BOARD MEETING DATE: March 4, 2011 AGENDA NO. 39

PROPOSAL: Adopt Revisions to PM2.5 and Ozone State Implementation Plan 

for South Coast Air Basin and Coachella Valley

SYNOPSIS: On November 22, 2010, U.S. EPA published its notice of proposed 

partial approval and partial disapproval of the 2007 Air Quality 

Management Plan (AQMP) PM2.5 Plan primarily because the 

attainment demonstration relies heavily on emissions reductions 

from several State rules that have not been finalized or submitted to 

U.S. EPA for approval. The proposed revision to the PM2.5 and 

ozone SIP addresses the critical issues of the proposed disapproval. 

It updates the implementation status of the AQMP control 

measures to meet the 2015 PM2.5 attainment and retains the 

AQMD’s proposal for contingency measures and also references 

and relies on CARB’s proposed contingency measures. In addition, 

the SIP revision will re-initiate its request that U.S. EPA 

voluntarily accept reduction responsibility for 10 TPD NOx 

emissions in 2014 but will propose that AQMD and CARB jointly 

provide a “fair share” backstop emissions reduction proposal, if 

necessary.

COMMITTEE: Not Applicable

RECOMMENDED ACTIONS:

1. Adopt the attached resolution: 

a. Certifying the Addendum to the 2007 AQMP Final Program Environmental 

Impact Report

b. Adopting the Revisions to the PM2.5 and Ozone SIP for the South Coast Air 

Basin and Coachella Valley

2. Direct staff to forward the revisions to the PM2.5 and Ozone SIP for the South Coast 

Air Basin and Coachella Valley to CARB for approval and submission to U.S. EPA 

as part of the 2007 SIP.

Barry R. Wallerstein, D.Env.

Executive Officer

EC:JCC
Background

On November 22, 2010 U.S, EPA issued a notice of proposed partial approval and 

partial disapproval of the 2007 South Coast SIP for the 1997 Fine Particulate Matter 

Standards and the corresponding 2007 State Strategy. U.S. EPA proposed to approve 

the plan’s inventory and regional modeling analyses; however it proposed to disapprove 

the attainment demonstration because it relies too extensively on commitments to 

emissions reductions in lieu of fully adopted, submitted, and SIP approved rules. The 

notice also cited deficiencies in the SIP’s contingency measures specifying the need for 

measures that are either fully adopted or otherwise ready for quick implementation and 

a trigger mechanism that achieves emissions reduction equivalent to one year of 

Reasonable Further Progress (RFP). In addition, U.S. EPA affirmed that it would not 

accept the Plan’s assignment of 10 tons per day (TPD) NOx emissions reductions to 

U.S. EPA as a contributing factor to its decision.

Proposal

AQMD is proposing to submit the attached revision to the PM2.5 and ozone SIP to 

update the implementation status of the AQMD control measures to meet the 2015 

PM2.5 attainment, revisions to the control measure adoption schedule and modifications 

to the emissions reduction commitment to reflect changes made to the inventory 

resulting from CARB’s December 2010 revisions to the on-road truck and off road 

equipment rules. The SIP revision retains the AQMD’s proposal for contingency 

measures and also references and relies on CARB’s proposed contingency measures 

that rely on reductions achieved through adopted rules that go beyond the RFP 

requirement. In addition, the SIP revision re-initiates its request that U.S. EPA 

voluntarily accept reduction responsibility for 10 TPD NOx emissions in 2014. Should 

U.S. EPA continue to not voluntarily accept reduction responsibility for federal sources 

in the 2007 SIP, AQMD and CARB will jointly provide a “fair share” backstop 

emissions reductions proposal. AQMD is committing to provide 1.0 TPD NOx 

emissions reductions in the event that the backstop proposal becomes necessary. 

