that the area's 2008 design 

value for the 8-hour ozone NAAQS, which was based on monitoring data 

collected from 2006 through 2008, show attainment of the 1997 8-hour ozone 

NAAQS. On December 3, 2009, U.S. EPA published a clean data finding for 

lmperial County. Subsequent monitoring data show that the County continues to 

meet the 1997 8-hour ozone standard. Figure 2 illustrates the lmperial County 

ozone nonattainment area and monitoring locations. 

Figure 2 shows the location of routine ozone monitoring stations in lmperial 

County. The number of routine ozone monitoring sites in lmperial County 

exceeds the monitoring density required in federal regulations for a county of 

approximately 180,000 residents (40 CFR Part 58, Appendix D). 
Finure 2 

Map of Imperial County and Monitoring Stations 

6 - Calexim East 

Table 3 shows the Imperial County air monitoring stations design values for 2006 

through 2009, representing 2004 through 2009 monitoring data. The design 

values for all of the monitoring sites are at or below the mandated 0.085 ppm 

threshold. The El Centro gth Street and Westmorland started with the highest 

design values; both show a trend of improving air quality. The design values for 

the Niland and Calexico-East sites show slight upward trends, but in both cases 

are still well below the 1997 8-hour ozone standard. On the map above, a dot 

represents an air monitoring station. 
Table 3 

Imperial Monitoring Station County Design Values 

(PP~) 

Calexico East 

Design values impacted by the deletion of June 2007 through October 2007 data due to 

monitoring irregularities. 

Pollution transport from Mexico contributed to high readings in some ozone 

exceedance days in Calexico, and possibly in some other Imperial County sites. 

The CAA allows the exclusion of concentrations caused by transport from 

another country in the development of attainment demonstration plans. This plan 

does not utilize international transport exclusion since the clean data finding does 

not rely on the transport argument. 

B. Moderate Nonattainment Area Requirements 

As discussed earlier, U.S. EPA's clean data finding suspends certain SIP 

requirements. This section reviews the elements that the District submitted to 

fulfill the remaining moderate area nonattainment requirements. 

New Source Review and Offset Ratio 

Federal New Source Review (NSR) regulations are applied to the siting and 

modification of sources that are located in areas designated as federal 

nonattainment for NAAQS. The purpose of federal NSR is to ensure that 

ambient air quality does not deteriorate any further in nonattainment areas. 

Imperial's SIP-approved NSR rule, Rule 207, was adopted by the Imperial 

County Air Pollution Control Board on November 10, 1980. The CAA requires 

moderate nonattair~ment areas to have offsets ratios of 1 .I 5 to 1. Rule 207 has a 

1 .I 5 to 1 offset ratio for ozone precursors. This rule and the offset ratio fulfill the 

requirements of the CAA. 
RACT Analysis 

The District completed its RACT analysis in a separate document (please refer to 

Section V). The Imperial County Air Pollution Control Board adopted the 2009 

RACT SIP at the July 13, 2010, Board meeting. 

Emissions Inventory 

The precursors of ozone are oxides of nitrogen (NOx) and reactive organic gases 

(ROG). Mobile sources contribute the bulk of Imperial County's NOx emissions 

with heavy duty trucks clearly leading locomotives, and passenger vehicles as 

the top source (Table 4). Livestock waste, passenger vehicles, and pesticides 

constitute the top sources for ROG emissions (Table 5). ROG and NOx 

emissions decreased significantly in these categories between 2002 and 2009, 

as did total emissions, as shown in Tables 4 and 5. 

The Emission Statement Rule requires the owner or operator of each stationary 

source that emits NOx or ROG to provide a statement for classes or categories 

of sources showing the actual emissions. The Imperial County Air Pollution 

Control Board adopted an Emissions Statement and Certification Rule on 

February 23, 2010. 

