BOARD MEETING DATE: December 7

, 20 12 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
st akeholders 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 standa rd for 2023, an attainment demonstration for the revoked 1

- hour ozone standard

, a VMT offset demonstration for ozone standards, and a report o n 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 ACTION S : 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 (A ttachment A); 

## South Coast Air Quality Management District 21865 Copley Drive, Diamond Bar, CA 91765

- 4178 (909) 396

- 2000  www.aqmd.gov- 2

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3. Adopt the 20 12 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 2 012 AQMP (as changed) including its appendices to the California Air Resources for its approval and subsequent submittal to the U.S. Environmental Protection Agency.

Ba rry 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 (O 3 ) 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 Manage ment 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/m 3

, while retaining the level of the annual PM2.5 standard

, 15  g/m 3

. On December 14, 2009, the U.S. EPA designated the Basi n 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, t he 8

- hour ozone NAAQS was subsequently lowered from 80 to 75 ppb

. T he 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 a ttainment of that standard by the applicable attainment date.- 3

-

 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 el ements 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) , o n 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 atta inment 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 demonstrat ion. The District ’s submittal of the updated 1

- hour ozone attainment demonstration as part of th is 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 t he 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 purpose s 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 commit ments 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. Spe cifically, 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 commitme nts 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 submitt ed 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).- 4

-

Public Process T he 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 recom mendations 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, an d 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 throug hout the AQMP development process and those meetings have been open to the public.

T he AQMD conducted a Technology S ymposium in September 201 1 with the participation of over 150 attendees

, including representatives from federal, state, and local governme nts, 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 a n enhanced 2012 AQMP Outreach Program to inform and engage a wide range of stakeholders on the requirements, approach, goals, and impacts of the 2 012 AQMP. I n 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

e nhanced outreach to all stakeholders in the region through n umerous presentations, workshops, focus groups through out the Basin

. In all, over 100 meetings were conducted in which the 2012 AQMP was presented or discussed.

A Draft 2012 AQMP was relea sed i n July 2012 in order to provide the public and other stakehol ders 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, r evisions 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 co mments 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 20 12 AQMP is being submitted to the Board for its consideration.- 5

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Proposal The 20 12 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 EMFAC2 0 11 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 20 12 Regional Transportation Plan ( 2012 RTP) developed by SCAG. The Pla n also includes control strategies for demonstrating attainment with the federal 24

- hour PM2.5 air quality standard

, and provide s 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 20 12 AQMP T he Draft 20 12 AQMP was released on July 2012 and provide d the initial strategy for
meet ing and maintain ing the federal 24

- hour PM2.5 air quality standard by attainment date of 20 14

, for satisfy ing the planning requirements of the federal Clean Air Act, and for provid ing 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 strateg ies

, an attainment demonstratio n, contingency measures , and transportation conformity budgets.

Revised Draft 20 12 AQMP Based on the comments received and additional analysis, the Revised Draft 20 12 AQMP

was released i n September 20 12 . The Revised Draft 20 12 AQMP included baseline

em ission inventor y refinements, and clarification s 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. B ased 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 ex ceeding the budget based on established ratios. During the release of the Revised Draft 2012 AQM P, 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

- H our O zone A tta inment D emonstration ; and Appendix VIII

- D emonstration of O ffset of G rowth in E missions A ssociated with G rowth in V ehicle M iles T raveled U nder S ection 182(d)(1)(A) of The Federal CAA.- 6

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Draft Final 20 12 AQMP The Draft Final 20 12 AQMP includes additional revisions to the Revised Draft P lan. Noted revisions include: 1) u pdated discussions of the 1

- hour ozone SIP submittal requirements; 2) f

inalized emissions inventory data; 3 ) f inalized modeling results; 4) updated precursor equivalency ratios; 5) added c larifications to a few control measures ; and 6) added a n alternative VMT offset demonstration base year approach

