DRAFT FINAL

2012 AQMP

ADDENDUM TO

RESPONSES TO COMMENTS

TO THE 2012 AQMP

DECEMBER 2012
Addendum to Response to Comments

COMMENT LETTER LOCATOR 

AGENCY/ COMPANY DATE Comment 

Letter Locator

Association of California Cities Orange County (ACCOC) 11/10/12 NNN

BizFed 11/9/12 MMM

Dillard, Joyce 11/12/12 RRR

Port of Los Angeles/Long Beach 11/8/12 KKK

Riverside County Waste Management Department 11/9/12 LLL

Sierra Club Angeles Chapter 11/12/12 QQQ

Western States Petroleum Association (WSPA) - Socioeconomic 11/12/12 OOO

Western States Petroleum Association (WSPA) – 2012 AQMP 11/12/12 PPP
PREFACE

Numerous comments have been received during the Plan development. Specific responses 

to 99 written comment letters on the 2012 AQMP are addressed in ―Draft Final 2012 

AQMP Responses to Comments to the 2012 AQMP‖ publicly released on November 21, 

2012 (Attachment C of the Board Letter). Additional responses to comment letters not 

included in the ―Draft Final 2012 AQMP Responses to Comments to the 2012 AQMP‖ are 

included in this Addendum to Attachment C.

For some comments similar remarks have been previously made in previous comment 

letters so the response indicates where the reader can locate the appropriate response in 

Attachment C (Draft Final 2012 AQMP Responses to Comments to the 2012 AQMP).

Other comments have been addressed in the Board Letter or Resolution (Attachment A to 

the Board Letter) and the response notes if that is the case. Finally, there are some 

comments that have not been provided specifically in the past so a written response is 

provided.
Draft Final 2012 AQMP

RTCA-1

AQMP Response to Comments

KKK. Port of Los Angeles / Port of Long Beach, November 8, 2012

KKK-1
Addendum to Response to Comments

RTCA-2

KKK-2

KKK-3
Draft Final 2012 AQMP

RTCA-3

Responses to Comment Letter KKK

Port of Los Angeles / Port of Long Beach

Response to Comment KKK-1:

Please refer to Response to comments C-1, M-1, KK-5, and EEE-2.

Response to Comment KKK-2:

Please refer to Response to comments HH-2, HH-5, JJ-1, JJ-2, Board letter and 

Attachment F.

Response to Comment KKK-3:

Please refer to Response to comments HH-6, and HH-7.
Addendum to Response to Comments

RTCA-4

LLL. Riverside County Waste Management Department, November 9, 2012

LLL-1

LLL-2
Draft Final 2012 AQMP

RTCA-5

LLL-3

LLL-2
Addendum to Response to Comments

RTCA-6

LLL-3

LLL-4
Draft Final 2012 AQMP

RTCA-7
Addendum to Response to Comments

RTCA-8

Responses to Comment Letter LLL

Riverside County Waste Management Department

Response to Comment LLL-1:

Please refer to Response to comment M-16.

Response to Comment LLL-2:

Please refer to Response to comments R-1, S-1, T-2, W-1, Z-2, BB-1, DD-8, KK3, LL-3, CCC-1, and GGG-1.

Response to Comment LLL-3:

The intent of the control measure is not to eliminate all flaring at landfill facilities, 

but rather to minimize flaring emissions through equipment upgrades and flare 

minimization techniques when feasible. During the rule development phase, staff 

will focus on identifying the emission reduction opportunities that are feasible and 

cost effective. Staff is fully aware that as landfills enter their inactive phase, 

landfill gas production rates and gas quality diminish. These issues will be 

considered during the rulemaking process. Also, please refer to Response to 

comment M-10.