AQMD has filed comments with U.S. EPA arguing that U.S. EPA’s insistence on a 

“10 percent” limit for reductions that rely on enforceable commitment, rather than fully 

approved rules, is improper. We do, however, expect CARB to propose a SIP revision 

at its April meeting to address U.S. EPA’s concerns.

Public Process

As required by federal law, a 30-day notice is required before holding a hearing to adopt 

revisions to PM2.5 and Ozone SIP for South Coast Air Basin and Coachella Valley. A 

Notice of Public Hearing providing the key elements of the proposed update to the SIP 

was released on January 26, 2011. 

CEQA and Socioeconomic Impacts

SCAQMD staff has evaluated the proposed revision to the PM2.5 and Ozone SIP and 

has concluded that only minor technical changes or additions to the 2007 AQMP Final 
Program Environmental Impact Report (PEIR) are necessary and none of the conditions 

in CEQA Guidelines §15162 apply. Therefore, an Addendum to the 2007 AQMP Final 

PEIR that analyzes the proposed timing and level of emission reduction commitments as 

a result of the proposed revision is the appropriate CEQA document.

Socioeconomic impacts for all control measures were already analyzed as part of the 

2007 AQMP and the proposed amendments are not expected to change the outcome of 

the previous analysis.

AQMP and Legal Mandates

The proposed revision to the PM2.5 and Ozone SIP for the South Coast Air Basin and 

Coachella Valley will not impact adversely the 2007 SIP attainment demonstration or 

the overall SIP reduction commitment. 

Resource Impacts

The proposed revision to the PM2.5 and Ozone SIP for the South Coast Air Basin and 

Coachella Valley will require no additional staff resources and funding.

Attachments

A Resolution 

B Revisions to the 2007 PM2.5 and Ozone SIP for South Coast Air Basin and 

Coachella Valley

C Addendum to the 2007 AQMP Final Program Environmental Impact Report

D 2007 AQMP Final Program Environmental Impact Report1

E Comments Received2

 1 Due to the bulk of these materials, the 2007 AQMP Program Environmental Impact Report is available online at 

http://www.aqmd.gov/ceqa/documents/2007/aqmd/finalEA/07aqmp/aqmp_fpeir.html for anyone wishing to view 

this material.

2 Response to these comments will be available prior to the Governing Board Meeting.
ATTACHMENT A

RESOLUTION NO. 11-

A Resolution of the South Coast Air Quality Management 

District Governing Board (AQMD) certifying the Addendum to Final 

Program Environmental Impact Report (PEIR) for the 2007 Air Quality 

Management Plan (AQMP) for a revision to the Final 2007 AQMP, to be 

referred to after adoption as the Revision to the Final 2007 AQMP.

A Resolution of the Governing Board of the AQMD adopting the 

Revision to the Final 2007 AQMP.

WHEREAS, the U.S. EPA promulgated 8-hour ozone and PM2.5 

standards in 1997, followed up by implementation rules which set forth the 

classification and planning requirements for State Implementation Plans (SIP); and

WHEREAS, the federal Clean Air Act requires SIPs for regions not 

in attainment with the 8-hour ozone and fine particulate standards be submitted no 

later than 3-years after the standards became effective, whereby, SIPs for the 

South Coast Air Basin and Coachella Valley must have been submitted for 8-hour 

ozone and PM2.5 by June 15, 2007 and April 5, 2008, respectively; and

WHEREAS, the South Coast Air Quality Management District has 

jurisdiction over the South Coast Air Basin and the desert portion of Riverside 

County known as the Coachella Valley; and

WHEREAS, the South Coast Air Quality Management District is 

committed to comply with the requirements of the federal Clean Air Act; and

WHEREAS, the AQMD Governing Board finds and determines that 

the Revision to the Final 2007 AQMP, is considered a "project" pursuant to the 

California Environmental Quality Act (CEQA); and

WHEREAS, AQMD staff has reviewed the Revision to the Final 

2007 AQMP and has concluded that the proposed project would result in no 

significant adverse environmental impacts; and

WHEREAS, AQMD staff has concluded that none of the 

modifications to the 2007 AQMP alter any of the conclusions reached in the Final 

PEIR for the 2007 AQMP and only minor technical changes or additions to the 

Final PEIR for the 2007 AQMP are necessary and none of the conditions in CEQA 

Guidelines §15162 apply so, an Addendum to the 2007 AQMP Final PEIR is the 

appropriate CEQA document (CEQA Guidelines §15164); and
WHEREAS, an Addendum to a previously certified EIR need not 

