San Joaquin Valley Air Pollution Control District June 25, 2013

Appendix G: Comments and Responses Annual Air Monitoring Network Plan



## APPENDIX G: Comments and ResponsesSan Joaquin Valley Air Pollution Control District June 25, 2013

Appendix G: Comments and Responses Annual Air Monitoring Network Plan 

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Appendix G: Comments and Responses G-1 Annual Air Monitoring Network Plan 

## Appendix G: Comments and Responses

This Appendix contains responses to comments made b y the public on the Annual Air Monitoring Network Plan (Plan). The District held a 30-day public inspection period on the Plan from March 18, 2013 through April 18, 2013

.

G.1 WRITTEN COMMENTS ON THE 2012 AIR MONITORING NET WORK PLAN

Comment period held from March 18, 2013 through Apr il 18, 2013.

Comments were received from the following organizat ion:

Earthjustice

Earthjustice’s April 18, 2013 comment letter refere nced and incorporated a previous comment letter dated October 18, 2012. The materia l below combines comments from
both letters.

Comment: Earthjustice asks for more details about District’ s rationale on air monitoring site mergers, site closures, and the siting of NO 2 

### near-road monitoring sites.

Response: The District has determined that closing and/or con solidating certain sites will streamline operations and reduce maintenance c osts without compromising National Ambient Air Quality Standards (NAAQS). Str eamlining operations and reducing
costs will allow the District to use the resources for other air monitoring purposes, such as, adding additional capabilities to existing site s and decreasing down time of the analyzers. The NO 2 

### near-road monitoring documentation contained in App endixes D and E has all of the required information that EPA needs to approve the site locations and closely follows the Technical Assistance Docume nt published by EPA.

Comment: The Plan requirements are described in the introduc tion but the criteria on which they are based are not explained in detail. For example, what population threshold is used for determining population sites? If a threshold was not used, how were those sites determined? Also, brief descriptio ns of each of the monitoring sites are provided in Appendix A and B but specific informati on about the area within which the sites are located is not provided.

Response: For each monitoring site, the District’s network pl an provides information on criteria listed in 40 CFR Part 58 Subpart B Section 58.10 which includes objective and spatial scale of representativeness. For more deta iled information on the objective and spatial scales, site types, and population please r efer to 40 CFR 58 Appendix D.

Comment: The District notes that the California Regional Par ticulate Air Quality Study (CRPAQS) is the basis of the PM2.5 monitoring netwo rk and that the completion date of the final report is expected to be June 2012. Has the report been completed? If so,San Joaquin Valley Air Pollution Control District June 25, 2013

Appendix G: Comments and Responses G-2 Annual Air Monitoring Network Plan 

### please make it available to the public. How did th e study influence the District’s network design?

Response: Data collection for the study has been completed an d many reports have been finalized and published. In addition, many pe er reviewed scientific and journal articles have appeared in a wide variety of scienti fic publications. The results of this study are used in air quality modeling and in the D istrict’s SIPs. These results aid in the understanding of the formation of air pollution and the areas of the District which have the worst air quality. All of this knowledge as co ntributed to the design of the air monitoring network. The final synthesis document, a summary of findings, is not yet complete, but the studies and analysis have been co nsistently used by the District as they have become available. Information on CRPAQS i s available to the public on the Central California Air Quality Studies page of the California Air Resources Board
website at http://www.arb.ca.gov/airways/CRPAQS/default.htm

.

Comment: The District states that the Bakersfield-Muni PM2. 5 and PM10 monitors met the criteria for a move under 40 CFR Part 58, howev er it did not request or receive approval from the Regional Administrator as require d under 40 CFR Part 58.14(b) prior to shutting down the monitors.

Response: As stated in Appendix C of the Plan, the PM analyze rs were shut down when the District realized that the AMS was not sit ed correctly for PM monitoring. In order for an AMS to have NAAQS comparable data, it needs to be sited in accordance with federal regulation. Appendix C provides all o f the necessary documentation. The
District will work with EPA and ARB to ensure that all the necessary requirements are
addressed.

Comment: Regarding the reason for shutting down the PM monit ors at BakersfieldMuni, the rationale suggests that the District is o perating under a definition of “ambient air” that differs from the definition found in 40 C FR 50.1.

Response: The District was using the term “ambient air” in co njunction with neighborhood scale which PM sites are intended to m easure. Specifically, a neighborhood scale site measures ambient air with r elatively consistent PM concentrations over an area of 50.2 square kilomete rs or 19.3 square miles.

Comment: Considering the severe public health consequences o f the District’s poor air quality, the District should prioritize the mainten ance of a comprehensive and reliable air monitoring network by adhering to pertinent regulat ions.

