MARINE CORPS INSTALLATIONS WEST 

BOX 555200 

CAMP PENDLETON, CALIFORNIA 92055-5200 

IN REP\.Y REFER TO: 

5090 

ES 

January 11, 2012 

Mr. Jared Blumenfeld 

Administrator, U.S. Environmental Protection Agency 

Pacific Southwest Region, Region 9 

75 Hawthorne Street 

San Francisco, CA 94105-3901 

SUBJECT:	 Reclassification of San Diego County to Serious 

Nonattainment Area for the 1997 Ozone Standard 

Dear Mr. Blumenfeld, 

Marine Corps Installations West is writing to express concern 

regarding the Environmental Protection Agency's (EPA) decision to move 

forward with reclassifying San Diego County as a 'serious' 

nonattainment area for the 1997 National Ambient Air Quality Standard 

(NAAQS) for ground-level ozone (i.e., 84 parts per billion [ppb]). 

This despite the fact that San Diego County has already attained this 

standard with an ozone value of 82 ppb based on data collected in 

2009-2011. San Diego County is expected to be classified by EPA as a 

marginal nonattainment area for the 2008 ozone standard in summer of 

2012. 

Reclassification to 'serious' nonattainment, therefore, would 

unnecessarily lower the San Diego Air Pollution Control District's 

threshold for Title V Operating Permit program by,SO%, from 100 tons 

per year(tpy) to SOtpy. Given the amount of force restructuring/ 

redeployments being considered by the current administration, this 

change could require operational limits on our jet engine test cells 

at Marine Corps Air Station, Miramar in San Diego County. As you 

know, the Marine Corps already has a comprehensive and effective air 

quality compliance program in place to ensure compliance will all 

permitting and prohibitory requirements in California. However, 

obtaining a Title V/synthetic minor permit with conditions that even 

temporarily limit our operating hours on testing jet engines would 

degrade our equipment readiness in support of our national defense 

mission. 

Reclassification also would change general conformity standards, 

which would affect other mission related decisions regarding future 

deployments of new equipment, such as combat aircraft, amphibious 

assault vehicles, and other mission critical weapons systems to key 

bases in San Diego County. Deployment of new equipment is a lengthy 5 

to 10 year process, which requires a degree of regulatory 

predictability and certainty. However, the temporary reclassification 

of San Diego as a serious non-attainment area for the 1997 NAAQS, 

introduces regulatory uncertainty to our installations in San Diego 
5090 

ES 

January 11, 2012 

County. If the EPA proceeds with reclassification of the region to 

serious nonattainment for the 1997 standard, the Marine Corps would be 

faced with having to plan and budget resources for a temporary 

reduction in major source threshold and its associated regulatory 

impact for an unknown period of time. 

Should EPA pursue reclassification to 'marginal', the current 

major source threshold in the region would not be altered and 

regulatory requirements for Marine Corps operations in the region 

would not be affected. 

In summary, the Marine Corps believes that reclassification to 

serious nonattainment area for an ozone standard that San Diego County 

has already attained will unnecessarily introduce significant 

regulatory uncertainty for USMC operations in our region. This 

decision would divert resources from projects that actually reduce air 

emissions while meeting our military mission to using these resources 

to meet administrative and recordkeeping requirements, as well as 

limiting our ability to test jet engines and introduce new equipment 

essential to Marines training to fight and win on the battlefield. As 

San Diego County has attained the 1997 federal ozone standard, the 

Marine Corps requests that EPA withdraw its ruling to classify the 

region as a serious nonattainment area. Instead, request that EPA find 

that the region has attained the standard after the monitoring data 

are analyzed and approved. 

Thank you for your time and consideration of this important 

matter. If you have any questions, please do not hesitate to contact 

me at 760-763-7950. 

Sincerely, 

~~-+ S. W. NORQUIST 

Director, Environmental Security 

Marine Corps Installations West 

By direction of the 

Commanding General 

Cc:
 

HQMe, CMCICOM (GF-5)
 

Robert Kard
 

Air Pollution Control Officer
 

San Diego County APCD
 

10124 Old Grove Road
 

San Diego, CA 92131-1649
 

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