be circulated for public review and comment (CEQA Guidelines §15164(c), but is 

attached herein to the Final PEIR for the 2007 AQMP; and

WHEREAS, the Governing Board shall consider the Addendum 

with the Final PEIR for the 2007 AQMP prior to making a decision on the 

proposed project; and

WHEREAS, it is necessary that the adequacy of the Addendum to 

the Final PEIR for the 2007 AQMP be determined by the AQMD Governing 

Board prior to its certification; and

WHEREAS, the Governing Board prior to voting on the Proposed 

Revision to the Final 2007 AQMP, has reviewed and considered the Addendum 

with the Final PEIR for the 2007 AQMP; and

WHEREAS, the South Coast Air Quality Management District 

Governing Board, adopted the 2007 AQMP dated June 1, 2007 consisting of the 

document entitled 2007 AQMP as amended by the final changes set forth by the 

South Coast Air Quality Management District Governing Board and the associated 

documents listed in Attachment 1 to the Resolution from June 2007, the Final 

Socioeconomic Report for the 2007 AQMP; the Final Program EIR for the 2007 

AQMP, and the Statements of Findings and Overriding Considerations and 

Mitigation Monitoring Plan; and

WHEREAS, the Resolution, the 2007 AQMP as amended by the 

final changes (including all documents listed in Attachment 1 to the Resolution

from June 2007), the emissions budgets as incorporated in the 2007 AQMP, and 

the Final Program Environmental Impact Report on the 2007 AQMP was 

forwarded to and adopted by CARB, and the Board Resolution requested that the 

2007 AQMP be forwarded to the U.S. EPA for approval as part of the State 

Implementation Plan which CARB subsequently did; and

WHEREAS, on November 22, 2010, U.S. EPA published its notice 

of proposed partial approval and partial disapproval of the 2007 Air Quality 

Management Plan (AQMP) PM2.5 Plan primarily because the attainment 

demonstration relies too heavily (i.e. greater than 10 percent) on emissions 

reductions from several State rules that have not been finalized or submitted to 

U.S. EPA for approval; and 
WHEREAS, the 2011 revision to the 2007 PM2.5 and ozone SIP 

addresses the key elements of the proposed disapproval; and 

WHEREAS, the 2011 revision to the 2007 PM2.5 and ozone SIP 

updates the implementation status of the AQMP control measures to meet the 

2015 PM2.5 attainment; and

WHEREAS, the 2011 revision to the 2007 PM2.5 and ozone SIP 

retains the AQMD’s proposal for contingency measures and also references and 

relies on CARB’s proposed contingency measures; and

WHEREAS, the 2011 revision to the 2007 PM2.5 and ozone SIP reinitiates the request that U.S. EPA voluntarily accept reduction responsibility for 

10 TPD NOx emissions in 2014 but will propose that AQMD and CARB jointly 

provide a “fair share” backstop emissions reduction proposal and includes the 

AQMD’s commitment to obtain an additional 1 TPD NOx, if necessary; and

WHEREAS, the 2007 AQMP, as revised by the 2011 revision, 

includes every feasible measure and an expeditious adoption schedule; and

WHEREAS, significant emission reductions must be achieved from 

sources under state and federal jurisdiction for the South Coast Air Basin to attain 

the federal air quality standards; and 

WHEREAS, said emission reduction programs have effectively 

improved air quality in the South Coast Air Basin for particulate matter less than 

2.5 microns in diameter (PM2.5) and for 8-hr ozone; and 

NOW, THEREFORE, BE IT RESOLVED, that the South Coast 

Air Quality Management District Governing Board hereby certifies that the 

Addendum to the Final Program Environmental Impact Report for the 2007

AQMP has been completed in compliance with the requirements of CEQA and 

finds that the Addendum to the Final Program Environmental Impact Report for

the 2007 AQMP, is adequate and thereby approves it.

