# Coalition For A Safe Environment

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

cfase @ att .net 310

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February 5 , 201 5

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

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Re: Agenda # 2 2 Supplement to 24

- Hour PM2.5 State Implementation Plan F or South Coast Air Basin

Su: Let ter 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 sta tionary 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 e stimates 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 an d 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 refin eries which failed to include accurate emissions
from :

a. A ll 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 a nnually 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 ju s tice, environmental, public health , community sustainability

, h omeowners 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 Ultra fine 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 I ncorporate 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 Con trol 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 (AC TS) 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 R ACM/RACT Analysis states that , “ SCAQMD staff’s analysis (see Attachment E)
sho ws 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 i s 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 Com mitments 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 AQ MD 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

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Co

- Signed:

Drew Wood

Executive Director
California Kids IAQ
1601 N. Wilmington Blvd., Ste. B4
Wilmington, CA 90744 californiakidsiaq@gmail.com

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Ricardo Pulido

Executive Dire ctor Community Dreams 1601 N. Wilmington Blvd., Ste. B2
Wilmington, CA 90744 mr.rpulido@aol.com

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Pastor Alfred Carrillo
Apostolic Faith Center

1508 E. Robidoux Street Wilmington, CA 90744
alfredcarrillo@msn.com

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