150 SOUTH NINTH STREET TELEPHONE: (760) 482

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- 9904 AIR POLLUTION CONTROL DISTRICT



### STAFF REPORT

FINAL DRAFT Imperial County 20 13 State Implementation Plan for the 2006 24

- Hour

PM 2.5 

### Moderate Nonattainment Area ( 2013 PM 2.5 

### SIP)

I Executive Summary

Since 1997 the United States Environmental Protection Agency (U.S. EPA) has

released two Na tional Ambient Air Quality Standards (Standard) for particulate matter or

PM. The PM Standards included PM 10 and PM 2.5

.

For PM 2.5 , U.S. EPA determined, using monitoring data, that Imperial County attained or met the 1997 standard (65μg/m 3 ). However, on October 17, 2006, U.S. EPA strengthened the primary and secondary 24

- hour PM 2.5 NAAQS from 65ug/m 3 to

35 ug/m 3 . The U.S. EPA designated Imperial County as “Moderate” Nonattainment for

the 2006 PM 2.5 NAAQS and required Imperial County to submit a PM 2.5 SIP t o the U.S. EPA by the end of December 2014.

The Clean Air Act requires a PM 2.5 SIP to address certain elements affecting an identified nonattainment area (NA). They are, 1) an emission inventory; 2) an attainment demonstration 3) transportation conformit y budgets; 4) New Source Review updates; 5) an analysis of Reasonably Available control Measures and Technologies (RACM/RACT); 6) an assessment of Reasonable Further Progress (RFP); and 7) Contingency Measures.

Finally, in order not to unduly burden borde r regions that are significantly impacted by international emissions, the Clean Air Act allows “States” to demonstrate, to the satisfaction of U.S. EPA, that the area qualifies for treatment under section 179B, which provides that areas which would have at tained the standard by the attainment date but for emissions from outside the U.S. are not to be subject to reclassification (i.e. from Moderate to Serious)

II Final Draft Imperial County 2013 PM 2.5 SIP (Plan) Description

The 2013 PM 2.5 SIP (Plan) for Imper ial County is a highly technical and scientific plan developed cooperatively with the California Air Resources Board and U.S. EPA. The

PM 2.5 SIP demonstrates that emissions originating in Mexico impacted the Calexico area during five exceedance days betwee n 2010 and 2012. The PM 2.5 SIP demonstrates that Imperial County would have attained the 24

- hour PM 2.5 standard “but for” emissions from Mexicali. Each chapter addresses specific elements required by the

Clean Air Act.

I Staff Report for the 2013 PM 2.5 SIP150 SOUTH NINTH STREET TELEPHONE: (760) 482

- 4606 EL CENTRO, CA 92243

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Chapter One

- Introduction and Background

This chapter introduces the reader to the pollutant in question, PM 2.5 . The chapter gives the reader the necessary regulatory background, identifies the regulatory agencies affected, a general description of the nonattainment area identified i n Imperial County and gives a general overview of the nature, components and the affects of PM 2.5

. Essentially, this chapter brings together the necessary data and discussion in presenting the PM 2.5 SIP for the 2006 NAAQS.

Chapter Two

– Ambient and Air Quality Data

This chapter introduces the reader to the concept of ambient air, its collection and use of data. It gives the reader information regarding the nature of the interaction between the identified pollutant, meteorology, climate, and location . This chapter provides an overview of impact of climate and meteorology on the dispersion of particulate matter, a description of the local air monitoring network and an overview of PM 2.5 data collected and its temporal and spatial patterns within Imperi al County. Essentially, the air quality

data demonstrates that air quality in Brawley and El Centro has improved showing a reduction of the average design value; however, in Calexico, air quality has not improved

and remains above the PM 2.5 standard of 35 μ g/m3.

Chapter Three

– Emissions Inventory

This chapter explains and introduces the reader to the concept of an “Emissions Inventory”. The chapter explains what an emissions inventory is, an accounting of the amount of a given pollutant that is emitted into the atmosphere by various sources over a specific time period. It also explains how a given pollutant is classified or categorized, either a “stationary source”, “area

- wide source” or “mobile source”. The chapter further explains and discloses the po llutants under review, PM 2.5 (known as direct PM 2.5 ) and its precursors (NOx, SOx, VOC’s, and ammonia) and provides the reader the time period used to analyze the Plan, 2008, 2011 and 2012. To complete the cycle the chapter discloses the actual concentrat ions per classification for each of the identified years, 2008, 2011 and 2012. Finally, because emissions inventories are an accounting of the concentrations of a given pollutant the chapter discusses the pollutants within the context of “significance”. Overall the chapter identifies the significant sources of direct

PM 2.5 as unpaved road dust, fugitive windblown dust, farming operations (tilling), managed burning and disposal and emissions from aircraft. No significant sources were identified for precur sor emissions.