BE IT FURTHER RESOLVED, that because no significant 

adverse environmental impacts were identified as a result of implementing the 

Revisions to the 2007 PM2.5 and Ozone SIP, Findings, a Statement of Overriding 

Considerations, and a Mitigation Monitoring Plan are not required.

BE IT FURTHER RESOLVED, that the South Coast Air Quality 

Management District Governing Board hereby approves the 2011 Revisions to the 

2007 PM2.5 and Ozone SIP.
BE IT FURTHER RESOLVED, that the Executive Office is 

hereby directed to forward a copy of this Resolution, modified the 2011 Revision 

to the 2007 PM2.5 and Ozone SIP to CARB and to request that they be forwarded 

to the U.S. EPA for approval as part of the State Implementation Plan, and that 

U.S. EPA approve the 2007 PM2.5 and Ozone SIP as so modified.

Dated:______________

Clerk of the District Board
ATTACHMENT B

Revisions to 2007 PM2.5 and Ozone State 

Implementation Plan for South Coast Air 

Basin and Coachella Valley

March 2011
Revisions to PM2.5 and Ozone State Implementation Plan for South Coast Air 

Basin and Coachella Valley

2

Executive Summary

This State Implementation Plan (SIP) revision updates the implementation status of the 

AQMD control measures to meet the 2015 PM2.5 attainment, and includes revisions to 

the control measure adoption schedule and modifications to the emissions reduction 

commitment to reflect changes made to the inventory resulting from CARB’s December 

2010 revisions to the on-road truck and off road equipment rules. The SIP revision

provided addresses key elements in U.S. Environmental Protection Agency’s (U.S. EPA) 

proposed partial approval and partial disapproval of the 2007 PM2.5 SIP for the South 

Coast Air Basin (Basin). The SIP revision retains the AQMD’s proposal for contingency 

measures and also references and relies on CARB’s proposed contingency measures that 

rely on reductions achieved through adopted rules that go beyond the RFP requirement. 

In addition, the SIP revision re-initiates its request that U.S. EPA voluntarily accept 

reduction responsibility for 10 TPD NOx emissions in 2014 for federal sources in the 

2007 SIP, but provides a commitment to obtain a “fair share” additional 1 TPD NOx 

reductions in 2014 should U.S. EPA reject this request. Staff expects CARB to commit 

to its “fair share” of 9 TPD NOx reductions if necessary. AQMD is committing to 

provide 1.0 TPD NOx emissions reductions in the event that the backstop proposal 

becomes necessary.

Background

On November 22, 2010 U.S, EPA issued a notice of proposed partial approval and partial 

disapproval of the 2007 South Coast State Implementation Plan (SIP) for the 1997 Fine 

Particulate Matter Standards and the corresponding 2007 State Strategy. U.S. EPA 

proposed to approve the plan’s inventory and regional modeling analyses; however it 

proposed to disapprove the attainment demonstration because it relies too extensively on 

commitments to emissions reductions in lieu of fully adopted and submitted rules. While 

the District has adopted enforceable rules that achieve more than 90 percent of its SIP 

emissions reductions commitment, the State Strategy and the recent actions to modify the 

on- and off-road emissions from heavy duty vehicles have not achieved the same 

percentage or been submitted to U.S. EPA as part of the SIP commitment. The notice 

also cited deficiencies in the SIP’s contingency measures specifying the need for 

measures that are either fully adopted or otherwise ready for quick implementation and a 

trigger mechanism that achieves emissions reduction equivalent to one year of RFP. In 

addition, U.S. EPA affirmed that it would not accept the Plan’s assignment of 10 tons per 

day (TPD) NOx emissions reductions to EPA as a contributing factor to its decision.
Revisions to PM2.5 and Ozone State Implementation Plan for South Coast Air 

