1 Pio Pico Energy Center Proposed PSD Permit No. SD 11

- 01 Environmental Justice Analysis

June 2012

Introduction

Executive Order 12898

, entitled “Federal Actions To Address Environmental Justice in Minority Populations and Low

- Income Populations

, ” states in relevant part that “each Federal agency shall make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low

- income populations.” Section 1

- 101 of Exec. Order 12898, 59 Fed. Reg. 7629, (Feb. 16, 1994 )

. “Federal agencies are required to implement this order consistent with, and to the extent permitted by, existing law.” Id. at 7632. Based on this Executive Order, the EPA’s Environmental Appeals Board (EAB) has held that environmental justice issues must be

considered in connection with the issuance of federal Clean Air Act (CAA) Prevention of Significant Deterioration (PSD) permits is sued by EPA Regional Offices and states acting under delegations of Federal authority. See, e.g., In re Prairie State Generating Company , 13 E.A.D. 1, 123 (EAB 2006); In re Knauf Fiber Glass, GmbH , 8 E.A.D. 121, 174

- 75 (EAB 1999) (“Knauf I”). EPA Regiona l Offices or their delegates in the states have for several years incorporated environmental justice considerations into their review of applications for PSD permits. The EAB reinforced the importance of completing an environmental justice analysis in a r ecent opinion

discussed further below. See In re: Shell Gulf of Mexico, Inc. and Shell Offshore, Inc. , OCS Appeal Nos. 10

- 1 to 10

- 4, Slip Op. at 63

- 4 (EAB December 30, 2010) (“ Shell II ”).

EPA determined that there may be minority or low

- income populatio ns potentially affected by its proposed action on the Pio Pico Energy Center ( PPEC or Project) PSD permit application, and determined that it would be appropriate to prepare an Environmental Justice Analysis for this action. EPA therefore prepared this En vironmental Justice Analysis.

For purposes of the Executive Order on environmental justice, EPA has recognized that compliance with the applicable National Ambient Air Quality Standards ( NAAQS ) is emblematic of achieving a level of public health protecti on that demonstrates that EPA’s issuance of a PSD permit for a proposed facility will not have disproportionately high and adverse human health or environmental effects on minority populations and low

- income populations. See, e.g., Shell II.

, slip op. at 74; In re Shell Offshore Inc. , 13 E.A.D. 357, 404

- 5 (EAB 2007) (“ Shell I

”); In re Knauf Fiber Glass, GmbH , 9 E.A.D 1, 15

- 17 (EAB 2000) (“ Knauf

II ”); In re AES Puerto Rico , L.P., 8 E.A.D. 324, 351 (EAB 1999). This is because the NAAQS

are health

- based standards, designed to protect public health with an adequate margin of safety, including sensitive populations such as children, the elderly, and asthmatics. As the EAB recently observed, “[i]n the context of an environmental justice analysis, compliance with the NAAQS is emblematic of achieving a level of public health protection that, based on the level of protection afforded by the NAAQS, demonstrates that minority or low

- income populations will not experience disproportionately high and adverse human health or environmental effects due to exposure to relevant criteria pollutants.” Shell II , Slip Op. at 73.2

The studies assessed by EPA in setting NAAQS and the integration of the scientific evidence presented therein have undergone extensive critical re view by EPA, the Clean Air Scientific Advisory Committee (CASAC), and the public. See e.g., Primary National Ambient Air Quality Standards for Nitrogen Dioxide, Final Rule, 75 Fed. Reg. 6474, 6478 Feb. 9, 2010. “The rigor of the review makes these studies , and their integrative assessment, the most reliable source of scientific information on which to base decisions on the NAAQS.” Id. When setting the NAAQS, “[t]he Administrator’s final decisions draw upon scientific information and analysis

related to he alth effects, population exposures, and risks; judgments about the appropriate response to the range of uncertainties that are inherent in scientific evidence and analyses; and comment received from CASAC and the public.” Id. at 6483. In light of these c haracteristics of the process for setting the standards, the EAB generally “relies on and defers to the Agency’s cumulative expertise when upholding a permit issuer’s environmental justice analysis based on a proposed facility’s compliance with the relevan t NAAQS in a PSD appeal.” Shell II , Slip Op. at 74. The NAAQS are also the underpinning for the State Implementation Plan process, which requires states to adopt rules and programs that will reduce emissions causing air pollution.