Chapter Four

– Attainment Demonstration

Chapter 4 is an overview of t he 179B analysis , “But

- for” emissions from Mexicali,

Mexico found in “Attachment A”. Chapter 4 summarizes the technical and scientific evidence analyzed within the 179B a nalysis which demonstrates that the Imperial

II Staff Report for the 2013 PM 2.5 SIP150 SOUTH NINTH STREET TELEPHONE: (760) 482

- 4606 EL CENTRO, CA 92243

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County nonattainment area (NA) would have timely attained the PM 2.5 standard “but for” emissions from Mexicali, Mexico.

Summary of the 179B Analysis for PM 2.5 Emissions Impacting Calexico in Imperial County

T he 179B Analysis utilized techniques reference d in U.S. EPA guidelines for areas impacted by emissions originating outside the U.S. Taking a scientific view point, with no preconceived notions, the analysis consisted of assessing emission inventories from Imperial County and Mexicali; evaluating samples collected from the Calexico monitor on exceedance days; reviewing meteorology; and performing what is known as a directional analysis which is an analysis that begins at the monitor and follows back to

the direction that it came from.

The technical analysis (Attachment A) indicated that the violations which occurred in

Calexico for the 24

- hour PM 2.5 were due to emission sources not found in California. The analysis further found that PM 2.5 concentrations a t El Centro and Brawley, which are more representative of local emissions within Imperial County, were significantly lower during those Calexico violation days. Overall, violations in Calexico occurred during stagnant conditions, where pollution from holi day activities in Mexicali, including extensive firework displays and bonfires containing plastics, tires and other refuse materials filled the entire air shed and drifted into Calexico. The analysis indicated that “but for” increased pollution emissions from the Mexicali Metropolitan area the Calexico

PM 2.5 levels would have attained the 24

- hour PM 2.5 standard.

The 179B Analysis demonstrates that emissions originating in Mexico impacted the Calexico area during five exceedance days between 2010 and 2012. The analysis also demonstrates that Imperial County would have attained the 24

- hour PM 2.5 standard “but

for” emissions from Mexicali.

Chapter Five

– RACM/RACT, RFP, Contingency Measures and Transportation Conformity

Chapter 5 provides the reader with t he methodology, summary and analysis of the Reasonable Available Control Measures (RACM), Reasonable Further Progress (RFP), Contingency Measures and the Transportation Conformity budgets, all requirements of moderate nonattainment areas. Chapter 5 explai ns to the reader the why’s, how’s and results of the RACM analysis required by the Clean Air Act. Without a proper RACM analysis, RFP, Contingency Measures and Transportation Conformity budgets become

difficult to assess.

Chapter 5 explains the regulator y background and requirements associated with any RACM analysis. It further summarizes the current measures and programs that are being implemented to address those significant sources of direct PM 2.5 . As mentioned within the Chapter 3 summary no signifi cant sources of PM 2.5 precursor emissions were

III Staff Report for the 2013 PM 2.5 SIP150 SOUTH NINTH STREET TELEPHONE: (760) 482

- 4606 EL CENTRO, CA 92243

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- 9904 AIR POLLUTION CONTROL DISTRICT

identified. Chapter 5 summarizes the current rules applicable to unpaved road dust, fugitive windblown dust, farming operations (tilling), managed burning and disposal and describes the state mobile program w hich addresses emissions from aircraft. Chapter 5 refers the reader to “Attachment B” for detailed rule comparisons. The RACM analysis (which includes RACT) demonstrates that the emissions of the collective existing control

measures are sufficient to main tain attainment “but for” emissions from an international source. However, in order to further protect the public health and to prepare for the newly adopted annual PM 2.5 standard Chapter 5 includes a commitment by Imperial County to further study sources of ammonia, i.e. Beef Feedlots, Composting Facilities and Agricultural Fertilizers.

In addition, Chapter 5 explains that RFP and Contingency Measures are met. The first year that the Imperial County NA would attain is 2012, therefore the milestones, whi ch is required for any RFP demonstration, shows emissions decreasing linearly or staying the same from 2008 to 2012 (the attainment year), meeting the original intent of demonstrating progress towards attainment. Contingency measures are met because

the a ttainment and RFP years are in the past. Since the Clean Air Act only requires contingency measures when RFP is not met , an RFP is met

, then the requirement for contingency measures is met. Finally, Chapter 5 establishes the Transportation Conformity Bud gets for PM 2.5 and NOx.

Chapter Six

– Border Strategic Concepts

This Chapter provides evidence to the reader of ongoing efforts at the federal, state and local level to implement different programs to achieve mutual international goals

oriented at educat ion and protection of the public health and welfare. Generally the chapter provides the reader a complete overview of the programs associated with improving air quality in both Mexicali and Imperial County. This chapter introduces and describes the organi zations and programs currently implemented for the benefit of both the Imperial and Mexicali valleys, such as: the web

- based air quality and health information center, the school flag alert program, the Mexicali and Imperial education media campaign and th e vehicle idling emissions study at the Calexico East and Calexico West ports of entry.

