# DRAFT FINAL

2012 AQMP

ADDENDUM TO RESPONSES TO COMMENT S TO THE 2012 AQMP

DECEMBER 2012Addendum to Response to Comments 

### COMMENT LETTER LOCATOR AGENCY/ COMPANY DATE Comment Letter Locator A ssociation of California Cities Orange County (A CCOC ) 11/10/12 NNN BizFed 11/9/12 MMM Dillard, Joyce 11/12/12 RRR Port of L os Angeles /L ong B each 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 n ot 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 re ader 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 - 1Addendum to Response to Comments

RTCA - 2 KKK - 2

KKK - 3Draft Final 2012 AQMP

RTCA - 3 R esponses 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 EE E - 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 Departm ent , November 9, 2012

LLL - 1

LLL - 2Draft Final 2012 AQMP

RTCA - 5 LLL - 3 LLL - 2Addendum to Response to Comments

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LLL - 4Draft Final 2012 AQMP

RTCA - 7Addendum to Response to Comments

RTCA - 8 R esponses 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, KK 3, 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 mini mize 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 full y 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, p lease refer to Response to comment M - 10. Response to Comment LLL - 4 : The u se 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 decomposi tion of the VOCs by microbes in the first 48 hours.Draft Final 2012 AQMP

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

RTCA - 10 MMM - 1Draft Final 2012 AQMP

RTCA - 11 MMM - 1Addendum to Response to Comments

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MMM - 3Draft Final 2012 AQMP

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MMM - 5 MMM - 6

MMM - 7Addendum to Response to Comments

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MMM - 9Draft Final 2012 AQMP

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RTCA - 17 R esponses 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, KK 3, 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 PM 2.5 exposure threshold below which no adverse health effects are observed. In fact, California has lower PM 2.5 standards than the federal standards. Furthermore, the U.S. EPA is in the process of proposing a more stringent annual PM 2.5 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 sin ce 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 fr om 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. Differenc es 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

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

NNN - 1Addendum to Response to Comments

RTCA - 20 NNN - 4 NNN - 3 NNN - 2 NNN - 1Draft Final 2012 AQMP

RTCA - 21Addendum to Response to Comments

RTCA - 22 R esponses 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, p lease 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, p lease 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 trac t 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 rel ease, 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 va rious 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 purpose s , it provides less information than the f ramework that the Socioeconomic Report uses for the AQMP analysis. Also, p lease refer to the 2012 AQMP Board Letter and the Resolution.Draft Final 2012 AQMP

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

RTCA - 24 OOO - 1Draft Final 2012 AQMP

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OOO - 2

OOO - 3Addendum to Response to Comments

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OOO - 4Draft Final 2012 AQMP

RTCA - 27 R esponses 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 c ontrol 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 va ry by facility and will be assessed during rulemaking when specific requirements are laid out. Also, please refer to R esponse to comments C - 1, M - 1, KK - 5, EEE - 2, and HHH - 2. Response to Comment OOO - 2 : Please refer to R esponse to comment EEE - 3 . Response to Comment OOO - 3 : Staff does not agree with the comment e r’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 region al economy. Also, as pointed out by another comment e r, many businesses reduce emissions to be more efficient and competitive (please see Response to comment EEE - 1) . Nevertheless, staff welcome s suggestions on methodologies for such analysis.Addendum to Response to Comments

RTCA - 28 PPP . Weste rn States Petroleum Association (WSPA), November 12, 2012Draft Final 2012 AQMP

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PPP - 2Addendum to Response to Comments

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PPP - 5Draft Final 2012 AQMP

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RTCA - 36 PPP - 2Draft Final 2012 AQMP

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PPP - 2Draft Final 2012 AQMP

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PPP - 9Draft Final 2012 AQMP

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PPP - 10Draft Final 2012 AQMP

RTCA - 45 PPP - 10Addendum to Response to Comments

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PPP - 11Draft Final 2012 AQMP

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PPP - 12Addendum to Response to Comments

RTCA - 48 R esponses 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, KK 3, 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 re ductions programs in source categories not currently subject to current LDAR requirement, but in a more efficient and cost - effective manner usingDraft Final 2012 AQMP

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advanced techniques. Staff will explore opportunities that would further enhance the effectiveness of traditi onal 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 : P lease refer to Response to comment W - 10 . Response to Comment PPP - 1 1 : 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 - 1 2 : 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 purpos es.Addendum to Response to Comments

RTCA - 50 QQQ . Sierra Club Angeles Chapter, November 12, 2012

QQQ - 1Draft Final 2012 AQMP

RTCA - 51 R esponses 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 f uture endeavors.Addendum to Response to Comments

RTCA - 52 RRR . Joyce Dillard, November 12, 2012

RRR - 1Draft Final 2012 AQMP

RTCA - 53 RRR - 4 RRR - 3 RRR - 2 RRR - 1Addendum to Response to Comments

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RRR - 7Draft Final 2012 AQMP

RTCA - 55 R esponses 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 ana lysis. 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 Cle an 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 benefit s 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 f

rom 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 tech nology 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 R esponse to commen t RR R - 03 .