Response to Comment LLL-4:

The use of impermeable tarps upon freshly chipped or ground green waste 

material will retain the moisture released by the material. This allow the VOCs 

(generally of a light alcohol nature) to be retained by the water vapor, thus 

allowing for further decomposition of the VOCs by microbes in the first 48 hours.
Draft Final 2012 AQMP

RTCA-9

MMM. BizFed, November 9, 2012
Addendum to Response to Comments

RTCA-10

MMM-1
Draft Final 2012 AQMP

RTCA-11

MMM-1
Addendum to Response to Comments

RTCA-12

MMM-2

MMM-3
Draft Final 2012 AQMP

RTCA-13

MMM-3

MMM-4

MMM-5

MMM-6

MMM-7
Addendum to Response to Comments

RTCA-14

MMM-8

MMM-9
Draft Final 2012 AQMP

RTCA-15
Addendum to Response to Comments

RTCA-16
Draft Final 2012 AQMP

RTCA-17

Responses to Comment Letter MMM

BizFed

Response to Comment MMM-1:

Please refer to Response to comments R-1, S-1, T-2, W-1, Z-2, BB-1, DD-8, KK3, LL-3, CCC-1, and GGG-1.

Response to Comment MMM-2:

Please refer to Response to comments W-9, and CCC-2.

Response to Comment MMM-3:

NOx and VOC reductions from ozone measures will lower PM2.5 because NOx 

and VOC are also precursors to PM2.5.

Response to Comment MMM-4:

There is no clear PM2.5 exposure threshold below which no adverse health effects 

are observed. In fact, California has lower PM2.5 standards than the federal 

standards. Furthermore, the U.S. EPA is in the process of proposing a more 

stringent annual PM2.5 standard based on several health studies (See Appendix I to 

the Draft Final 2012 AQMP for more details).

Response to Comment MMM-5:

The local economy is projected to experience a net modest positive job impact of 

clean air benefits and control measures. As our economy transitions to a new 

phase of better air quality, there will be new job opportunities and some sectors 

may decline due to the overall efficiency gain in our economy. This phenomenon 

is consistent with any other transition in our economy. The sectors that are 

forecasted to decline due to the Plan were truck transportation and auto repair 

which result from less demand for their services due to improvements in traffic. 

The rise in job opportunities in other sectors will help offset the negative impacts 

in these two sectors.

Response to Comment MMM-6:

Chapter 2 of the Report presents the current state of the economy and the analysis 

in the Report shows deviations from the current state of the economy. The 

commentor needs to elaborate on why cost estimates are outdated and/or 

unreliable and staff has solicited comments on cost assumptions for the measures 

since July 2012 and will continue to incorporate new information as the AQMD 

further studies the measures of begins the rulemaking process.
Addendum to Response to Comments

RTCA-18

Response to Comment MMM-7:

The Socioeconomic Report clarifies that no job in our economy is permanent. 

Therefore, any job statistics for any given year reflects a count of jobs and does 

not address the length of employment. Even without TCMs, the positive job 

impact of clean air benefits outweighs the negative job impact of control measures 

by a 5 to 1 margin. Compared to the total number of jobs in the four-county area, 

job impacts in the Socioeconomic Report represent less than 0.4 percent of the 

total jobs in our economy. Based on comments on TCMs, staff has included an 

additional cost benefit scenario without TCMs.

Response to Comment MMM-8:

Detail cost assumptions and data for each measure has been posted online 

(http://www.aqmd.gov/gb_comit/aqmpadvgrp/2012AQMP/meetings/2012/july26/

agenda.html) since late July per the commentor’s request. Typically, a two-phase 

control measure requires additional technology assessment to refine the 

technology and control potential. Therefore, Phase II is contingent upon the 

findings from Phase I. In those cases, no SIP reductions are committed. 

Wherever appropriate, the AQMD has also provided costs for Phase I 

requirements. Appendix IV to the AQMP shows a range of cost effectiveness 

estimates for measures, when applicable. Differences in costs from year to year 

reflect variations in implementation dates of measures. The cost for the 2015 

AQMP cannot be calculated at this time since the attainment strategy has yet to be 

developed.