Air Quality Planning 

In developing this plan, the District held regularly scheduled SIP working group 

meetings that included various community representatives, health, 

environmental, and industry and military representatives, local and county 

governments, and state and federal agencies. The meetings were initiated in 

March 2008 and ended in June 2009. The District also posted drafts of the 2009 

Ozone Plan on their website throughout the process. 
Table 4 

Imperial County NOx Sources 

11 lmnerial Countv - Ton Sources of NOx (tons ner davl 11 1) Rank (2002) I Source Category I 2002 1 2009 I 

1 I HEAVY DUTY DIESEL TRUCKS 11 2 I LOCOMOTIVES 7 5 

7 

8 

9 

11 TOP 10 CATEGORIES PERCENT OF TOTAL 1 96% 1 95% 11 

10 I AGRICULTURAL IRRIGATION PUMPS 

TOP 10 CATEGORIES TOTAL 

TOTAL EMISSIONS 

Numbers may not add due to rounding 

"Top 10" categories are prioritized by 2002 emissions 

MANUFACTURING AND INDUSTRIAL (BOILERS, IC ENGINES) 

MANAGED BURNING AND DISPOSAL 

AIRCRAFT 

Table 5 

Imperial County ROG Sources 

1 

36 

37 

Imperial County -Top Sources of ROG (tons per day) 11 Rank l2OO2l I Source Cate~orv I 2002 1 2009 

1 

1 

1 

1 

31 

32 

II 1 I LIVESTOCK WASTE 19 1.6 11 

2 

2 I PASSENGER VEHICLES 17 1 11 3 I PESTICIDES 3 

11 6 I ASPHALT PAVING / ROOFING 121211 

1 

7 I CONSUMER PRODUCTS 111 11 8 I AIRCRAFT 1112 11 

9 I HEAVY DUTY DIESEL TRUCKS 111 11 10 I RECREATIONAL BOATS 1111 

4 

11 TOP 10 CATEGORIES TOTAL 1 33 1 27 11 

OFF-ROAD RECREATIONAL VEHICLES 131 

MANAGED BURNING AND DISPOSAL I2l2 

The District released the draft 2009 Ozone Plan and the 2009 RACT SIP on June 

13, 2010 following several months of coordinated efforts between District staff 

and the SIP working group. The District released a notice of public hearing for 

the adoption of the 2009 Ozone Plan and associated negative declaration 30 

days prior to its Board meeting, and held two public workshops to discuss both 

the 2009 Ozone Plan and 2009 RACT SIP. 

1 

TOTAL EMISSIONS 

TOP 10 CATEGORIES PERCENT OF TOTAL 

Numbers may not add due to rounding 

"Top I0 categories are prioritized by 2002 emissions 

3 7 

87% 

3 2 

86% 
Air Pollution Transport 

Since lmperial County in effect shares an air basin with the Baja California city of 

Mexicali, ozone levels in southern part of the county are likely impacted by 

emissions from Mexico. The CAA allows states to demonstrate that an area , 

would have attained the NAAQS by the applicable attainment date but for 

emissions emanating from outside of the United States (CAA section 179B(b)). 

lmperial County's 2009 Ozone Plan does not utilize the international transport 

provision since it was not needed to demonstrate attainment of the 1997 8-hour 

ozone NAAQS. However, ARB has previously assessed the impacts of 

transported pollutants on violations of the State Ambient Air Quality Standard 

(SAAQS) for ozone, and determined that transport from Mexico can cause or 

contribute to high ozone levels in lmperial County. ARB, the local District, and 

U.S. EPA continue to coordinate on efforts to improve air quality and reduce 

transported pollutants throughout the border region. 

V. 2009 RACT SIP 

Ozone non-attainment areas classified as moderate or above are required by 

CAA sections 182(b)(2) and 182(f) to implement RACT for sources subject to 

Control Techniques Guideline (CTG) documents and for all major sources of 

VOC and NOx that are not subject to a CTG. The 2009 RACT SIP fulfills CAA 

requirements for a moderate area, and ARB staff recommends that it be 

submitted as a SIP revision simultaneously with the 2009 Ozone Plan. The 

District worked closely with U.S. EPA and stakeholders as it prepared its RACT 

SIP. The District also released a public notice 30 days prior to its Board hearing, 

and held two workshops to discuss the draft 2009 RACT SIP. On July 13,2010, 

the lmperial County Air Pollution Control Board adopted the 2009 RACT SIP. 

VI. Staff Recommendations 

ARB staff has reviewed the lmperial County 2009 Ozone Plan for the lmperial 

County ozone nonattainment area, including the 2009 RACT SIP, and consulted 

with District staff during its review. ARB staff finds that the lmperial County 2009 

Ozone Plan and 2009 RACT SIP meet all applicable CAA requirements for a 

moderate nonattainment area. Staff recommends that the Board adopt the 

lmperial County 2009 1997 8-Hol.~r Ozone Modified Air Quality Management Plan 

and 2009 Reasonably Available Cor~trol Technology State Implementation Plan, 

and direct the Executive Officer to submit them to U.S. EPA as proposed 

revisions to California's SIP.