BOARD MEETING DATE: December 7, 2012 AGENDA NO. 30

PROPOSAL: Adopt Draft Final 2012 Air Quality Management Plan

SYNOPSIS: The Draft Final 2012 Air Quality Management Plan (AQMP) has 

been developed in partnership with CARB, U.S. EPA, SCAG and 

stakeholders throughout the region, including input from local 

government, health and environmental organizations, and the 

business community. The AQMP is the legally enforceable 

blueprint for how to meet and maintain state and federal air quality 

standards. The 2012 AQMP identifies control measures needed to 

demonstrate attainment with the federal 24-hour standard for PM2.5 

by 2014 in the South Coast Air Basin. In addition, the 2012 AQMP 

provides updates on progress towards meeting the 8-hour ozone 

standard for 2023, an attainment demonstration for the revoked 1-

hour ozone standard, a VMT offset demonstration for ozone 

standards, and a report on the health effects of PM2.5.

COMMITTEE: Mobile Source, Reviewed (January 20, February 17, March 16, April 

20, May 18, June 15, July 27, September 21, and October 19, 2012)

RECOMMENDED ACTIONS:

1. Append to Appendix I (Health Effects) any additional material or information 

submitted at the Public Adoption Hearing and then accept Appendix I, which 

includes a report on the health effects from particulate matter in the South Coast Air 

Basin, as in conformance with Health and Safety Code Section 40471(b).

2. Certify the Final Program Environmental Impact Report for the 2012 AQMP, in 

accordance with the attached Resolution (Attachment A);

South Coast 

Air Quality Management District

21865 Copley Drive, Diamond Bar, CA 91765-4178

(909) 396-2000  www.aqmd.gov
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3. Adopt the 2012 AQMP in accordance with the attached Resolution; 

4. Authorize the Executive Officer to make appropriate changes to the adopted 2012 

AQMP and its appendices (if necessary) to reflect amendments adopted at the 

Public Hearing; and then

5. Direct the Executive Officer to forward the adopted 2012 AQMP (as changed) 

including its appendices to the California Air Resources for its approval and 

subsequent submittal to the U.S. Environmental Protection Agency.

Barry R. Wallerstein, D.Env.

Executive Officer

EC:PF:vm

Background

The U.S. Environmental Protection Agency (EPA) promulgated the National Ambient 

Air Quality Standards (NAAQS) for Fine Particles (PM2.5) and 8-hour ozone (O3) in 

July 1997 which became effective in June 2004 and April 2005, respectively. The federal 

1-hour ozone standard of 1979 was revoked by the U.S. EPA and replaced by the 8-hour 

average ozone standard, effective June 15, 2005. However, the South Coast Air Basin 

(Basin) and the former Southeast Desert Modified Air Quality Management Area (which 

included the Coachella Valley) did not attain the 1-hour federal ozone NAAQS by the 

attainment date and have some continuing obligations under the former standard. Ozone 

and PM2.5 are the main regional pollutants for which the U.S EPA has designated the 

Basin as nonattainment. The Coachella Valley is also a nonattainment area for ozone, but 

PM2.5 concentrations remain below the federal standards. 

Several changes to the NAAQS have occurred since the last Air Quality Management 

Plan (AQMP) update in 2007:

 In 2006, U.S. EPA significantly lowered the level of the 24-hour PM2.5 standard, 

from 65 to 35 g/m3, while retaining the level of the annual PM2.5 standard, 

15g/m3. On December 14, 2009, the U.S. EPA designated the Basin as 

nonattainment for the 2006 24-hour PM2.5 NAAQS. A SIP revision is due to U.S. 

EPA no later than three years from the effective date of designation, December 14, 

2012, demonstrating attainment with the standard by 2014. 

 Effective May 27, 2008, the 8-hour ozone NAAQS was subsequently lowered from 

80 to 75 ppb. The SIP submittal for this standard is not due until 2015. However, 

nonattainment areas for the 1997 8-hour ozone standard have continuing obligations 

to implement their plan and demonstrate attainment of that standard by the applicable 

attainment date. 
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 In 2008, the California Air Resources Board (CARB) withdrew key components of its 

emission reduction commitments in the 2003 South Coast 1-hour ozone SIP. In 2009, 

U.S EPA approved certain elements of the 2003 South Coast 1-Hour Ozone SIP but 

disapproved the attainment demonstration, largely because CARB’s 2008 withdrawal 

of emission reduction commitments rendered the plan insufficient to demonstrate 

attainment. Based on the court decision in Ass’n of Irritated Residents v. EPA, 686 

F.3d 668 (9th Cir. 2012), on September 19, 2012, U.S EPA published a proposed SIP 

call under Section 110(k)(5) of the CAA, finding the existing approved 1-hour ozone 

SIP substantially inadequate to provide for attainment of the revoked 1-hour ozone 

standard by the applicable attainment date of November 15, 2010. U.S EPA’s

proposed SIP call would give the State up to one year after the effective date of the 

final SIP call to submit the revised attainment demonstration. The District’s submittal 

of the updated 1-hour ozone attainment demonstration as part of this Final 2012 

AQMP is in response to this recent U.S. EPA proposed action. Pursuant to the AIR 

case, U.S EPA also disapproved the SIP revisions submitted by the State of California 

to meet the vehicle miles traveled (VMT) emissions offset requirement under the 

Clean Air Act for the Los Angeles-South Coast Air Basin 1-hour and 8-hour ozone 

nonattainment areas.

