Attachment 4

Public Comments and Response s to the 2013 Revision to the Sacramento Regional 8

- Hour Ozone Attainment and Reasonable Further Progress Plan (Plan) and Appendices

September 26 , 2013Public Comments and Responses to The

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Public Comments and Responses PUBLIC COMMENTS AND RESPONSES

Comment Letter from Greg Rowe, Sacramento County Airport Systems dated 05/09/2013Public Comments and Responses to The

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Public Comments and ResponsesPublic Comments and Responses to The

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Public Comments and ResponsesPublic Comments and Responses to The

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Public Comments and ResponsesPublic Comments and Responses to The

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Public Comments and Responses Comment Sacramento County Airport Systems (SCAS) is concern ed that the

proposed Ground Support Equipment (GSE) emissions inventory may not

accurate ly count the number and type of GSE operating at the
Sacramento International Airport (SMF) currently or in 2014, 2017, and

2018.

Response GSE em issions are determined through the combination s of CARB’s

OFFROAD and categorical specific models. They are calculated for the
state and allocated to each county based on the commercial aircraft

activities.

Emission inventor ies undergo improvement continuously. As better data

a nd methodolog ies become available, the inventory will be updated.
Responses 2

- 9 provide detailed explanation regarding SCAS ’s concerns

that the proposed Ground Support Equipment (GSE) emissions inventory
may not accurately count the number and type of GSE operating at SMF.Public Comments and Responses to The

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Public Comments and Responses Comment Letter from Carl Mosher, Sacramento County Airport Systems dated 05/16/2013Public Comments and Responses to The

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Public Comments and ResponsesPublic Comments and Responses to The

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Public Comments and ResponsesPublic Comments and Responses to The

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Public Comments and Responses Response to Comment Letter from Carl Mosher

, Sacramento County Airport SystemPublic Comments and Responses to The

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Public Comments and ResponsesPublic Comments and Responses to The

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Public Comments and Responses Comment Letter from Brian Roth, B

- 52 Construction Inc. dated 05/20/2013

Comment The co mmenter disagree s with the regulations that require a

truck/equipment owner to retrofit heavy duty truck / equipment with
expensive particulate filter or as alternative, get rid of the old
truck/equipment

. He concerns that t he regulation does not seem fair,
reasonable, or remotely supportive for small business. He also
commented that offering grant money does not solve the issue because it
costs tax payers’ money.

Response The California Air Resource Board (CARB) is responsible for

implementing the In

- Use, Off

- Road Equipment and the In

- Use, On

- Road
Truck and Bus regulations, which they adopted in 2007 and 2008,
respectively. The Plan, developed by the Sacramento region’s local air
districts, has no impact on CARB’s already adop ted regulations.Public Comments and Responses to The

2013 Revisions to the Sacramento Regional 8

- Hour Ozone Attainment and Reasonable Further Progress Plan Page 25 September 26 , 2013

Public Comments and Responses Local air districts have no regulatory authority over motor vehicles,
including heavy trucks and other mobile equipment. This plan amendment
does not add or change any regulations pertaining to motor vehicles,
including heavy trucks and other mobile equipment , but simply
incorporates the emission benefits from previously approved regulations.

The Air Resources Board has a long history of adopting engine emission
standards for new vehicles to improve California’s air quality. These

standar ds, combined with smog check and vehicle retirement incentive
programs, have helped to significantly reduce emissions from passenger
vehicles even as the State’s population and overall vehicle use have

increased. These reductions are a critical factor in m eeting California’s air
quality goals.

However, the diesel vehicle fleet does not turn over as rapidly as the
passenger vehicle fleet. Diesel trucks and off

- road equipment have long
service lives, and typically remain in use for many years

- if not decades

. This long life means that newer, lower

- emitting engines would be
introduced into fleets slowly, and that the resulting emission reductions

and associated health benefits would also be slow to materialize. The in

use fleet rules encourage faster fleet tur n

- over and the use of updated

emission controls on older vehicles that remain in the fleet. The
Sacramento Metropolitan region cannot meet the federal ozone standard
by the 2018 deadline without the reductions from ARB’s 2007 In

- Use, Off

Road Equipment Reg ulation, and its 2008 In

- Use, On

- Road Truck and
Bus Regulation.

In 2010 ARB approved a suite of amendments to the in

- use rules that
were designed to account for reduced activity resulting from the recession
and provide regulatory relief to truck and equipm ent owners. The off

- road
rule revisions delayed implementation requirements for all fleets by four
years, expanded early compliance credits, and simplified and extended
phase

- in requirements overall. The truck rule revisions eased
requirements for lighter trucks, delayed compliance deadlines for heavier
trucks, and expanded credits for fleet downsizing and early compliance.
The amendments reduce overall compliance costs while providing the

emission reductions needed to meet Clean Air Act deadlines.

While it is ideal to replace all older trucks for newer and cleaner trucks,
ARB recognizes that not all operators can afford to replace their vehicles.
Diesel exhaust filters have proven to be effective, reliable, and durable for
most engines and are typically the most cost effective way to reduce
harmful toxic soot emissions from existing trucks. To date, more than

50,000 exhaust filter retrofits have been sold and installed in California.Public Comments and Responses to The

2013 Revisions to the Sacramento Regional 8

- Hour Ozone Attainment and Reasonable Further Progress Plan Page 26 September 26 , 2013

Public Comments and Responses There are also a variety of funding programs beside grant money that are

av ailable throughout the State for the early clean

- up of trucks. The ARB's
Providing Loan Assistance for California Equipment program, also known
as PLACE, is an innovative loan guarantee program to offer financial
opportunities to on

- road heavy

- duty fleet o wners. More information
regarding the regulation and ARB’s incentive programs can be found at
ARB’s Truck Stop website at
http://www.arb.ca.gov/msprog/truckstop/truckstop.htm

.

The local air districts in the Sacramento region also have grant and
incentive programs to help fleets pay for new lower emission engines,
lower emission retrofits, and new equipment replacements. These
programs include Engine Repower and Engine Retrofit for Off

- and On

Road equipment

, and On

- Road Truck Replacement

. More information
about Sacramento AQMD’s Heavy

- Duty Low

- Emission Vehicle Program

can be found at http://www.airquality.org/mobile/inde x.shtml

.