Response: The District strives to maintain its comprehensive air monitoring network and the network’s reliability through the efforts o f its staff of experts in accordance with regulations outlined in 40 CFR. Currently, the air monitoring network exceeds federal requirements and the District continues to enhance the network as additional requirements, such as NO 2 

### near-road monitoring, are promulgated.April 18, 2013

Jennifer Ridgway San Joaquin Valley Air Pollution Control District 1990 East Gettysburg Avenue
Fresno, CA 93726

Re: San Joaquin Valley Air Pollution Control District Annual Air Monitoring Network Plan, March 19, 2013

Dear Ms. Ridgway,

Thank you for the opportunity to submit additional comments on the San Joaquin Valley Air Pollution
Control District’s (“District”) An nual Air Monitoring Network Plan (“Plan”). These comments build upon
the comments provided in October 2012 on the September 13, 2012 draft of the Plan , and are
submitted on behalf of the Central Valley Air Quality Coalition, Greenaction, and the Coalition for Clean

Air

. The October 2012 comment letter is attached for your review

. T his letter reiterates the request that

the District provide more detailed information about its decision

- making process with respect to
monitoring site closures and consolidations . Without that information, the Plan does not fully

communicate the District’s approach toward maintaining and improving its air monitoring network.
Given the importance of the monitoring network in documenting progress toward attainment and
improving publ ic health, this Plan is a key tool in meeting the Valley’s air quality goals and should clearly
explain the District’s air monitoring activities to the public

.

Despite soliciting public comment on the September 13, 2012 draft of the Plan, the District did not acknowledge or respond to comments received. District staff reported that comments on the earlier
draft of the Plan were no longer thought to be relevant given the numerous changes made between the
September 2012 and March 2013 drafts of the Plan. How ever, comments that Earthjustice filed in

October 2012 asked for more detailed information about sites that is not included in the March 2013
draft. As just one example, the October 2012 comments stated:

Although the District describes the Plan requiremen ts in the introduction, the criteria behind those requirements are not fully explained. For example, on page 7, 1 the Plan details the different monitoring site types, such as sites near the highest pollutant concentrations, sites in areas of high populatio n density, and sites to identify background concentration levels. This section would be more helpful if it described how the District assigned specific monitors to the different site types. For sites in high population areas, what is the population thresho ld used to determine which sites fall under the “population oriented” site type? Or, if a threshold is not used, how are

1 Starts on page 8 in the March 19, 2013 draft of the Plan.Jennifer Ridgway, San Joaquin Valley Air Pollution Control District

April 18, 2013
Page 2 of 3

those sites determined? Similar questions should be answered for the

remainder of the site types.

The section of the Plan to which thes e comments refer was not updated in the March 2013 draft.
District staff should review the previously submitted comments again in their entirety and incorporate
responses to those comments into the next iteration of the Plan

. Those comments also request

ad ditional information on the District’s summary of planned changes, including potential site mergers,
so that the public understands why the District is considering removing monitors with years of air quality

data. This information also was not included in the most recent draft of the plan. During the March 28,

2013 public workshop, District staff explained the rationale behind a few of the potential mergers when
asked, but that is not sufficient. The District should include those explanations in the next dr aft of the

Plan for all proposed site changes.

The District’s recent decision to shut down the PM10 and PM2.5 monitors at the Bakersfield

- Muni site
raises serious concerns about the process by which the District maintains its air monitoring network and

the reliability of the data collected. The Bakersfield

- Muni PM10 and PM2.5 monitors were SLAMS
monitors, and, as the District notes, are regulated under the criteria in 40 CFR Part 58. The District states

that the Bakersfield

- Muni monitors met the criteria fo r a move under 40 CFR Part 58; however, the
District did not request or receive approval from the Regional Administrator as required under 40 CFR
Part 58.14(b) prior to shutting down the monitors

.

Additionally, the District argued that the PM2.5 and PM10 monitors should be moved due to activities in
the area, such as street sweeping and disking of an open field, that altered air quality near the monitors
such that the monitors’ data would not capture “ambient air” in the Valley. This rationale suggests tha t the District is operating under a definition of ambient air that differs from the definition found in 40 CFR
50.1(e), which defines ambient air as “that portion of the atmosphere, external to buildings, to which
the general public has access.” Street swe eping and disking are common activities throughout the
Valley, so there is no reason to exclude a site where these activities take place . In the next version of the

Plan

, the District should review its rationale for closing the Bakersfield

- Muni SLAMS monit ors without
EPA approval and take appropriate action to address the errors identified in these comments. Altering
the monitoring network without EPA approval and without appropriate notice can jeopardize the
District’s ability to measure progress toward attainment of the ozone and PM2.5 NAAQS. Considering
the severe public health consequences of th e District’s poor air quality, the District should prioritize the
maintenance of a comprehensive and reliable air monitoring network by adhering to pertinent

re gulations.