Basin and Coachella Valley

3

2007 AQMP and State Strategy Commitments

The 2007 Air Quality Management Plan was adopted by the SCAQMD Governing Board 

at its June 22, 2007 meeting and forwarded to CARB for inclusion in the SIP. The 

California Air Resources Board adopted the SIP, and the State Strategy for emissions 

reductions to meet the 2015 PM2.5 standard at its September 27, 2007 meeting. The two 

components of the SIP were submitted to U.S. EPA on November 16, 2007 for approval. 

As part of its share, the 2007 AQMP committed the District to reduce 18.8 TPD NOx, 10 

TPD VOC, 2.9 TPD SOx and 2.9 TPD PM2.5 by 2014 of the needed emissions 

reductions to demonstrate attainment. 

Update of the 2007 AQMP Implementation Status 

The SCAQMD has fulfilled the overwhelming majority of its emissions reductions 

commitments specified in the 2007 SIP. Table-1 summarizes the progress achieved 

toward fulfilling SCAQMD’s emissions reductions commitments to attain the 1997 

PM2.5 annual and federal 8-hour ozone standards by the required dates. Through 

January 31, 2011, the SCAQMD Governing Board has amended and adopted 13 rules 

achieving approximately 96 percent of the District’s SIP commitment outlined in the 

2007 AQMP. The majority of these rules have been submitted to U.S. EPA and 

approved as part of the SIP. Several recently adopted District rules have been submitted 

to CARB to be submitted to and subsequently be evaluated by U.S. EPA.

The 96 percent achievement rate of the District’s SIP commitment outlined in the 2007 

AQMP represents the balance of emissions reductions achieved by calculating the 

relative contributions of VOC, NOx, PM2.5, and SOx based on PM2.5 formation 

potential. As summarized in CARB’s staff report Proposed 2007 State Implementation 

Plan for the South Coast Air Basin – PM2.5 Annual and 8-Hour Average Ozone National 

Ambient Air Quality Standards (Appendix C, Tables-2 and -3) the relative contribution 

of the PM2.5 precursor emissions can be normalized to provide equivalent formation

potential on a ton per day (TPD) basis. The common methodology chosen to express the 

formation potential is as equivalent NOx emissions reductions whereby 1-TPD VOC 

reduction is equivalent to 0.43 TPD NOx, 1-TPD directly emitted PM2.5 is equivalent to 

9.86 TPD NOx, and 1-TPD SOx is equivalent to 15.03 TPD NOx. By applying these 

factors to the 2007 AQMP PM2.5 SIP the District committed to 87.43 TPD equivalent 

NOX reductions and through January, 2011 has achieved 83.89 TPD equivalent NOX 

reductions. If the balance were to be met by NOx alone, they are equivalent to 3.53 TPD 

of NOx. Similarly, they can be met by 0.36 TPD of PM2.5 or 0.24 TPD of SOx, based 
Revisions to PM2.5 and Ozone State Implementation Plan for South Coast Air 

Basin and Coachella Valley

4

on each pollutant’s effectiveness in PM2.5 formation. The District will continue to 

pursue further reductions of each of these pollutants.

Tables 2 through Table 5 summarize the implementation status of each SCAQMD control 

measure with reductions attained vs. original SIP commitments. As stated in Chapter 4 

of the 2007 AQMP (p. 4-2), substitution is allowed between measures to meet the overall 

SIP tonnage commitment. Table 2 through Table 5 note where such substitution occurs.

