Attachment 4

Public Comments and Responses to the 2013 Revision to the Sacramento Regional 8-

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

September 26, 2013

Public Comments and Responses to The

2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

Page 1 September 26, 2013

Public Comments and Responses

PUBLIC COMMENTS AND RESPONSES

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

2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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Public Comments and Responses to The

2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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Public Comments and Responses to The

2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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Public Comments and Responses to The

2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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Public Comments and Responses to The

2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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Public Comments and Responses

Comment Sacramento County Airport Systems (SCAS) is concerned that the 

proposed Ground Support Equipment (GSE) emissions inventory may not 

accurately count the number and type of GSE operating at the 

Sacramento International Airport (SMF) currently or in 2014, 2017, and 

2018.

Response GSE emissions are determined through the combinations 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 inventories undergo improvement continuously. As better data 

and methodologies 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

2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

Page 8 September 26, 2013

Public Comments and Responses

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

2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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Public Comments and Responses to The

2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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Public Comments and Responses to The

2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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Response to Comment Letter from Carl Mosher, Sacramento County Airport System
Public Comments and Responses to The

2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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and Reasonable Further Progress Plan

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and Reasonable Further Progress Plan

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2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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2013 Revisions to the Sacramento Regional 8-Hour Ozone Attainment

and Reasonable Further Progress Plan

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Comment Letter from Brian Roth, B-52 Construction Inc. dated 05/20/2013

Comment The commenter disagrees 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 the 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 adopted 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 

standards, 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 meeting 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 inuse fleet rules encourage faster fleet turn-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, OffRoad Equipment Regulation, 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 equipment 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 

available 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 owners. 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 OnRoad 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/index.shtml.