Pursuant to Clean Air Act section 165(a)(3), construction of a major emitting facility may not commence until the owner or operator of such facility demonstrates, among other things, that the facility will not cause or contribute to air pollution in excess of any NAAQS applicab le to the

PSD permit decision. 42 U.S.C. § 7475(a)(3); see also 40 C.F.R. §§ 52.21(k), 52.21(i)(2). With respect to the proposed PSD permit for the PPEC, EPA would regulate emissions affecting the following NAAQS: nitrogen dioxide ( NO 2 ) (1

- hr and annual average ), particulate matter 2.5 μm

in diameter and smaller ( PM 2.5 ) ( 24

- hr and annual ), and particulate matter 10 micrometers (μm)

in diameter and smaller ( PM 10 ) ( 24

- hr)

. S everal pollutants do not trigger PSD review as the Project’s potential emissions fall below the significant emissions rate for these pollutants, including lead (Pb)

, sulfur dioxide ( SO 2 ), and carbon monoxide ( CO ) 1

. EPA has determined that the proposed facility’s projected emissions will not cause or contribute to a violation of the applicable NAAQS. EPA has determined that compliance with the applicable NAAQS is sufficient to satisfy the Executive Order as to th e pollutants regulated under the PSD program

.

Project Description and Regulatory Fra mework

Pio Pico Energy Center, LLC has applied to EPA Region 9 for authorization under the

CAA PSD permitting program to construct a new power plant that will generate 300 megawatts (MW) of electricity using natural gas. The plant will be located in San Diego County, California, within the San Diego Air Pollution Control District ( SDAPCD or District). The District is located within the San Diego air basin. The District’s jurisdiction begins in the south

at the U.S./Mex ico border and extends north to the Orange County line, east to the Riverside County line, a nd west to the Pacific Ocean

.

Under the CAA, new sources of pollutants for an area that has been designated attainment or unclassifiable are regulated under the PSD program. In addition, certain other

1 The Project is not expected to emit lead . T he Project’s potential SO 2 emissions are estimated to be 4.1 tons per year (tpy), which is well below the 40 tpy significant emissions rate for SO 2 , and the Project’s potential CO emissions are estimated to be 96.4 tpy, below the 100 tpy significant emission s rate for CO. See 40 C.F.R. §§ 52.21(b)(23)(i); 52.21(j)(2); 52.21(m)(1).3

pollutants for which no NAAQS have been set are subject to regulation with a defined applicability threshold under the PSD regulations. Within the District’s boundaries, the pollutants regulated under the PSD program and for which the proposed Project is either a major source or has the potential to emit in significant amounts include NO 2 , total particulate matter ( PM ) , PM 10 , PM 2.5 , and greenhouse gases (GHG) . These pollutants are addressed by the PSD permit for the Project. The emissions of other air pollutants from the proposed Project, including the pollutants for which the area is n ot meeting the NAAQS (and precursors that lead to the formation of such pollutants), are regulated by the District. The District implements the Nonattainment New Source Review (NNSR) permitting program for this area as required under

the Clean Air Act and 40 CFR 51.160 to 51.165. The District is currently designated as an

unclassified ozone non

- attainment area under the 1997 0.080 parts per million (ppm) 8

- Hour

O zone NAAQS S tandard

. 2 The non

- attainment pollutants subject to non

- attainment NSR permitting by the District include nitrogen oxides ( NOx ) and volatile organic carbons ( VOC ) as ozone precursors. However, PPEC will not be a major source of any nonattainment pollutant, and therefore requirements of nonattainment NSR, including Lowest Achievable Emission Rate (LAER) and emission offsets, do not apply to the Project. 3 Instead, the minor NSR permit issued by SDAPCD addresses both attainmen t and nonattainment pollutants , and o n May 4

, 201 2 , the District issued a Final Determination of Compliance ( F DOC) for the Project to address applicable NSR SIP requirements as well as other local permitting requirements. Also, the California Energy Commi ssion (CEC) must issue a license to authorize construction of proposed power plant s over 50 MW in size

. The District and CEC approval proce sses are separate from

EPA’s PSD permitting process.