The purposes of the 2012 AQMP for the Basin are to set forth a comprehensive and 

integrated program that will lead the Basin into compliance with the federal 24-hour 

PM2.5 air quality standard, to satisfy the planning requirements of the federal Clean Air 

Act, and to provide an update to the Basin’s commitments towards meeting the federal 8-

hour ozone standards. It will also serve to satisfy the recent U.S. EPA proposed 

requirement for a new attainment demonstration of the revoked 1-hour ozone standard, as 

well as a VMT emissions offset demonstration. Specifically, the Plan will serve as the 

official SIP submittal for the federal 2006 24-hour PM2.5 standard, for which U.S. EPA 

has established a due date of December 14, 2012. In addition, the 2012 AQMP will 

update specific new control measures and commitments for emissions reductions to 

implement the attainment strategy for the 8-hour ozone SIP, and thus help to reduce 

reliance on CAA Section 182(e)(5) long-term measures. Once approved by the District 

Governing Board and CARB, the 2012 AQMP will be submitted to U.S. EPA as the 24-

hour PM2.5 SIP addressing the 2006 PM2.5 NAAQS and as a limited update to the 

approved 8-hour ozone SIP. The 1-hour ozone attainment demonstration and VMT 

emissions offset demonstration will also be submitted through CARB to EPA.

The 2012 AQMP also includes an update on the air quality status of the Salton Sea Air 

Basin (SSAB) in the Coachella Valley, a discussion of the emerging issues of ultrafine 

particle and near-roadway exposures, a report on the health effects of PM2.5, and an 

analysis of the energy supply and demand issues that face the Basin and their relationship 

to air quality. Pursuant to statute, the public hearing will also discuss the report on health 

effects of PM2.5 (Health & Safety Code §40471).
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Public Process 

The development of the 2012 AQMP has been a regional, multi-agency effort including 

the District Governing Board, CARB, Southern California Association of Governments 

(SCAG), and U.S. EPA. A 2012 AQMP Advisory Group was formed to provide 

feedback and recommendations on the development of the plan, including policy issues 

and control strategies. The Advisory Group represents a diverse cross section of 

stakeholders such as large and small businesses, government agencies, environmental and 

community groups, and academia. In addition, a Scientific, Technical, and Modeling Peer 

Review (STMPR) Advisory Group convened to make recommendations on air quality 

modeling, emissions inventory and socioeconomic modeling and analysis. Both Advisory 

Groups met monthly throughout the AQMP development process and those meetings 

have been open to the public. 

The AQMD conducted a Technology Symposium in September 2011 with the 

participation of over 150 attendees, including representatives from federal, state, and 

local governments, academia, industry experts and the public. The goal of the 

symposium was to solicit new and innovative control concepts to assist in designing a 

plan for attaining the ambient air quality standards. Based on input received, District 

staff developed 38 control measures for the 2012 AQMP.

In conjunction with the development of the 2012 AQMP, staff prepared an enhanced

2012 AQMP Outreach Program to inform and engage a wide range of stakeholders on the 

requirements, approach, goals, and impacts of the 2012 AQMP. In addition to on-going 

AQMP Advisory Group and Scientific, Technical, Modeling & Peer Review Advisory 

Group meetings, and the mandatory regional workshops/hearings, staff engaged in 

enhanced outreach to all stakeholders in the region through numerous presentations, 

workshops, focus groups throughout the Basin. In all, over 100 meetings were conducted 

in which the 2012 AQMP was presented or discussed.

A Draft 2012 AQMP was released in July 2012 in order to provide the public and other 

stakeholders an early opportunity for review. Subsequent to the release of the Draft 2012

AQMP, four regional hearings were held throughout the four counties in September 2012

to discuss the Draft 2012 AQMP and solicit public input.