Response to Comment MMM-9:

One of the future enhancements as indicated in Chapter 8 of the Report is to 

update methods, underlying technical studies, and approaches, as appropriate.
Draft Final 2012 AQMP

RTCA-19

NNN. Association of California Cities Orange County (ACCOC), November 10, 2012

NNN-1
Addendum to Response to Comments

RTCA-20

NNN-4

NNN-3

NNN-2

NNN-1
Draft Final 2012 AQMP

RTCA-21
Addendum to Response to Comments

RTCA-22

Responses to Comment Letter NNN

ACCOC

Response to Comment NNN-1:

Staff strives to release information as it becomes available so as to engage 

stakeholders early and throughout the process. In addition, upon the release of the 

Socioeconomic Report, a public review period of 45 days was provided. Also, 

please refer to Response to comments T-1, W-11, W-12, Z-1, and LL-2.

Response to Comment NNN-2:

Appendix G to the Socioeconomic Report has results derived from excluding 

TCMs. Exclusion of TCMs from the analysis does not change the conclusion of 

the analysis.

Response to Comment NNN-3:

The AQMD will examine this study as part of future enhancements. Also, please 

refer to the 2012 AQMP Board Letter and the Resolution.

Response to Comment NNN-4:

Cal/EPA’s environmental health screening tool is still under development. Zip 

code level data was used by Cal/EPA for illustration in the draft screening tool 

document. In the Socioeconomic Report air quality data is based on a 4 by 4 

kilometer grid and economic data is modeled at the census tract level, both of 

which are finer than zip code level data. The Cal/EPA’s screening tool is a 

qualitative tool that ranks environmental exposure data (e.g., pesticide use, air 

quality, toxic release, and traffic congestion), community health data (e.g., asthma, 

cancer, heart disease, and birth weight), and demographic data (e.g., population 

age profile, educational attainment, and income) in a snapshot of time to construct 

a weighted score for various communities. The Socioeconomic Report links air 

quality, epidemiological, and economic models to produce quantitative results 

across time and space. While the screening tool is useful for some other purposes, 

it provides less information than the framework that the Socioeconomic Report 

uses for the AQMP analysis. Also, please refer to the 2012 AQMP Board Letter 

and the Resolution.
Draft Final 2012 AQMP

RTCA-23

OOO. Western States Petroleum Association (WSPA), November 12, 2012
Addendum to Response to Comments

RTCA-24

OOO-1
Draft Final 2012 AQMP

RTCA-25

OOO-1

OOO-2

OOO-3
Addendum to Response to Comments

RTCA-26

OOO-3

OOO-4
Draft Final 2012 AQMP

RTCA-27

Responses to Comment Letter OOO

WSPA

Response to Comment OOO-1:

Detail cost assumptions and data for each measure has been posted online 

(http://www.aqmd.gov/gb_comit/aqmpadvgrp/2012AQMP/meetings/2012/july26/

agenda.html) since late July. Except Control Measure ONRD-05 (Further 

Emission Reductions from Heavy-Duty Vehicles Serving Near-Dock Railyards), 

no emission reductions are claimed for control measures without costs. Table 6-4 

in the 2012 AQMP and respective measures in Appendices IV (A) and IV (B) to 

the 2012 AQMP has additional information on measures without cost data. 

Construction costs associated with the re-design of a facility vary by facility and 

will be assessed during rulemaking when specific requirements are laid out. Also, 

please refer to Response to comments C-1, M-1, KK-5, EEE-2, and HHH-2.

Response to Comment OOO-2:

Please refer to Response to comment EEE-3.

Response to Comment OOO-3:

Staff does not agree with the commenter’s assumption that available RTC supplies 

would necessarily be reduced. Currently, there are substantial excess RTCs 

available in the market and still NOx reduction potential among RECLAIM 

facilities. Staff believes that CMB-01 Phase I can be implemented through market 

transactions as there is an excess of RTCs currently. The socioeconomic analysis 

assumes that the Phase II shave would be achieved through the use of BARCT, 

which is more conservative than if some facilities elect to purchase RTCs.