The proposed Project will be comprised of three General Electric (GE) LMS100 natural

gas

- fired combustion turbine

- generators (CTGs) with a total net generating capacity of approximately 100 megawatts each (MW, gross ). The Project will be supplying peaking energy to San Diego Gas and Electric (SDG&E) u nder a 20

- year purchase agreement. The GE LMS100 natural gas

- fired turbines were developed specifically for producing peak demand electrical

needs

, allowing the facility to meet and respond to variable demands. To meet Best Available Control Technology ( BACT) requirements under the PSD permitting program, add

- on pollution control technologies for the Project will include a selective catalytic reduction (SCR) system and water injection to reduce NOx emissions. T he Project will also include an oxidation ca talyst to
reduce CO emissions ; however, the oxidation catalyst is not required to meet BACT requirements under the PSD permit for the PPEC because CO is not regulated under th is PSD permit as explained above

.

2 To date, the SDCAPCD has not been classified under the 1997 8

- Hour Ozone NAAQS Standard, but during 2012,

EPA intends to make a formal determination the area has attained the 1 997 NAAQS. However, EPA recently designated San Diego as nonattainment for the newer and more stringent 2008 0.075 ppm NAAQS for ozone. Requirements related to the 2008 NAAQS are pending.

3 New source review in non

- attainment areas is different from PSD review. Because a non

- attainment area already has air quality that does not meet national health standards, and yet to preserve the ability for economic development

to occur in those areas wi thout exacerbating air quality and public health concerns, the CAA requires that sources seeking to build or expand in a non

- attainment area must meet LAER and offset their anticipated new emissions by eliminating emissions of an equal, or depending on the severity of the non

- attainment, greater amount. LAER requires a level of emissions reduction, through the use of control technology or other approaches, that is as or more stringent than BACT, which is required in attainment/unclassifiable areas.4

The facility is expected to have emissi ons of pollutants regulated under the PSD program as shown in the following table

. 4

Table 1: Estimated Emissions and PSD Applicability

Pollutant Estimated Annual

Emissions (tons/year) Major Source

Threshold (tons/year) Significant

Emission Rate (tons/year) Does PSD

apply?

CO 96.4 250 100 No

NO 2 70.4 250 40 Yes

PM 37.2 250 25 Yes

PM 10 37.2 250 15 Yes

PM 2.5 37.2 250 10 Yes

SO 2 4.1 250 40 No

Pb 0 250 0.6 No

H 2 SO 4 3.4 250 7 No

GHG ( in

mass tons ) 623,299 250 0 Yes

As mentioned above, BACT is required under the PSD permitting program. EPA’s proposed permit for the Project includes, among other requirements, the use of BACT to limit emissions of

NO X , PM, PM 10 , PM 2.5 , and greenhouse gases, to the greatest extent feasi ble.

Demographics, Public Participation/Outreach Activities

, and Air Quality in the Otay Mesa

Area

Description of Local Area

The proposed P roject would be located in San Diego County in an unincorporated area known as Otay Mesa

. The proposed site is comprised of a 9.99 acre parcel of previously

disturbed land located at 7363 Calzada de la Fuente , Otay Mesa, CA 92154 in the existing Otay

Mesa Business Park. The site is already served by paved roads and other public utilities and i s zoned for heavy and mixed industrial use , technology busines s park, and conservation uses

, with heavy industrial being the major use. Existing site and land uses in the vicinity of the proposed Project include the Otay Mesa Generating Project (a natural gas

- fired power plant) and two correctional facilities ( the Richard J. Donovan Correctional Facility and the George F. Bailey

4 Whil e there is a NAAQS for lead, th is facility is not expected to emit lead.5

County Correctional Facility). The area is located approximately 21 miles (~33.8 km) 5 southeast of downtown San Diego and approximately 1.5 miles (~2.4 km) north of the U.S./Mexico

border.

The Project site is located within an industrial business complex, with t he residential area

nearest to the P roject located approximately seven mile s (11.3 km) west in Ocean Crest, a

res idential neighborhood in the southern section of San Diego

. Based on available information,

there are a few residences within a five m ile (8.0 km) radius of the proposed facility , with the closest being approximately 1.6 miles (2.6 km) away

. Other p opula tion centers located within San Diego County in the vicinity of the P roject site include the City of Imperial Beach (13

miles /21.0 km west ) with a population of 23,324

, the City of Chula Vista (15 miles/24.1 km

north west ) with a population of 243,916

, National City (17 miles/27.4 km northwest) with a population of 58,582

, and the City of San Diego (25 miles /40.2 km northwest ) with a population of 1,307,402, as of the 2010 census

.