Based on comments received, revisions to the Draft 2012 AQMP were made publicly 

available in a Revised Draft 2012 AQMP released in September 2012. An additional 

four regional public hearings were held in November 2012 in each of the four counties, 

where additional public input and comments were solicited. These hearings also 

discussed Appendix I, which reports on the health effects of PM2.5. As a result of this 

extensive public process, the Final Draft 2012 AQMP is being submitted to the Board for 

its consideration. 
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Proposal

The 2012 AQMP incorporates the most recent planning assumptions and the best 

available information including: revised stationary point and area source emissions 

inventories; on-road and off-road mobile source emissions inventories based on CARB’s 

latest EMFAC2011 and Off-Road Models; the use of new meteorological episodes for 

ozone and expanded air quality modeling analysis; and the latest demographic growth 

forecasts based on the approved 2012 Regional Transportation Plan (2012 RTP) 

developed by SCAG. The Plan also includes control strategies for demonstrating 

attainment with the federal 24-hour PM2.5 air quality standard, and provides an update to 

the Basin’s commitments towards meeting the federal 8-hour ozone standards. It will 

also serve to satisfy recent U.S. EPA proposed requirements for a new attainment 

demonstration of the revoked 1-hour ozone standard, as well as a VMT emissions offset 

demonstration. 

Draft 2012 AQMP

The Draft 2012 AQMP was released on July 2012 and provided the initial strategy for

meeting and maintaining the federal 24-hour PM2.5 air quality standard by attainment 

date of 2014, for satisfying the planning requirements of the federal Clean Air Act, and 

for providing an update to the Basin’s commitments towards meeting the federal 8-hour 

ozone standards. The Draft 2012 AQMP provided base-year and projected emissions 

inventory updates, Reasonably Available Control Technology (RACT) and Reasonably 

Available Control Measure (RACM) analysis, control strategies, an attainment 

demonstration, contingency measures, and transportation conformity budgets. 

Revised Draft 2012 AQMP

Based on the comments received and additional analysis, the Revised Draft 2012 AQMP 

was released in September 2012. The Revised Draft 2012 AQMP included baseline

emission inventory refinements, and clarifications to several control measures. Also, in 

response to public comments, the initial NOx RECLAIM Phase I measure was shifted 

from the main strategy to a contingency measure. Based on discussions with SCAG staff,

an inter-pollutant flexibility mechanism was developed to allow for emissions below the 

budget for one pollutant to be used to supplement another pollutant exceeding the budget 

based on established ratios. During the release of the Revised Draft 2012 AQMP, staff 

also released two additional appendices to satisfy the recent U.S. EPA proposed 

requirements for a new attainment demonstration of the revoked 1-hour ozone standard, 

as well as a VMT emissions offset demonstration; Appendix VII - 1-Hour Ozone 

Attainment Demonstration; and Appendix VIII - Demonstration of Offset of Growth in 

Emissions Associated with Growth in Vehicle Miles Traveled Under Section 

182(d)(1)(A) of The Federal CAA.
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Draft Final 2012 AQMP

The Draft Final 2012 AQMP includes additional revisions to the Revised Draft Plan. 

Noted revisions include: 1) updated discussions of the 1-hour ozone SIP submittal 

requirements; 2) finalized emissions inventory data; 3) finalized modeling results; 4) 

updated precursor equivalency ratios; 5) added clarifications to a few control measures; 

and 6) added an alternative VMT offset demonstration base year approach. A list of the 

documents contained in the Draft Final 2012 AQMP is provided as Attachment B to this 

Board letter. Since the release of the Draft Final AQMP, some minor clarifications were 

made to several control measures in response to comments received. These changes are 

included in Attachment F. 

Key Findings

Some of the key findings and highlights of the 2012 AQMP include:

1) Air Quality Trends - Although the long-term trend of air quality in the Basin shows 

continuous improvement due to existing air quality regulations, the slowing rate of 

improvement in ozone levels is a cause for concern. Both PM10 and PM2.5 levels 

have improved dramatically over the past two decades. Annual average PM10 and 

PM2.5 concentrations have been cut in half since 1990 and 1999, respectively. The 

Basin has met the PM10 standards at all stations and a request for re-designation to 

attainment is pending with U.S. EPA. The 2012 AQMP demonstrates attainment of 

the federal 24-hour PM2.5 standard by 2014 in the Basin through adoption of all 

feasible measures. However, substantial reductions are still needed to meet the 

federal 8-hour and 1-hour ozone standards by the applicable attainment dates.

2) Emissions Inventory - The emission inventory consists of the emissions that 

occurred in the Basin during the 2008 base year, and the projected emissions in the 

milestone years of 2014, 2019, 2023, and 2030. The future year emissions are based 

on growth projections and implementation of adopted air regulations. The emissions 

inventory is divided into four major classifications: stationary, area, on-road, and offroad sources. Despite projected growth in the population and the economy, baseline 

emissions decrease over time due to continued implementation of existing regulations. 

The baseline emission projections provide an estimate of future air quality conditions, 

including the effects from already adopted rules and regulations, but without the

proposed control strategy.