Response to Comment OOO-4:

All the costs of implemented control measures and their associated air quality 

benefits of the past AQMPs are reflected in the economic baseline against which 

the 2012 AQMP is evaluated. Performing a cumulative assessment of all the past 

and current AQMPs would not be practical as past events have already occurred 

and become part of the baseline. It would be difficult to isolate air quality 

regulations out of the entire regional economy. Also, as pointed out by another 

commenter, many businesses reduce emissions to be more efficient and 

competitive (please see Response to comment EEE-1). Nevertheless, staff 

welcomes suggestions on methodologies for such analysis.
Addendum to Response to Comments

RTCA-28

PPP. Western States Petroleum Association (WSPA), November 12, 2012
Draft Final 2012 AQMP

RTCA-29

PPP-1

PPP-2
Addendum to Response to Comments

RTCA-30

PPP-2
Draft Final 2012 AQMP

RTCA-31

PPP-3
Addendum to Response to Comments

RTCA-32

PPP-4

PPP-5
Draft Final 2012 AQMP

RTCA-33

PPP-5
Addendum to Response to Comments

RTCA-34

PPP-2
Draft Final 2012 AQMP

RTCA-35

PPP-2
Addendum to Response to Comments

RTCA-36

PPP-2
Draft Final 2012 AQMP

RTCA-37

PPP-6
Addendum to Response to Comments

RTCA-38

PPP-6

PPP-7

PPP-2
Draft Final 2012 AQMP

RTCA-39

PPP-2
Addendum to Response to Comments

RTCA-40

PPP-2
Draft Final 2012 AQMP

RTCA-41

PPP-8
Addendum to Response to Comments

RTCA-42

PPP-8

PPP-9
Draft Final 2012 AQMP

RTCA-43

PPP-9
Addendum to Response to Comments

RTCA-44

PPP-9

PPP-10
Draft Final 2012 AQMP

RTCA-45

PPP-10 
Addendum to Response to Comments

RTCA-46

PPP-10 

PPP-11 
Draft Final 2012 AQMP

RTCA-47

PPP-11 

PPP-12
Addendum to Response to Comments

RTCA-48

Responses to Comment Letter PPP

WSPA

Response to Comment PPP-1:

Please refer to Response to comments R-1, S-1, T-2, W-1, Z-2, BB-1, DD-8, KK3, LL-3, CCC-1, and GGG-1.

Response to Comment PPP-2:

Please refer to Response to comments S-6, T-3, W-3, W-4, and CCC-3.

Response to Comment PPP-3:

Please refer to Response to comments S-6, T-3, W-4, W-5, BB-2, and CCC-3.

Response to Comment PPP-4:

Please refer to Response to comment W-7.

Response to Comment PPP-5:

Please refer to Response to comments W-9, and CCC-2.

Response to Comment PPP-6:

Please refer to Response to comments W-2, and EEE-1.

Response to Comment PPP-7:

It is correct that the elements of the 2007 AQMP control measures MCS-03 are 

carried over and included in the broader scope of the 2012 AQMP control measure 

EDU-01.

Response to Comment PPP-8:

Any expansion of Rule 1177 applicability will necessarily follow the traditional 

rulemaking process that will include the thorough evaluation of the feasibility and 

cost effectiveness of achieving further reductions from the new sources proposed 

for inclusion. The evaluation will include a full socio-economic and 

environmental assessment of the impacts of the Rule’s expanded applicability.

Response to Comment PPP-9:

The purpose of this control measure is not to replace current traditional LDAR 

programs, which have produced significant fugitive VOC reductions in the Basin. 