There are multiple Indian tribes located within the vicinity of the pro posed Project

. The Jamul Indian Village of California is located within a 15 km radius to the northeast of the Project

site

. The Sycuan Band of the Kumeyaay Nation is located within a 25 km radius to the northeast of the Project. Tribal lands located wi thin a 50 km radius include the Campo Band of the Kumeyaay Nation

, the Viejas Band of the Kumeyaay Indians

, the Cap itan Grande Reservation

, and the Barona Band of Mission Indians

. Neighboring t ribal lands located outside the 50 km

radius include lands of the La Posta Band of Mission Indians

, the Cuyapaipe Reservation , the Inaja and Cosmit Reservation, the Mesa Grande Band of Diegueno Mission Indians , and the

Santa Ysabel Reservation

.

Demographic Information

EPA's screening for potential environm ental justice concerns focused on an area encompassed by a 25 km radius from the proposed facility. We chose this area to consider because our modeling analysis indicates that a 25 km radius includes the primary populations that may be impacted by emissio ns from the Project. However, because this large an area is much greater than typically considered for community level impacts, EPA also includes demographic information for areas closer to the proposed facility. Our analysis indicated that

there are no residents living within a 2 km radius of the proposed Project. We included demographic information for areas of 5 and 15 km radii for comparison. These areas are all encompassed within the County of San Diego. Thus, to compare health information, EPA wil l present metrics for both San Diego County and the State of California as a whole.

Demographic information is captured within four radii surrounding the proposed Pio Pico Energy Center at 50, 25, 15, and 5 km 6

.

5 All distances are approximate.

6 U

. S . Census Bureau, 2000 and 2010 Data; ESRI, 2012; TANA, 2006; Google, 2012.6 Table 2: Demographic Information for Proposed Project Location and Surrounding Areas

City/Area Population

(2010 Census) Percent

Minority (2010 Census) Percent

Under Age 18 (2010 Census) Percent

Over Age 64 (2010 Census) Percent

Linguistically

Isolated (2000 Census) 7 Percent

w/o High

School Diploma (2000 Census) Average

Median

Household Income, $ ( 2000

Census )
5 km 9,568* 78.34 21.62 3.37 11.69 17.98 $69,779

15 km 276,728* 81.60 27.80 9.70 11.20 25.30 $52,762

25 km 660,853* 70.60 26.20 10.60 9.30 25.70 $41,305

50 km 1,183,062* 40.80 19.80 19.80 5.80 12.60 $52,268 Imperial

Beach 23,324 64.00 25.40 9.00 5.68 23.08 $35,927

Chula

Vista 243,916 79.60 27.9 0 10.00 9.27 21.49 $47,829

National City 58,582 88.30 25.50 10.60 21.13 42.98 $30,389

City of San Diego 1,307,402 54.90 21.40 10.7 8.13 17.22 $50,649

San Diego County 3, 095,313 51.54 23.40 11.40 6.75 17.42 $51,621

State of

CA 37,253,956 59.85 24.95 11.40 9.62 23.21 $52,719

* Population derived assuming uniform population distribution.

The three radii closest to the proposed facility (5, 15, and 25 km) capture populations above the state average for percent minority , while the population’s minority percentage decreases as distance from the Project increases (50 km from the proposed facility). The 5, 15 and 50 km radii surrounding the proposed facility capture populations similar to or above the state average for median household income

, while the median household income captured in the 25 km radius is more than $10,000 below the state average.

Linguistic isolation limits a household’s capacity for civic engagement in the regulatory

process. 8 The two radii closest to the proposed facility capture households that are similar or slightly higher than the state average for linguistic isolation . Linguistic isolation d ecreases slightly with distance from the project ( 25 and 50 km). The percent of linguistically isolated

households in the State of California is 9.6 2 %

, a s compared with the percent of households

located with in 25 km of the Project , which is 9.30 %.

Education level is another factor that may influence susceptibility and vulnerability to air pollution. Limited formal education is a barrier to employment, health care and social resources,

7 2010 U.S. Census data was not available for these metrics at the t ime of this analysis.