Revisions to Reduction Commitment

In Table 3, the 2014 emissions reduction commitment for the SOON Program has been 

revised from 12 TPD NOx reduction to 4 TPD to reflect ARB’s update of the off-road 

emissions inventory in December 2010. The revised off-road inventory due to better 

information on equipment population, load factor, and expected activity level has resulted 

in lower baseline emissions. In other words, some of the reductions expected from this 

measure have already occurred due to reductions in the baseline inventory. Although 

SCAQMD’s funding commitment and percent control efficiency for the SOON program 

remain the same, the expected reductions due to this measure are lowered from 12 TPD

to 4 TPD. This change does not result in higher emissions in the air. Should the 

economy recover to the levels projected in the 2007 SIP by 2014, the expected reductions 

can reach 8 TPD.

Revisions to Implementation Schedule

A limited number of revisions to the 2014 implementation dates are proposed in Tables 2 

through 5. Control measure EGM-01 rule adoption moves from 2010 to 2012 with full 

implementation for 2023. Control measure BCM-05 rule adoption is moved from 2010 

to 2011-2012.

Requirements for Contingency Measures

The CAA requires that non-attainment area SIPs contain sufficient contingency measures 

such that upon implementation of those measures additional emissions reduction of up to 

3 percent of the emissions in the adjusted base year would be achieved in the year 

following the year where the failure to meet milestone emission reduction targets or 

attain the NAAQS was observed. The CAA requires that the contingency measures be 

fully adopted or otherwise ready for quick implementation, with a trigger mechanism and 

implementation schedule that quantifies emissions reductions. 
Revisions to PM2.5 and Ozone State Implementation Plan for South Coast Air 

Basin and Coachella Valley

5

The Final 2007 AQMP contained four contingency control measures (2007 AQMP, Table 

9-1) to address the requirements of the CAA. The contingency control measures will be 

retained with a trigger for implementation of non-attainment of the PM2.5 standard by 

2015. 

As a practical matter, all feasible measures, to adopt as rules, are already included as 

2007 AQMP main control strategy measures and thus are not available for use as 

contingency measures. However, U.S. EPA may continue to conclude that this is not 

sufficiently quick implementation. Therefore, the AQMD would also rely on 

implementation of CARB’s contingency measures for the 2007 SIP as a whole, which are 

already adopted. 

Federal Measures Assignment

A final key element in the notice of disapproval was the U.S. EPA’s rejection of the SIP’s 

assignment to EPA of 10 TPD NOx emissions reductions. The U.S. EPA cited that the 

CAA does not authorize a State to assign responsibility to the federal government for 

meeting SIP requirements. U.S. EPA did however recognize that the authority and 

responsibility to regulate certain nationwide sources is within its jurisdiction. The control 

measure in question requested federal funding to mitigate locomotive emissions. The 

sources in question would be those less well controlled than California regulated sources 

and the measure would be implemented to acquire equivalent emissions reduction to 

those estimated if Tier 4 NOx locomotive engine standards were enforceable in 2014.

SCAQMD understands that U.S. EPA’s position is that a state may not, under the current 

Clean Air Act structure, unilaterally assign any portion of the SIP responsibility to U.S. 

EPA. However, we do not believe there is any prohibition on U.S. EPA voluntarily 

accepting such a responsibility. In this case it is only fair to do so, given the large 

percentage of remaining PM2.5 precursor emissions, after implementation of SCAQMD 

and CARB measures that is attributable to federally-regulated sources. 

Should U.S. EPA continue to not accept assignment for this measure, SCAQMD will 

work with CARB to modify or develop control measures that commit equivalent 

emissions reductions to assure PM2.5 attainment to the extent needed. As part of its “fair 

share” the AQMD is committing an additional 1 TPD NOx emissions reduction in 2014 

with ARB assuming the bulk of the federal assignment.
Revisions to PM2.5 and Ozone State Implementation Plan for South Coast Air 

Basin and Coachella Valley

6

Table-1

SCAQMD PM2.5 SIP Implementation Status

for the 2007 AQMP (TPD)