The latest draft of the Plan provides more information on the Distri ct’s plans for its air monitoring
network, particularly as they relate to the siting of near roadway monitors

. However, there are still
many gaps to be filled. We urge the Distr ict to provide more detailed information explaining the
rationale for site selection and for any planned changes to the monitoring network. The District must

also ensure that its plans for monitor closures and mergers adhere to all applicable regulations b efore it
takes any action

.Jennifer Ridgway, San Joaquin Valley Air Pollution Control District

April 18, 2013
Page 3 of 3

Sincerely,

Adenike Adeyeye Research & Policy Analyst EarthjusticeOctober 18, 2012

Jennifer Ridgway San Joaquin Valley Unified Air Pollution Control District 1990 East Gettysburg Avenue
Fresno, CA 93726

Re: San Joaquin Valley Unified Air Pollution Control District, 2012 Air Monitoring

Network Plan

Dear Ms. Ridgway,

Thank you for the opportunity to provide comments on the San Joaquin Valley Unified Air Pollution Control District’s (“District”) 2012 Air Monitoring Network Plan (“Plan”). This report provides information that greatly helps us and other interested parties understand and participate in the District’s air monitoring efforts. These c omments, submitted on behalf of the Central Valley Air Quality Coalition, the Center for Race, Poverty, and the Environment, and
the National Parks Conservation Association, ask for clarification and additional information regarding some aspects of the plan, to further facilitate our understanding of the District’s

a pproach to meeting federal air monitoring requirements.

Although the District describes the Plan requirements in the introduction, the criteria behind those requirements are not fully explained. For example, on page 7, the Plan details the different monitoring site types, such as sites near the highest pollutan t concentrations, sites in areas of high population density, and sites to identify background concentration levels. This section would be more helpful if it described how the District assigned specific monitors to the different site types. For sites in hig h population areas, what is the population threshold used to determine which sites fall under the “population oriented” site type? Or, if a threshold is not used, how are those sites determined? Similar questions should be answered for the remainder

of the site types.

Answering these questions for each of the site types would also provide important information about the characteristics of each monitoring site. Appendices A and B offer brief descriptions of each of the monitoring sites, but neither provide s the site

- specific descriptions that would be especially useful in understanding the scope of the District’s monitoring network. Appendix A contains brief narrative descriptions of each monitoring site, with a heavy focus on regional

characteristics. For example, the Bakersfield

- Muni site description gives a brief overview of the city of Bakerfield’s location and pollution profile. It does not provide specific information about

the area in which the monitor is sited. Is it in a residential area? An industr ial area? This a nd other pertinent information sh ould be added to the descriptions in Appendix A. In Appendix B,Jennifer Ridgway, San Joaquin Valley Unified Air Pollution Control District

October 18, 2012 Page 2 of 3

there are tables that provide some site

- specific information, but these still do not supply the type of information requested in the questions above. Adding more information about the area in which a monitor is sited would offer a more complete picture of air monitoring in the District, when reviewed in conjunction with the detailed site information in Appendix B and the more general site descrip tions in Appendix A.

This information would also allow for more meaningful comment s on expected changes to the air monitoring network in the District. The summary of planned changes lists potential site mergers without any explanation of the reasons for me rging the sites. While, for example, the District explains that it will include NOy monitors for specific sites “to comply with the regulations for PAMS Type 3 sites,” 1 the same section simply states that “[t]he District may investigate consolidating” 2 two different sites in a given city. The District, in this Plan, considers consolidating six sites: Merced

- M Street and Merced

- Coffee, Madera

- Pump and Madera

- City,

and Fresno

- Pacific and Fresno

- Drummond. What prompted the District to contemplate consolidating these sites? What benefits will consolidation provide to the monitoring network?

How did the District decide where to locate the consolidated monitors? Answers to these questions are necessary to enable the public to review and comment on the District’s p roposed plans as required by 40 CFR §58.10(c).

The District’s monitoring system will be required to comply with EPA goals regarding near

highway monitoring for 1

- hour NO 2 and PM2.5 concentrations, but there is no discussion of these goals in the Plan. H as the District considered how it will comply with near

- highway monitoring requirements? Will the requirements impact other monitors within the system in any way? Providing information about compliance with new goals along with other information about plan ned changes to the system would offer a more comprehensive overview of the future of the monitoring network.

The public would also benefit from clarification on the foundation of the District’s particulate matter (“PM”) monitoring system. The District cites the California Regional Particulate Air Quality Study (“CRPAQS”) as the basis for the PM monitoring system. It also notes that the CRPAQS final report compiling key data and analysis of particulates in the region was “expected to be completed in June 2012.” 3 Has that report been completed? How did it influence system design? If the report is complete, please make it available so that the public can use it to evaluate the District’s monitoring approach more fully.

1 San Joaquin Valley Air Pollution Control District. (September 13, 2012). 2012 Air Monitoring Network

Plan , at 39.

2 Id.

3 Id., at 18.Jennifer Ridgway, San Joaquin Valley Unified Air Pollution Control District

October 18, 2012 Page 3 of 3

In conclusion, the Plan supplies im portant information about the status of the air monitoring network in the District. But, without greater detail about how District site selection satisfies relevant criteria, the District’s rationale for potential site mergers, the research that influenced the design of the monitoring system, and the areas in which monitors are sited, meaningful public review and comment cannot occur. We look forward to receiving more detailed responses to the questions and comments posed in this letter.

Sincerely,

Ad enike Adeyeye Research & Policy Analyst Earthjustice