8 A linguistically isolated household is defined by the U

. S

. Census Bureau as a household in which no member 14 years old and over (1) speaks only English or (2) speaks a non

- English language and speaks English "very well." In

other words, all members 14 years old and over have at least some difficulty with English.7

and can increase the risk of poverty, stress, and impacts from environmental stressors. The percent of the population over 25 years of age without a high school diploma with in a 25 km

radius of the Project (25.70%) is slightly higher than the state averag e of 23 .21 %. The percent of the population without a high school diploma decreases with respect to the population closest to the facility (17.98%)

.

Public Participation/Outreach Activities for EPA’s Proposed PSD Permit Decision

EPA is undertaking a numb er of actions to provide public participation opportunities to the community for its proposed PSD permit decision for the PPEC

.

In light of the Spanish

- speaking population in the nearby community, EPA is issuing its public notice for the proposed PSD pe rmit for the Project in both English and Spanish. The notice is being provided to the public through a wide variety of methods, including the following: posting on the EPA Region 9 website, publication in English in the San Diego Union Tribune, followed b y an additional publication in Spanish in La Prensa San Diego ; distribution to

a mailing list of those who have requested to be notified by U.S. Mail of any actions related to the Project ; and distribution by email to those who have requested to be notifie d by email

.

EPA’s pr oposed PSD permit for the Project

, the accompanying fact sheet/ambient air quality impact report ( Fact Sheet ), and the Public Notice, will be available for review at the following locations: San Diego County Air Pollution Control District in San Diego , CA; San

Ysidro Library in San Diego , CA; Otay Mesa

- Nestor Library in San Diego , CA; Chula Vista Public Library, Civic Center Branch in Chula Vista , CA; National City Public Library in National City , CA ; and San Diego Central Library in San Diego, CA

. Key documents in EPA’s administrative record for the proposed PSD permit, including, among others, the permit application, the proposed PSD permit, and EPA’s F act S heet, are also available for public review on the EPA Region 9 website as well as at the EPA Region 9 Office in San Francisco , CA

.

EPA has scheduled a public hearing for July 24, 2012 at the San Ysidro High School in San Ysidro, CA

. The purpose of the public hearing is to provide the public with an additional opportunity to provide oral and/or written comment s on EPA’s proposed PSD permit for the Project . EPA will be providing English

- Spanish translation services at the public hearing. EPA

has also prepared a public information sheet for distribution at the hearing that pro vides a brief overview of EPA’s proposed PSD permitting action for the Project

. Th is handout ha s also been translated into Spanish and is available on the EPA Region 9 permit website: http://www.epa.gov/region9/air/permit/r9

- permits

- issued.html#part71

.

Status of Air Quality in the Area

The District is designated as attainment or unclassifiable for PM 10 , PM 2.5 , NO 2 , CO, SO 2 , and lead. The District is also designated a n unclassified ozone non

- attainment area. As

discussed above, the Project is not a major source of ozone or its precursors and does not trigger

non

- attainment New Source Review. T he District’s F DOC , however, does addresses non

attainment pollutants, i.e.

, ozone precursors associated with the Project

.8

Impact of Project’s Emissions on the NAAQS Applicable to the PSD Permit

EPA’s environmental justice analysis focuses on the potential effects on minority or low income populations from emissions that may affect the NAAQS that are applicable in the PSD review for the Project. Those are emissions potentially affecting the NAAQS for NO 2 (1

- hr and

annual ), PM 2.5 ( 24

- hr and an nual ), and PM 10 ( 24

- hr). As noted earlier, the potential emissions

from the Project are below the significan t emission rates for CO (1

- hr and 8

- hr average), SO 2 , and lead ; thus , the Project is not subject to PSD review for those NAAQS

.