. A list of the documents contained in the Draft Final 20 12 AQMP is provided as Attachment B to this Board letter. Since the release of the Dr aft 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 Tren d s - 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 dramatical ly 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. E PA. 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 need ed t o 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 e missions 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 off

road sources. Despite projected growth in the population and t he economy, b aseline emissions decrease over time due to continued implementation of existing regulations

. The baseline emission projections provide a n estimate of future air quality conditions, including the effects from already adopted rules and regulat ions, 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- 7

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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

mea sures through the application of available cleaner technologies, best management practices, incentive programs, as well as development and implementation of zero

and 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

- h our 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 20 23 (to at tain 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 Demonstra tion 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 re quirements 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/m 3 air qualit y 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 AQM P is an integrated plan addressing multiple pollutants and multiple deadlines. It serve s 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. T he 2012 AQMP also provides a limited update o f 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 ;- 8

-

6) 1

- Hour Ozone Attainment Demonstration

- The 2012 1

- hour attainment demonstration was prepared in respon s e 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 ozo ne 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 demonstrate d 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

e missions 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 t he 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 brin g the Basin into attainment with the 1

- hour ozone standard . The se emissions translate in to 30 TPD (7 percen t) reduction in VOC emissions and a 185 TPD (55 percent) reduction in NOx emissions beyond 2022 baseline emissions

. 7) VMT Offset Requirement Demons tration

- 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. B ased on t he 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 t he 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

con trol strategies and TCMs to offset the emissions increase due to growth in VMT.- 9

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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 20 12 AQMP are addressed in A t tach ment C , "Response to Comments to the 20 12 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 A ddendum to Attachment C.

Key Policy Issues There are seven key policy issues related to the adoption of the 20 12 AQMP for Board consideration which are briefly presented here:

1. Inclusion of an Ozone Strategy in the 2012 AQMP

– Comment s were received stati ng 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 th at 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 m easures 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 demonstra tion 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 l itigation

. Moreover , federal law requires expeditious progress and state law requires all feasible measures t owards 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 Control s 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 aime d 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- 10

-

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 th e 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 ensur ing that existing claimed reductions will be realized

.
3. Timing of the Submi ttal 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 o r 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 wa s 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 ea rly submitt al 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 the ir 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 effective ness 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- 11

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comparable to those of conventional solvents. CTS

- 04 does not seek an acro ss 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 s tarting 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. Impleme nting 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 n eed 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 Sour ces 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 t hat 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.”- 12

-

As a result, the Por ts 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 t he 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 an d 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 continge ncy measure, only to be implemented if the Basin fails to attain the 24

-- 13

-

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 lim ited time for review and public input on all do c uments

. 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 a n 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 Dece mber 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 wo rkshops, 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 exten sive outreach and s ufficient 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 20 12 AQMP

. The Draft PEIR was r eleased for a 45

- day public review and comment period beginning on September 7 , 20 12 , and ending on October 23 , 20 12

. The Draft PEIR analyzed potential adverse impacts from implementing AQMP control measures in the following environmental areas: aesthetic s; 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 pr oposed 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 cost s of control measures

, benefit s 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 TCM s proposed by the Southern California Associ ation 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 co ntrols.

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 in formation 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 comme nts 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 clean er air.

Cost effect iveness 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 c riteria 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 th e Governing Board members and Advisor y Group s pursuant to California Health & Safety Code Section 40428. Appendix I was modified to reflect any comments received from the Advisory Council , h ealth agenc ies and general public. Findings include that a large body of scientific evidence shows adverse impacts of air pollution including PM2.5 o n human and animal health

. Population

- based and laboratory studies link air pollution including PM2.5 and increased morbidity and, i n some instances, earlier mortality

. Finally, while m ethods 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 20 12 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 Sourc e 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) Demonst ration

 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/201 2aqmp/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. Dra ft Final 20 12 AQMP ( including Appendices I

- VIII ) C. Responses to Comments on the 2012 AQMP D. Final Program Environmental Impact Report for the 20 12 AQMP E. Draft Final Socioeconomic Report for the 2012 AQMP F. Changes to Control Measures IND

- 0 1, CMB

- 01, CTS

- 01 and CTS

- 04