3) Control Strategy - The overall control strategy proposed in the Final 2012 AQMP 

will provide for attainment of the 2006 24-hour PM2.5 standard by the 2014 

attainment date through implementation of short-term 24-hour PM2.5 control 

measures. The short term measures primarily consist of enhancements to episodic 

burning curtailment programs for residential wood burning and open burning. The 

control strategy also specifies ozone measures to further implement the U.S. EPA 

approved ozone plan for the 8-hour ozone standard. The control strategy includes 
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emission reductions from both stationary and mobile sources. The proposed control 

measures in the 2012 AQMP are based on implementation of all feasible control 

measures through the application of available cleaner technologies, best management 

practices, incentive programs, as well as development and implementation of zeroand near-zero technologies and control methods. 

Although the Basin is projected to meet the 2006 24-hour PM2.5 standards by the 

applicable attainment deadlines, significant challenges remain in meeting the federal 

ozone standards. The next AQMP in 2015 will include a more comprehensive 

strategy to demonstrate attainment of the 1997 and 2008 8-hour ozone standards by 

2023 and 2032. The 2007 State Implementation Plan (SIP) for the 8-hour ozone 

NAAQS contains commitments for emission reductions that rely on advancement of 

technologies, as authorized under Section 182(e)(5) of the federal Clean Air Act. 

These innovative strategy (182)(e)(5) measures account for a substantial portion of 

the NOx emission reductions needed to attain the federal ozone standards – over 200 

tons/day. The deadlines to achieve these reductions in the region is 2023 (to attain the 

80 ppb NAAQS) with necessary rulemaking completed by 2020. Therefore, all 

currently feasible ozone control measures are included in the 2012 AQMP as an 

update to the previously approved 2007 8-hour ozone SIP. 

4) 24-Hour PM2.5 Attainment Demonstration and RFP- The CAA requires SIPs for 

most nonattainment areas to demonstrate reasonable further progress (RFP) towards 

attainment through emission reductions phased in from the time of the SIP submission 

until the attainment date time frame. The RFP requirements in the CAA are intended 

to ensure that there are sufficient PM2.5 and precursor emission reductions in each 

nonattainment area to attain the 2006 24-hour PM2.5 NAAQS by the December 14, 

2014 deadline. The 2012 AQMP demonstrates attainment with the 24-hour PM2.5 

standard in 2014, which is five years from the 2009 designation date. In such cases, 

EPA does not require a separate RFP plan.

With respect to the contingency measure requirements, the 2012 AQMP contains an 

excess of 1.2 g/m3air quality improvement (or 71 tpd of NOx equivalent 

reductions) through the proposed measures. 

5) SIP Submission - In order to design the most efficient path to clean air with clear 

regulatory commitments for the immediate future, the 2012 AQMP is an integrated 

plan addressing multiple pollutants and multiple deadlines. It serves as the official 

SIP submittal for the federal 2006 24-hour PM2.5 standard, for which U.S. EPA has 

established a due date of December 14, 2012. The 2012 AQMP also provides a

limited update of specific new control measures and commitments for emissions 

reductions to implement the attainment strategy for the approved 8-hour ozone SIP 

and to reduce reliance on the Section 182(e)(5) long-term measures;
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6) 1-Hour Ozone Attainment Demonstration - The 2012 1-hour attainment 

demonstration was prepared in response to the U.S. EPA’s published “SIP call” 

proposal on September 19, 2012, finding the existing approved 1-hour ozone SIP 

substantially inadequate to provide for attainment of the revoked 1-hour ozone 

standard by the applicable attainment date of November 15, 2010. As a result, the 

state must submit an attainment demonstration for the South Coast for the 1-hour 

ozone standard showing attainment “as expeditiously as practicable,” but not to 

exceed 10 years beyond the effective date of the SIP call. EPA’s proposed SIP call 

would give the State up to one year after the effective date of the final SIP call to 

submit the revised attainment demonstration. The District has demonstrated that a 

period of the full 10 years allowed by law is needed to attain the 1-hour standard. The 

1-hour ozone attainment demonstration is a stand-alone document, but with references 

to the 2012 AQMP and related documents. The attainment demonstration is based on 

emissions in the 2008 base year and projected controlled emissions for the 2022 when 

reductions need to be achieved. Given the approximate alignment of the attainment 

dates, the control strategy for the 1-hour ozone standard is identical to the control 

strategy for the 1997 federal 8-hour ozone standard. The form of the 1-hour standard 

allows for a single exceedance at a station annually. The modeling analysis produces 

a Basin carrying capacity of 410 tons per day of VOC and 150 tons per day of NOx 

emissions to bring the Basin into attainment with the 1-hour ozone standard. These 

emissions translate into 30 TPD (7 percent) reduction in VOC emissions and a 185 

TPD (55 percent) reduction in NOx emissions beyond 2022 baseline emissions. 