EPA has determined from the modeled results for the Project that impacts are below the applicable NAAQS for the PSD pollutants regulated under the PSD permit, as follows: The

modeled annual NO 2 impact is 0. 3 μg/m 3 , which is below the Significant Impact Level (SIL) 9 of 1 μg/m 3 and therefore did not trigger a cumulative NAAQS analysis

. T he cumulative 1

- h ou r NO 2 impact is 179 μg/m 3 , as compared with the NAAQS of 188 μg/m 3 . The modeled 24

- hour

PM 10 impact is 2.6 μg/m 3 , which is below the SIL of 5 μg/m 3 , an d therefore did not trigger a cumulative NAAQS analysis. The cumulative 24

- hour PM 2.5 impact is 27.7 μg/m 3

, as compared with the NAAQS of 35 μg/m 3

. The modeled annual PM 2.5 impact is 0.26 μg/m 3 , which is below the SIL of 0.3 μg/m 3

, and therefore did not trigger a cumulative NAAQS analysis. However, an

annual PM 2.5 analysis was done; the predicted annual impact is 14.4 μg/m 3 compared with the NAAQS of 15 μg/m 3

. As stated above, the NAAQS are health

- based standards and are designed to protect public health with an adequate margin of safety, including sensitive populations. Taking into account these modeled results in light of the health

- based nature of the applicable NAAQS, EPA has determined that the proposed emissions for these po llutants from the PPEC will not result in disproportionately high and adverse human health or environmental effects on minority populations and low

- income populations.

Table 3: PPEC Impacts as Compared with Significant Impact Levels

NAAQS pollutant &

av eraging time Project

- only

Modeled Impact ug/m 3 Significant Impact

Level (SIL) , μg/m 3 Project impact significant?

NO 2 , 1

- hr 111 (27) 7.5 (4 ppb) Yes

NO 2 , annual 0.3 1 No

PM 10 , 24

- hr 3 5 No

PM 2.5 , 24

- hr 2.6 1.2 Yes

PM 2.5 , annual 0.26 0.3 No

Sources : PSD Application Table 4

- 24, p.PSD 4

- 43pdf.152

9 Projects with project

- alone predicted impacts are required to do a cumulative impact analysis for comparison to NAAQS for that pollutant.9 Tabl e 4 : PPEC Compliance with the NAAQS

NAAQS pollutant & averaging

time All

Sources

Modeled Impact Background

Concentration Cumulative

impact w/ background NAAQS

(ug/m 3 )

NO 2 , 1

- hr 111 (hourly) 179 188 (100 ppb)

PM 2.5 , 24

- hr 0.7 27.0 27.7 35

PM 2.5 , annual 1.9 12.5 14.4 15

Sources:

NO 2 , PM 2.5 (NAAQS): PSD Application Table 4

- 25, p. PSD

- 4.45 pdf154

PM 2.5 (PSD increment): Letter from Sierra Research (S. Hill) to EPA (G. Rios) on modeling, December 2011

Pollutants for Which Area Exceeds Air Quality Standards

Although ozone is not regulated under EPA’s PSD permit for the Project, nor is the Project a major source of ozone precursors, we note as background that t he District is designated

a n ozone no n

- attainment area. S cientific studies have linked ground

- level ozone exposure to a variety of problems, including , for example, a irway irritation, coughing, and pain when taking a deep breath; wheezing and breathing difficulties during exercise or outdoor activities; inflammation, which is much like a sunburn on the skin; aggravation of asthma and increased susceptibility to respiratory illnesses like pneumonia and bronchitis; and p ermanent lung damage with repeated exposures.

With respect to ozone leve ls in San Diego C ounty, EPA, the State of California

, and the local air districts are working diligently through the air quality planning process under the CAA to ensure that there is a comprehensive plan with adequate controls for attaining and maintainin g the 1997 0. 0 80 ppm NAAQS for ozone. Based on the 2009

– 2011 monitoring data, the San Diego ozone nonattainment area is attain ing the 1997 NAAQS for ozone. During 2012, EPA intends to make a formal determination the area has attained the 1997 NAAQS. H owever, EPA recently designated San Diego as nonattainment for the newer and more stringent 2008 0.075 ppm NAAQS for ozone. Requirements related to the 2008 NAAQS are pending. Further, as noted above, the District’s F DOC includes provisions to address oz one precursors.

Conclusion

Our analysis indicates that this Project will not cause or contribute to air quality levels in excess of health standards for the pollutants regulated under EPA’s proposed PSD permit for the Project

, and that there will not be disproportionately high and adverse human health or environmental effects with respect to these air pollutants on minority or low

- income populations residing near the proposed P roject or the community as a whole. Nonattainment pollutants are addressed by the State and District Project approval and comprehensive air quality planning

processes. We also note that our outreach strategy will make information related to our proposed action more accessible to nearby communities, including linguistically isolated populations that are primarily Spanish speaking

.