Chapter Seven

– Conclusion and SIP Checklist

Chapter 7 provides the reader a checklist with a general description of the Clean Air Act requirement for Moderate Nonat tainment Areas. The chapter provides a description and/or location to the reader where that identified requirement is found within the 2013

PM 2.5 SIP.

III California Environmental Quality Act (CEQA)

The Final Draft Imperial County 2013 PM 2.5 SIP (Plan) is a “project” as defined by the CEQA. Since the Plan imposes the greatest discretionary authority of approval upon

IV Staff Report for the 2013 PM 2.5 SIP150 SOUTH NINTH STREET TELEPHONE: (760) 482

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the ICAPCD it is therefore the lead agency for this project. As part of the review process the ICAPCD examined the Plan for applicability to C EQA. Because the Plan does not proposed or imposed any new regulation and in fact demonstrates attainment of the Standard “but for” emissions from an international source a class “8” categorical exemption applies. However, in order to provide for optimum public participation and involvement the ICAPCD opted not to utilize the exemption and instead provide an additional resource for the identification of any potential environmental impacts associated with the Plan. Thus, in order to fulfill the purpose an d intent of CEQA the ICAPCD prepared an Initial Study to help identify and address any potential environmental impacts associated with the Plan.

In accord with the Imperial County Planning and Development protocols for CEQA the

Environmental Evaluation Co mmittee (EEC) met October 23, 2014 at 1:30pm to discuss and review the prepared Initial Study. After discussion, review and input from the public the EEC made a “mandatory finding” of “No Impact” to the degradation to the quality of

the environment. The EEC “[f]ound that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION ...” was proposed based on the evidence on record. The final “finding” was signed by the

Assistant Air Pollution Control Officer R eyes Romero on October 23, 2014 indicating that the ICAPCD would prepare a Negative Declaration.

The Public Notice of a proposed Negative Declaration was released for a 30 day comment period by the ICAPCD October 23, 2014. The transmittal list included 86

pos tal mailing as well as e

- mails to local, federal, state, libraries, cities, school districts, special districts and others. In addition

, the ICA PCD posted the Public Notice on the home page for the ICAPD, outside the main Administration building and outsi de the ICAPCD building. Comments are due by close of business November 25, 2014.

IV Final Draft Imperial County 2013 PM 2.5 SIP (Plan) Development

The Plan development extended over a period of five years with a cooperative tri

agency effo rt including the C ARB, U.S. EPA and the ICAPCD to address the intricate technical aspect s of the Plan

. In order to engage additional perspectives and to gain insight into public opinion the ICAPCD introduced a draft version of the Plan October 1,

2014. Two workshops were held to afford the greatest amount of participation, a n afternoon workshop in El Centro and an evening workshop in Calexico. CARB was present at both workshops to help explain the technical aspects of the Plan. Translation services, both in English and S panish

, were available for both workshops

. T he public notice inviting the community to participate was released in Spanish and English September 26 , 2014. Two comments were received that were general and broad in

nature. One comment was a statement that the commenter observed burning in Imperial County. The second comment asked about the servicing, operation and function of a monitor, no specific monitor was mentioned. Both comments were duly noted and discussed during the workshop in detail. The r esp onse by CARB and ICAPCD during the workshop was detailed and informative

.

V Staff Report for the 2013 PM 2.5 SIP150 SOUTH NINTH STREET TELEPHONE: (760) 482

- 4606 EL CENTRO, CA 92243

- 2850 FA X: (760) 353

- 9904 AIR POLLUTION CONTROL DISTRICT

The Public Hearing notice was released and published in the Imperial Valley Press legal section on October 24, 3014 and November 2, 2014. All interested parties were notified

of the Public Hearing notice via e

- mail and provided a link to the Plan on October 24,

2014.

V Recommendations

IC APCD ADVISORY BOARD

The ICAPCD Advisory Board met to discuss and review the Imperial County Draft Imperial County 2013 State Implementation Plan for the 2006 24

- Hour PM 2.5 Moderate Nonattainment Area on November 10, 2014. The ICAPCD Advisory Board recommended the approval of the Draft Imperial County 2013 State Implementation

Plan for the 2006 24

- Hour PM 2.5 Moderate Nonattainment Area, the staff r eport and it’s findings.

ICAPCD STAFF

ICAPCD staff recommends adoption of the attached Draft Imperial County 2013 State Implementation Plan for the 2006 24

- Hour PM 2.5 Moderate Nonattainment Area and associated findings. Concurrently, the ICAPCD recommen ds the certification and adoption of the Negative Declaration for the Draft Imperial County 2013 State Implementation Plan for the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area.