7) VMT Offset Requirement Demonstration - The VMT emissions offset 

demonstration for the 1-hour and 8-hour ozone standards is prepared in response to 

U.S. EPA’s proposed action entitled “Disapproval of Implementation Plan Revisions; 

State of California; South Coast VMT Emissions Offset Demonstrations” published 

on September 19, 2012 (77 Fed. Reg. 58067). The VMT offset demonstration is 

performed in accordance with EPA’s new guidance for both the 8-hour and 1-hour 

ozone requirements. To address U.S. EPA’s guidance on the selection of a base year, 

two analyses are provided: One using 1990 as base year for both ozone air quality 

standards, and a second alternative using 2002 as the base year in conjunction with 

the 8-hour ozone attainment demonstration provided in the 2007 SIP. Based on the 

2007 SIP for the 8-hour ozone attainment demonstration, it is projected that the 8-

hour ozone ambient air quality standard will be achieved by 2023. The 1-hour ozone 

attainment demonstration shows that the revoked 1-hour ozone standard will be 

achieved by 2022. Although District staff believes that 1990 is the appropriate base 

year for both the 1-hour and 8-hour demonstration, an alternative analysis using 2002 

is provided for the 8-hour ozone. In both analyses, there are sufficient transportation 

control strategies and TCMs to offset the emissions increase due to growth in VMT.
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Public Comments 

Numerous comments have been received during the Plan development. The specific 

responses to 99 written comment letters on the 2012 AQMP are addressed in Attachment 

C, "Response to Comments to the 2012 AQMP," dated November 2012. Additional 

responses to comment letters not included in the “Draft Final 2012 AQMP Responses to 

Comments to the 2012 AQMP” publicly released on November 21, 2012 are included as 

an Addendum to Attachment C.

Key Policy Issues

There are seven key policy issues related to the adoption of the 2012 AQMP for Board 

consideration which are briefly presented here:

1. Inclusion of an Ozone Strategy in the 2012 AQMP – Comments were 

received stating that the primary purpose of the 2012 AQMP should be to 

demonstrate attainment with the 24-hour PM2.5 standard, which is the only 

legal requirement, and the Plan should not include SIP commitments to address 

the 8-hour ozone standard. 

Staff believes that given the short timeframe until 2023, and the fact that a 

significant fraction of the large amount of emission reductions needed to meet 

the 8-hour ozone standard by 2023 is still from innovative strategy measures, it 

is important to identify specific measures to achieve the needed reductions in a 

timely manner. . Comments and potential litigation on U.S EPA’s approval of 

the 2007 ozone SIP have called into question the relative size and reliance on 

innovative strategy (182)(e)(5) measures to demonstration ozone attainment. 

Making SIP commitments for reductions when they are identified as feasible 

demonstrates AQMD’s strong commitment to reduce reliance on (182)(e)(5)

measures as attainment deadlines approach and preempts possible litigation. 

Moreover, federal law requires expeditious progress and state law requires all 

feasible measures towards meeting clean air standards. Including an 8-hour 

ozone strategy has been supported by U.S. EPA (comment letter dated August 

30, 2012). 

2. Need for VOC Controls in the Ozone Strategy - Comments received stated 

that there is no reason for additional VOC controls in the ozone strategy given 

the need for a NOx-heavy control approach to meet the 8-hour ozone 

standards. Industry believes any additional measures aimed at the lowering of 

VOC content in products, restriction on flexibility provisions, or removal of 

exemptions will create compliance challenges, and will result in the loss of 

business activity in the Basin.

Modeling efforts by staff have shown that while a NOx heavy strategy is 

needed for 8-hour ozone attainment, continued modest VOC reductions are 
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also needed to ensure that all areas of the Basin show improvement in ozone 

levels. This is due to the fact that ozone levels not only depend upon overall 

VOC and NOx emissions levels, but they also depend on the atmospheric ratio 

of VOC to NOx. When this ratio increases due to necessarily aggressive NOx 

reductions, it can lead to increases in ozone levels in some areas, especially in 

the western portion of the Basin. Reduction in VOC emissions could also 

lessen the burden of controlling the NOx emissions. The additional VOC 

reductions are nominal, with some proposed measures ensuring that existing 

claimed reductions will be realized. 

3. Timing of the Submittal of the 1-hour Ozone Attainment Demonstration -

A requirement for the submittal of an attainment demonstration for the revoked 

1-hour ozone standard has been proposed by U.S. EPA, and the submittal will 

be due by no later than the latter part of 2013 or early 2014. Since the 

emissions inventory, control strategy, and RACT/RACM analysis has already 

been developed for the 2012 AQMP, and because attainment of the 1-hour 

standard relies on the same strategy proposed for the 8-hour ozone standard, 

staff was able to complete an attainment demonstration for the 1-hour ozone 

standard as an Appendix to the 2012 AQMP. Some commenters would prefer 

to delay the submittal of the 1-hour ozone attainment demonstration.

