UNITED STATES MARINE CORPS MARINE CORPS INSTALLATIONS WEST BOX 555200 CAMP PENDLETON, CALIFORNIA 92055-5200

INREP\.YREFERTO: 5090 ES January 11, 2012

Mr. JaredBlumenfeld Administrator, U.S. Environmental ProtectionAgency Pacific Southwest Region, Region 9 75 Hawthorne Street San Francisco, CA 94105-3901

SUBJECT: Reclassification of SanDiego County to Serious Nonattainment Area for the 1997 Ozone Standard

DearMr. Blumenfeld,

Marine Corps Installations West is writing to express concern regarding the Environmental ProtectionAgency's (EPA) decision to move forward with reclassifying SanDiego County as a 'serious' nonattainment area for the 1997 National Ambient Air Quality Standard (NAAQS) for ground-level ozone (i.e., 84 parts perbillion [ppb]). This despite the fact that SanDiego Countyhas already attained this standard with an ozone value of 82 ppbbased on data collected in 2009-2011. San Diego County is expectedto be classifiedby EPA as a marginal nonattainment area for the 2008 ozone standard in summer of 2012.

Reclassification to 'serious' nonattainment, therefore, would unnecessarily lower the SanDiegoAir PollutionControl District's threshold for TitleVOperating Permit programby,SO%, from 100 tons peryear(tpy) to SOtpy. Given the amount of force restructuring/ redeployments being consideredby the current administration, this change could require operational limits on ourjet engine test cells at Marine CorpsAir Station, Miramar in San Diego County. As you know, the Marine Corps alreadyhas a comprehensive and effective air quality compliance program inplace to ensure compliance will all permitting andprohibitoryrequirements in California. However, obtaining a Title V/syntheticminorpermit with conditions that even temporarily limit our operatinghours on testingjet engines would degrade our equipment readiness in support of our national defense mission.

Reclassification also would change general conformity standards, whichwould affect othermission related decisions regarding future deployments of new equipment, such as combat aircraft, amphibious assault vehicles, and othermission critical weapons systems tokey bases in SanDiego County. Deployment of new equipment is a lengthy 5 to 10 yearprocess, which requires a degree of regulatory predictability and certainty. However, the temporary reclassification of San Diego as a seriousnon-attainment area for the 1997 NAAQS, introduces regulatoryuncertainty to our installations in SanDiego5090 ES January 11, 2012
County. If the EPA proceeds with reclassification of the region to serious nonattainment for the 1997 standard, the Marine Corps wouldbe faced withhaving to plan andbudget resources for a temporary reduction inmajor 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 attainedwill unnecessarily introduce significant regulatoryuncertainty for USMC operations inour region. This decision would divert resources from projects that actually reduce air emissions while meeting ourmilitarymission 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 classifythe 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 considerationof 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 CountyAPCD 10124 Old Grove Road San Diego, CA 92131-1649

2