Coalition For A Safe Environment

1601 N. Wilmington Blvd. Ste. B, Wilmington, California 90744

cfase @ att.net 310-704-1265

 February 5, 2015

Chairman Burke & Governing Board

South Coast Air Quality Management District 

21865 Copley Drive

Diamond Bar, CA 91765

Clerk of the Board, Saundra McDaniel: 

smcdaniel@aqmd.gov

909-396-3317

clerkofboard@aqmd.gov

909-396-2500

Re: Agenda # 22 

Supplement to 24-Hour PM2.5 State Implementation Plan For South Coast Air Basin

Su: Letter of Opposition To Staff Recommendation

Honorable Chairman of the Board & Members of the Board:

The Coalition For A Safe Environment (CFASE) submits our Letter of Opposition to the staff 

recommendation because the proposed Supplement to the 24-Hour PM2.5 State Implementation Plan 

and measures for the South Coast fail to guarantee that the SCAQMD will reach attainment and 

compliance with the 24-Hour PM2.5 National Ambient Air Quality Standard by 2015 under the Clean 

Air Act, Title 1, Part D, Subpart 4.

The AQMD staff intentionally did not hold a public hearing in the Los Angeles and Long Beach Harbor 

Communities which have been the most active and knowledgeable on how to reduce PM10 and PM 

2.5. Downtown Los Angeles has no significant stationary or mobile sources of PM as compared to 

Wilmington, San Pedro, Carson and Long Beach.

CFASE and numerous public entities have repeatedly stated in our public comments to Port of Los 

Angeles & Port of Long Beach adopted project EIR’s that emission estimates were significantly 

underestimated and included information that supported our claims. AQMD staff has continuously 

failed to investigate these claims because they would show that AQMD information submission to 

California’s SIP were not accurate and proposed measures to reduce PM10 and PM2.5 would fail, 

resulting in continuous federal non-attainment.

CFASE challenges the AQMD Air Quality Monitoring Data because as stated before, the AQMD has used 

underestimated data submitted by ports and oil refineries which failed to include accurate emissions 

from:

a. All port truck destinations, numerous ships idling outside the breakwater because the ports do 

not have enough chassis or trucks, not including truck idling on the Shuyler Heim Bridge when it 

goes up to allow a ship to pass under or the diesel generator that comes on to provide extra 

power to the bridge.

b. Refinery Flaring due to monthly malfunctions and equipment breakdown and regular power 

outages.
c. AQMD’s formula for estimating refinery emissions was found to be inaccurate and was recently 

updated and resulted in higher emissions.

It is an insult to the public and an affront to the legal mandate to reduce PM 2.5 for the SCAQMD to 

state in the Supplement that achievement for compliance is, “not likely, largely due to unusual extreme 

drought conditions in the basin,” and “Unanticipated extreme weather conditions have affected air 

quality making attainment in 2014 unlikely.” This is an excuse not to mandate known feasible and cost 

effective technologies for the worst PM emitters Petroleum Industry, Ports and Freight Transportation 

Industries.

We the public recognize the obvious that AQMD intentionally avoided the Petroleum Industry, Ports 

and Freight Transportation Industries who emit hundreds of tons annually and are the largest 

producers of PM 2.5 and instead chose to pick on residents and beach goers who use open burning and 

wood burning devices.

CFASE and numerous other environmental justice, environmental, public health, community 

sustainability, homeowners associations, faith based groups and academic institutions have made 

numerous recommendations over the past several years on various AQMD Rules, Projects, Programs 

and Permit Requirements which would significantly reduce PM 10.0, PM 2.5 and Ultrafine Particles 

which have been continuously ignored by AQMD staff. Some of past submitted recommendations 

which are feasible and cost-effective include:

1. Require Mandatory Maximum Achievable Flare Reductions Of 90% Within 3 Years

2. Mandate Oil Refineries Incorporate Back-Up Power To Prevent Flaring From Power Outages

3. Mandate Oil Refineries Use Of Vapor Recovery Systems On All Storage Tanks To Prevent 

Flaring

4. Mandate Port of Los Angeles & Port of Long Beach To Incorporate the Advanced Maritime 

Emissions Control System When A Ship Cannot Use Electric Shorepower

5. Mandate BNSF and Union Pacific Railroad Companies Use The Advanced Locomotive

Emissions Control System At All Locomotive Engine Maintenance Yards

6. Mandate That The Alameda Corridor Transit Authority (ACTS) Change To Zero Emissions 

Electric Trains

7. Mandate That All Future Port of Los Angeles & Port of Long Beach Projects Use Zero 

Emission Electric Trucks 

The AQMD Supplement RACM/RACT Analysis states that, “SCAQMD staff’s analysis (see Attachment E) 

shows that VOC and ammonia from major sources (100 tons per year or greater) do “not contribute 

significantly” to overall emissions and thus ambient PM2.5 levels.” What they failed to disclose is that 

if looked at from a Cumulative Source Perspective PM2.5 is 451 tons and therefore would increase 

emissions and PM2.5 levels. We have already stated the emission estimates from the Petroleum 

Industry, Ports and Freight Transportation Industries have been significantly under estimated.

The Control Strategy Commitments referenced do not guarantee with any certainty attainment will be 

achieved. The reference emissions prevention and emissions capture technologies recommendations 

1-7 referenced above provide a guarantee of significant PM2.5 emission reductions. 

The Los Angeles and Long Beach Harbor Environmental Justice and Title VI Protected Communities of 

Carson, Wilmington, San Pedro and Long Beach are the most significantly and negatively impacted by 

PM 2.5 toxic emissions. We have repeatedly asked the AQMD to require Health Impact Assessments 

(HIA) for all Petroleum Industry, Ports and Freight Transportation Industries Project EIR’s so as to 

provide accurate information on public health impacts and the AQMD staff have refused.
The Coalition For A Safe Environment is an Environmental Justice Organization headquartered in 

Wilmington with members in Carson, Wilmington, Long Beach, Compton and over 25 cities in Los 

Angeles and Orange County.

Respectfully Submitted;

Jesse N. Marquez

Executive Director

jnm4ej@yahoo.com

310-704-1265

Co-Signed:

Drew Wood

Executive Director

California Kids IAQ

1601 N. Wilmington Blvd., Ste. B4

Wilmington, CA 90744

californiakidsiaq@gmail.com

916-616-5913

Ricardo Pulido

Executive Director

Community Dreams

1601 N. Wilmington Blvd., Ste. B2

Wilmington, CA 90744

mr.rpulido@aol.com

310-567-0748

Pastor Alfred Carrillo

Apostolic Faith Center

1508 E. Robidoux Street

Wilmington, CA 90744

alfredcarrillo@msn.com

310-940-6281