Staff believes that there is no reason to delay submitting the 1-hour ozone 

attainment demonstration given that the overall control strategy is the same as 

that for the 8-hour standard. Utilizing the current 2012 AQMP emissions 

inventory, modeling framework and public process is the most efficient use of 

resources and time. Furthermore, there is little current or expected guidance 

from U.S EPA on the technical approach to the 1-hour ozone attainment 

demonstration. Staff believes it has developed the most reasonable technical 

approach, and that the early submittal of the 1-hour ozone attainment 

demonstration with the 2012 AQMP is the best way to get feedback from and 

provide input to U.S. EPA on its approach. Finally, because this issue is 

currently before the Court regarding credit rules, submittal now of the 1-hour 

attainment demonstration should preempt that issue in the current lawsuit. 

4. Evaluation of the Consumer Products Low Vapor Pressure (LVP) 

Exemption - Various affected industries (e.g., cleaning product companies, 

fragrance manufacturers, etc.) were concerned about their ability to 

successfully reformulate their products if implementation of control measure 

CTS-04 results in the removal of exemptions for low vapor pressure 

components. 

The purpose of this measure is to assess the effectiveness of existing rules with 

an LVP exemption. Recent studies indicate many solvents that currently enjoy 

the LVP exemption volatilize just as rapidly and exhibit reactivity values 
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comparable to those of conventional solvents. CTS-04 does not seek an across 

the board elimination of the LVP exemption but rather the re-evaluation of the 

criteria for the exemption to ensure that the environmental benefit of the 

consumer product regulation is fully achieved. The control measure seeks a 

phased implementation starting with data collection of sales and formulation. 

Then, it will identify product categories for lab testing of evaporative potential 

where the exemption may need revision. Finally, alternatives to LVP-VOCs 

will be identified. CARB has authority over the relevant consumer product 

regulations, and staff is working in partnership with CARB on proposed 

technical studies and data collection. Any alteration to the LVP exemption 

will be developed pursuant to the traditional rulemaking process that includes

detailed feasibility and cost benefit evaluations as well as extensive public 

participation. Potential emission reductions are not being committed into SIP. 

Proposed clarifications to CTS-04 in the Draft Final Plan are included in 

Attachment F. 

5. Implementing BCM-01 (Residential Wood Burning) – Concerns were raised 

as to whether the burning of wood from residential fireplaces is a major source 

of PM2.5 pollution and if curtailment has any substantial benefits. There have 

also been comments regarding the need for extensive outreach and education 

associated with the curtailment measure.

Modeling by staff has clearly shown that the wood burning curtailment 

substantially reduces PM2.5 concentration levels during high pollution 

episodes, and thus is the primary control measure allowing the Basin to 

achieve the 24-hour PM2.5 standard by 2014. Staff is aware of the challenges 

in raising public awareness of the curtailment program, in providing sufficient 

notice on curtailment days, and in communicating the health impacts of wood 

smoke. Staff believes that education and outreach are the most important 

components of this measure, and strategic planning for communication 

programs is already underway. Other air districts in the state of California 

have successfully implemented a similar program, thus, it is considered a 

feasible control measure. 

6. Backstop Rule for Indirect Sources at Ports – The Ports of Los Angeles and 

Long Beach have provided comments on Control Measure IND-01: Backstop 

Measure for Indirect Sources of Emissions from Ports and Port Related 

Sources (Port Backstop Measure). Through the Clean Air Action Plan 

(CAAP), the Ports have voluntarily implemented programs to reduce emissions 

from a variety of port-related sources. The Ports have commented that the 

AQMD “reconsider its approach and allow the continuation of the successful 

collaborative work by the ports, regulatory agencies and other stakeholders 

under the voluntary Clean Air Action Plan and the San Pedro Bay Standards.” 
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As a result, the Ports have requested that the Port Backstop Measure be 

removed from the 2012 AQMP. The Ports have commented that they “can’t 

accept any regulatory action by the AQMD that will result in AQMD oversight 

and approvals of port actions, or enforcement actions by the AQMD on the 

ports for failure of the port industry to meet the ports’ emission reduction 

goals.”The AQMD staff agrees that the Ports have made significant progress in 

reducing emissions. It still remains however, that the Ports of Los Angeles and 

Long Beach are collectively the single largest fixed source of air pollution in 

Southern California. Port sources such as marine vessels, locomotives, trucks, 

harbor craft and cargo handling equipment, continue to be the largest sources 

of NOx, PM2.5 and PM2.5 precursors in the region. These sources play a 

major role in the Basin’s ability to achieve the national PM2.5 ambient air 

quality standards. The AQMD staff believes that it is appropriate and 

necessary to include a backstop measure to ensure that the Basin’s largest 

source of NOx and PM2.5 emissions maintains its course of emission 

reductions. 