Rather, it seeks to take advantage of new imaging technologies to institute fugitive 

emission reductions programs in source categories not currently subject to current 

LDAR requirement, but in a more efficient and cost-effective manner using 
Draft Final 2012 AQMP

RTCA-49

advanced techniques. Staff will explore opportunities that would further enhance 

the effectiveness of traditional LDAR programs through the use of OGI 

techniques. Note that the $11,000 per ton cost effectiveness is based on traditional 

LDAR programs, and reflects an upper bound considering the lower expected cost 

of OGI techniques.

Response to Comment PPP-10:

Please refer to Response to comment W-10.

Response to Comment PPP-11:

This measure is a voluntary incentive program targeting potential emissions 

reductions not regulated by the current CARB regulation. The participation is 

voluntary based on technically feasible and cost-effective technologies. 

Response to Comment PPP-12:

As stated in the comment, this measure seeks to incentivize cleaner vessels to call 

on the Ports of Los Angeles and Long Beach. It builds upon and complements 

other programs already being implemented. As it does not seek SIP-committed 

emissions reductions through imposing regulations, there is no need for the legal 

authority to implement such voluntary incentive programs. The emission 

reductions referenced are for discussion purposes.
Addendum to Response to Comments

RTCA-50

QQQ. Sierra Club Angeles Chapter, November 12, 2012

QQQ-1
Draft Final 2012 AQMP

RTCA-51

Responses to Comment Letter QQQ

Sierra Club Angeles Chapter

Response to Comment QQQ-1:

Staff will study costs of health impacts on EJ areas in future enhancements. For 

the detailed locations of green jobs, please see the 2010 EDD report of 

―California’s Green Economy—Summary of Survey Results.‖ Staff will examine 

data availability on the differential impacts of investments on clean fuels versus 

fossil fuels as part of its future endeavors.
Addendum to Response to Comments

RTCA-52

RRR. Joyce Dillard, November 12, 2012

RRR-1
Draft Final 2012 AQMP

RTCA-53

RRR-4

RRR-3

RRR-2

RRR-1
Addendum to Response to Comments

RTCA-54

RRR-5

RRR-6

RRR-7
Draft Final 2012 AQMP

RTCA-55

Responses to Comment Letter RRR

Joyce Dillard

Response to Comment RRR-1:

Please refer to Response to comment M-2.

Response to Comment RRR-2:

The 2012 AQMP is primarily designed to address the air quality of criteria 

pollutants, namely PM2.5 and ozone. It does not propose measure to address 

methane emissions and their impact on climate. There is no current evidence that 

methane significantly affects ozone formation. It is therefore considered inert and 

not an ozone precursor. There may be co-emitted VOCs from oil operations that 

do affect ozone formation, and those are accounted for in the AQMP analysis.

Response to Comment RRR-3:

The 2012 AQMP is designed to address the regional air quality of criteria 

pollutants, namely PM2.5 and ozone. Localized toxic impacts and environmental 

justice issues are addressed through other programs, such as our Clean 

Communities Plan, diesel emission reduction efforts, air toxic assessment studies, 

CEQA review, and risk reduction strategies. However, some of the measures 

designed for regional air quality improvement will have commensurate exposure 

reduction benefits for local communities

Response to Comment RRR-4:

The NOx RECLAIM market only applies to the largest stationary sources in the 

Basin, and does not apply to construction or maintenance of distributed 

infrastructure.

Response to Comment RRR-5:

Emissions from oil wells in the Basin and their impact on ozone and PM2.5 are 

included in the analysis. Localized impacts are addressed through other programs, 

such as permitting, CEQA review and AB2588 risk reduction strategies. AQMD 

staff has recently held a technology symposium on hydraulic fracturing, and is 

initiating a rulemaking on reporting and public notification.

Response to Comment RRR-6:

Please refer to Response to comments C-1, M-1, KK-5, EEE-2, and HHH-2.
Addendum to Response to Comments

RTCA-56

Response to Comment RRR-7:

Please refer to Response to comment RRR-03.