After addressing the technical and non

- technical issues raised by the U.S. E PA, the Draft Imperial County 2013 State Implementation Plan for the 2006 24

- Hour PM 2.5 Moderate Nonattainment Area effectively demonstrates that Imperial County timely met

attainment of the PM 2.5 standard “but for” emissions from Mexicali Mexico.

VI Declara tion of Findings

The Imperial County Air Pollution Control District Board hereby finds as follows:

The ICAPCD is a regulatory agency and the public agency with the principle responsibility for carrying out the project.

Clean air is a valuable and essent ial natural resource.

U.S. EPA partially designated Imperial County as a nonattainment area for the PM 2.5 24

- hr standard, effective December 14, 20 09

.

The partial PM 2.5 nonattainment area includes the majority of the populated area in Imperial County.

VI Staff Report for the 2013 PM 2.5 SIP150 SOUTH NINTH STREET TELEPHONE: (760) 482

- 4606 EL CENTRO, CA 92243

- 2850 FA X: (760) 353

- 9904 AIR POLLUTION CONTROL DISTRICT

A s a result of a ruling by the United States Court of Appeals for the District of Columbia

circuit Imperial County was classified by “operation of law” as a “moderate” non

attainment area as required by subpart 4 provisions on June 2, 2014 by U.S. EPA

.

The Draft Imperial County 2013 State Implementation Plan for the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area meets the requirements of the federal C lean A ir A ct (CAA) for areas classified as “ moderate ” non attainment for PM 2.5

. In accordance with

section 1 79B of the CAA, this Draft Imperial County 2013 State Implementation Plan for

the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area satisfies the attainment demonstration requirement satisfying the provisions of subpart 1 and subpart4 of the

CAA.

Failure to adopt the Draft Imperial County 2013 State Implementation Plan for the 2006

24

- Hour P M 2.5 Moderate Nonattainment Area would guarantee that the Imperial County

would not meet federal PM 2.5 standards as required by the CAA.

The Draft Imperial County 2013 S tate Implementation Plan for the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area demonstrates attainment as required by the CAA with a long

- term effect resulting in the reduction /maintenance in emissions from stationary and

mobile sources.

The Draft Imperi al County 2013 State Implementation Plan for the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area incorporates an updated emissions inventor y, the CAA

section 179 B analysis, an analysis of Reasonable Available Control Measures (RACM),

an assessment of Reason able Further Progress (RFP) and a discussion of contingency

measures

.

The Draft Imperial County 2013 State Implementation Plan for the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area satisfies the planning requirements set forth in the

federal CAA includin g establishing a transportation conformity budget based on the latest planning assumptions.

The continued implementation of the Draft Imperial County 2013 State Implementation

Plan for the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area existing control

me asures would provide for continued attainment of the PM 2.5 N ational A mbient A ir
Q uality S tandard (NAAQS)

.

The Draft Imperial County 2013 State Implementation Plan for the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area demonstrates that air quality monitor ed data for 20 10

thru 20 12 demonstrates that Imperial County would have been in attainment of the 24

- hour PM 2.5 NAAQS “but

- for” international emissions emanating from Mexico.

The Draft Imperial County 2013 State Implementation Plan for the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area is considered a “project” pursuant to the CEQA and that

VII Staff Report for the 2013 PM 2.5 SIP150 SOUTH NINTH STREET TELEPHONE: (760) 482

- 4606 EL CENTRO, CA 92243

- 2850 FA X: (760) 353

- 9904 AIR POLLUTION CONTROL DISTRICT

an Initial Study was prepared and presented to the EEC on October 23 , 20 14 with a finding of “No Impact”

Imperial County prepared and subsequently released for a 30 da y public comment period a Negative Declaration upo n the recommendation of the EEC.

That Certif ication and approv al is necessary of the Negative Declaration for the Draft Imperial County 2013 State Implementation Plan for the 2006 24

- Hour P M 2.5 Moderate

No nattainment Area because there has been no evidence presented to suggest that the Draft Imperial County 2013 State Implementation Plan for the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area will lead to or result in significant adverse impacts to the

envir onment

.

The Draft Imperial County 2013 State Implementation Plan for the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area is technically sound and capable of being understood by those persons directly affected by it.

The Draft Imperial County 2013 State Im plementation Plan for the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area does not conflict with or contradict any existing statute, court decision, state or federal regulation.

The Draft Imperial County 2013 State Implementation Plan for the 2006 24

- Hour P M 2.5 Moderate Nonattainment Area is not duplicative of any existing state or federal regulation or plan.

The ICAPCD has a population of less than 500,000 people.

VIII Staff Report for the 2013 PM 2.5 SIP