In response to comments from the Ports, the AQMD staff has made revisions 

to the Port Backstop Measure that further clarifies the intent and rule 

development process (see Attachment F). AQMD staff has clarified that a 

backstop rule will become effective only if emissions from port-related sources 

exceed targets for NOx, SOx, and PM2.5 in 2014. In addition, the measure has 

been revised to further clarify that if additional emission reductions are needed, 

the Ports would be required to submit a plan on only the emission reduction 

shortfall. The backstop rule would not require any strategy to be implemented 

that lacked legal authority, was not cost-effective, or was found to be 

infeasible. In addition, staff clarified that the backstop rule would include time 

extension to achieve the targets, if necessary. Lastly, language has been added 

to the measure regarding enforcement of the port backstop rule. The AQMD 

staff is committed to continue to work collaboratively with the Ports, agencies, 

environmental community groups, industry representatives, and other 

interested parties through the rule development process

7. NOx RECLAIM Reduction - Comments were made as to the need for the 

first phase of NOx emissions reductions from RECLAIM facilities. 

Commenters have also expressed opinions on the mechanism for the NOx 

RECLAIM shave (all RECLAIM sources, larger RECLAIM sources, etc.)

State law requires a periodic review and the last re-evaluation of NOx 

RECLAIM occurred 7-8 years ago (2004-2005). Further NOx reductions are 

necessary for attainment of the ozone standard. In the Revised Draft 2012 

AQMP, the first phase of the NOx RECLAIM shave has been shifted to a 

contingency measure, only to be implemented if the Basin fails to attain the 24-
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hour PM2.5 standard by 2014. The measure will have a gradual 

implementation to fully achieve a total of 3-5 tons per day NOx RECLAIM 

reductions by 2020. Staff will assess mechanisms for the NOX RECLAIM 

shave during rule development. Proposed clarifications to CMB-01 in the 

Draft Final Plan are included in Attachment F. 

8. Compressed Schedule - Concern has been raised that the 2012 AQMP 

development schedule has been compressed, with limited time for review and 

public input on all documents.

A total of 17 months for public discussion and review occurred during the 

2012 AQMP development process. All data and information has been 

provided to the public as soon as it became available in an open and 

transparent process. The review period for most of the documents has been 

extended, additional workshops and regional public hearings have been added, 

and the scheduled Governing Board adoption hearing date was postponed from 

September to December 2012. The Draft Plan was released for 51 days; the 

Revised Draft for 61 days and the Draft Final for 30 days. The Draft Program 

EIR and Socioeconomic Report were circulated for public review and 

comment for 45-days. There have been seven public workshops, eight regional 

hearings in the four-county region, 13 AQMP Advisory Group meetings and 

11 STMPR Advisory Group meetings. Staff participated in 75 outreach 

meetings and provided 65 formal presentations on the 2012 AQMP. Thus, 

there has been extensive outreach and sufficient time for public comment was 

provided. 

CEQA

Pursuant to California Environmental Quality Act (CEQA) Guidelines §15168, the 

AQMD has prepared a Program Environmental Impact Report (PEIR) for the 2012

AQMP. The Draft PEIR was released for a 45-day public review and comment period 

beginning on September 7, 2012, and ending on October 23, 2012. The Draft PEIR 

analyzed potential adverse impacts from implementing AQMP control measures in the 

following environmental areas: aesthetics; air quality; energy; hazards and hazardous 

materials; hydrology and water quality; land use; noise; solid/hazardous waste; and 

transportation/traffic. Responses to all comments received have been prepared and 

incorporated into the Final PEIR for the proposed project. Finally, since significant 

adverse environmental impacts and mitigation measures were identified for the proposed 

project, a Statement of Findings, a Statement of Overriding Considerations, and a 

Mitigation Monitoring Plan were prepared in accordance with the requirements of CEQA 

(Attachment 2 to the Board Resolution). 
- 14 -

Socioeconomic Analysis

The socioeconomic analysis for the 2012 AQMP includes costs of control measures, 

benefits of clean air, job impacts, and other socioeconomic impacts. The analysis is 

presented at the sub-county level (21 regions within the four-county area).

The projected average annual implementation cost of the 2012 AQMP is $448 million. 

The PM2.5 strategy, including TCMs proposed by the Southern California Association of 

Governments (SCAG), is projected to cost $326.6 million. The cost of TCMs alone is 

$326.4 million. The projected cost for all the ozone measures is approximately $122 

million annually, of which $40 million is attributable to stationary source controls.