Pollutant

SIP Commitment by 2014

Commitment Achieved Balance*

VOC 10.40 14.40 +4.00

NOx 10.80 7.60 -3.20

PM2.5 2.90 1.00 -1.90

SOx 2.90 4.01 +1.11

* If the balance for each pollutant were converted to NOx-equivalent values, the 

remaining tons required to be obtained would be 3.53 TPD NOx, which are 

still scheduled to be obtained by 2014 in NOx-equivalent reductions. Or, they 

can be met by 0.36 TPD of PM2.5 or 0.24 TPD of SOx, based on each 

pollutant’s effectiveness in PM2.5 formation. The District will continue to 

pursue further reductions of each of these pollutants.
7

Table-2

2007 AQMP Emission Reduction Commitment by Measure/Adoption Date (VOC)1

Control

Measure #

Control Measure Title

Adoption Date Implementation Date 2014 Reductions (TPD) 2023 Reductions (TPD)

Commitment Achieved Commitment Achieved Commitment Achieved Commitment Achieved

MOB-05 AB923 Light-Duty Vehicle High-Emitter 

Identification Program [NOx, VOC](a)(b) On-going On-going 2007-2020 On-going 0.8 0 0.7 0

2007 Total 0.8 0 0.7 0

FLX-02 Petroleum Refinery Pilot Program [VOC 

and PM2.5] 2008 (a) 2010 0.7 0 1.6 0

CTS-01 Emission Reductions from Lubricants 

[VOC][R1144] 2008 2009 2010 2011 1.9 3.9 2.0 4.2

MOB-06

AB923 Medium-Duty Vehicle HighEmitter Identification Program [NOx, 

VOC](a)(b)

2008 On-going 2010-2020 On-going 0.5 0 0.6 0

FUG-04 Pipeline and Storage Tank 

Degassing[VOC]- R1149 2007 2008 2008-2009 2008 NA 0.04 NA 0.04

BCM-03

Emission Reductions from Wood 

Burning Fireplaces and Wood Stoves 

[All]

2007-2008 2008 2008-2014 2008-2014 NA 0.44 NA 0.70

MCS-07 All Feasible Measures (R1125) On-going 2008 2010-2020 2008 NA 0 NA 0

2008 Total 3.1 4.4 4.2 4.9

FUG-02

Emission Reductions from Gasoline 

Transfer and Dispensing Facilities 

[VOC]

2009 (c) 2010-2012 3.7 0 4.0 0

MCS-05 Emission Reductions from Livestock 

Waste [VOC] 2009 (a) 2011 0.8 0 0.6 00

EGM-01

Emission Reductions from New or 

Redevelopment Projects [NOx, VOC, 

PM2.5](d)

2012 Beginning 

2014 N/A 0 0.5 0

2009 Total 4.5 0.0 5.1 0.0
Revisions to PM2.5 and Ozone State Implementation Plan for South Coast Air Basin and Coachella Valley

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Table-2 Continued

2007 AQMP Emission Reduction Commitment by Measure/Adoption Date (VOC) continued

Control 

Measure # Control Measure Title

Adoption Date Implementation Date 2014 Reductions (TPD) 2023 Reductions (TPD)

Commitment Achieved Commitment Achieved Commitment Achieved Commitment Achieved

MCS-01* Facility Modernization [NOx, VOC, 

PM]-R1110.2(a) (e) On-going 2008+ Beginning 2012 2011+ 2.0 0.3 9.2 0.3

CTS-03

Consumer Products Certification and 

Emissions Reductions from Use of 

Consumer Products at Institutional and 

Commercial Facilities [VOC] (f)

2007-2010 2010-2020 NA 0 NA 0

CTS-04

Emission Reductions from the Reduction 

of VOC Content of Consumer Products 

not Regulated by the State Board 

[VOC[R1143] (f)

2008-2010 2009 2010-2020 2011 NA 9.7 NA 10.1

2010 Total 2.0 10.0 9.2 10.4

Total SIP Commitment 10.4 14.4 17.9 15.3

1 2014 reductions estiimated in average annual day, 2023 in planning inventory.