Compliance with the federal 24-hour PM2.5 standard and progress toward the ozone 

standards are projected to result in an average annual clean air benefit of $3.5 billion. 

The $3.5 billion benefit includes approximately $519 million for congestion relief from 

TCMs, $2.2 billion for reductions in premature deaths and averted illness, $696 million 

for visibility improvements, and $14 million for reduced damage to materials. 

The socioeconomic analysis represents a rigorous application of statistical and economic 

framework, epidemiological studies, and computer modeling to assess the aggregate 

potential impacts of the overall suite of control measures and their resulting clean air 

benefits. The analysis has undergone external peer-review to improve information for the 

2012 AQMP and seek suggestions for enhancement of future analyses.

Based on the analysis, the 2012 AQMP is not expected to result in dramatic impacts on 

the region’s competitiveness. The estimated $3.5 billion benefit is greater than the

estimated $448 million cost. There is a net modest job gain as a result of the 2012 

AQMP.

Staff utilized all available information and state-of-the-art models for the socioeconomic 

analysis, and the methodology underwent extensive peer-review. Key comments 

received from stakeholders on the socioeconomic report include the need for the 

quantification of cost effectiveness for all control measures, as well as questioning the 

assumptions used to quantify the job creation benefits of cleaner air.

Cost effectiveness values were determined for all the control measures with committed 

SIP emissions reductions, except for one measure which requires further technology 

assessment and selection to estimate the costs. Staff is committed to conducting a review 

of its socioeconomic methodology during 2013, convening a panel of experts, and 

updating the underlying technical studies and assumptions, the assessment methods, and 

the modeling approaches as appropriate.
- 15 -

Particulate Matter Health Effects

Appendix I (Health Effects) in the 2012 AQMP was prepared to discuss the overall health 

effects from criteria pollutants (e.g., ozone, PM, CO, NO2, SO2, sulfates, lead) and toxic 

air contaminants. The Appendix includes a report on the health effects of particulate 

matter in the South Coast Air Basin as required by California Health & Safety Code 

Section 40471(b). The evaluation was prepared in conjunction with public health 

agencies, CARB and OEHHA, and peer-reviewed by an Advisory Council made up of 16 

members chosen by the Governing Board members and Advisory Groups pursuant to 

California Health & Safety Code Section 40428. Appendix I was modified to reflect any 

comments received from the Advisory Council, health agencies and general public. 

Findings include that a large body of scientific evidence shows adverse impacts of air 

pollution including PM2.5 on human and animal health. Population-based and laboratory 

studies link air pollution including PM2.5 and increased morbidity and, in some 

instances, earlier mortality. Finally, while methods to study air pollution health effects 

have progressed, there are still no clear thresholds below which no adverse effects are 

demonstrated for some pollutants. 

The 2012 AQMP submitted for the Governing Boards’ consideration consists of the 

documents entitled:

 Resolution (Attachment A)

 Draft Final 2012 AQMP (Attachment B)

 Appendix I - Health Effects 

 Appendix II - Current Air Quality 

 Appendix III - Base and Future Year Emission Inventory 

 Appendix IV (A) - District’s Stationary Source Control Measures

 Appendix IV (B) - Proposed 8-Hour Ozone Measures

 Appendix IV (C) - Regional Transportation Strategies & Control Measures

 Appendix V - Modeling & Attainment Demonstrations

 Appendix VI - Reasonably Available Control Measures (RACM) Demonstration

 Appendix VII - 1-Hour Ozone Attainment Demonstration

 Appendix VIII - VMT Offset Requirement Demonstration

 Responses to Comments on the 2012 AQMP (November 2012) – (Attachment C)

 Final Program Environmental Impact Report for the 2012 AQMP (Attachment D)

 Findings, Statement of Overriding Considerations, and Mitigation Monitoring and 

Reporting Plan (Attachment 2 to the Resolution)

 Draft Final Socioeconomic Report for the 2012 AQMP (Attachment E)

 Changes to Control Measures IND-01, CMB-01, CTS-01 and CTS-04 (Attachment F)
- 16 -

All of the above documents, as well as previous drafts and marked-up versions, have 

been made available to the public on the AQMD Website 

(http://www.aqmd.gov/aqmp/2012aqmp/DraftFinal/index.html) and have also been made 

available through the AQMD Public Information Center.

Attachments

A. Resolution (including Attachment 2: Findings, Statement of Overriding 

Considerations, and Mitigation Monitoring and Reporting Plan)

B. Draft Final 2012 AQMP (including Appendices I-VIII)

C. Responses to Comments on the 2012 AQMP

D. Final Program Environmental Impact Report for the 2012 AQMP

E. Draft Final Socioeconomic Report for the 2012 AQMP

F. Changes to Control Measures IND-01, CMB-01, CTS-01 and CTS-04