(a) SIP commitment for the PM2.5 Plan was met via excess reductions achieved from CTS-04 (R1143).

(b) The SOON and AB923 incentive programs are on track to achieve the targeted reductions by 2014. 

(c) AQMD lacks legal authority to adopt the control concept in the measure. SIP reduction commitment was met via excess reductions achieved from the CTS-04 (R1143).

(d) No SIP emission reduction commitment for the PM2.5 Plan. Rulemaking is delayed due to potential co-benefits of SB375 reduction targets. (e) AQMD will continue to implement this measure to meet the overall SIP reduction commitment for 2023.

(f) CTS-03 was adopted by CARB in November 2010. Emission Reductions from CTS-04 are not included in AQMD’s SIP commitments and there is no double counting in emission 

reductions relative to CARB regulations.

* NOx emission reductions taken in 2008; PM emission reductions taken in 2009; VOC emission reductions taken in 2010.

NA: Not applicable, no SIP Reductions quantified in the 2007 AQMP.
Revisions to PM2.5 and Ozone State Implementation Plan for South Coast Air Basin and Coachella Valley

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Table-3

2007 AQMP Emission Reduction Commitment by Measure/Adoption Date (NOx)1

Control 

Measure #

Control Measure Title

Adoption Date Implementation Date 2014 Reductions (TPD) 2023 Reductions (TPD)

Commitment Achieved Commitment Achieved Commitment Achieved Commitment

Achieved

MOB-05 AB923 Light-Duty Vehicle High-Emitter 

Identification Program [NOx, VOC](a) On-going On-going 2007-2020 On-going 0.4 0 0.4 0

2007 Total 0.4 0 0.4 0

CMB-01

NOx Reduction from Non-RECLAIM 

Ovens, Dryers ad Furnaces 

[NOx][R1147]

2008 2008 Beginning 

2010 2010 3.5 3.5 4.1 4.1

MOB-06

AB923 Medium-Duty Vehicle HighEmitter Identification Program [NOx, 

VOC](a)

2008 On-going 2010-2020 On-going 0.5 0 0.6 0

MCS-01* Facility Modernization [NOx, VOC, 

PM]-R1110.2, PR1146, PR1146.1 2008-2010 2008+ Beginning 2012 2011 1.6 2.17 2.2 3.15

BCM-03

Emission Reductions from Wood 

Burning Fireplaces and Wood Stoves 

[All][R445]

2007-2008 2008 2008-2014 2008-2014 NA 0.06 NA 0.10

SOON Program(a)(b) 2008 2008 2014 2008-2014 4-8 1.8 NA NA

2008 Total 9.6 7.5 6.9 7.3

CMB-03 Further NOx Reductions from Space 

Heaters [NOx]) 2009 2009 Beginning 

2012 2012-2043 0.8 0.1 1.1 3.0

EGM-01

Emission Reductions from New or 

Redevelopment Projects [NOx, VOC, 

PM2.5] (c)

2012 Beginning 

2014 0 0.8

2009 Total 0.8 0.1 1.9 3.0

Total SIP Commitment(d)(e) 10.8 7.6 9.2 10.3

1 2014 reductions estiimated in average annual day, 2023 in planning inventory.

(a) The SOON and AB923 incentive programs are on track to achieve the targeted reductions by 2014.

(b) A revised SIP commitment of 4 TPD reflects ARB's update on the off-road emissions inventory in December 2010 and maintains the same control efficiency.

The upper range of 8 TPD excludes the impact of recession.

(c) No SIP emission reduction commitment for the PM2.5 Plan. Rulemaking is delayed due to potential co-benefits of SB375 reduction targets. 

(d) The SIP shortfall for the 2014 reduction commitment was met via excess reductions achieved from the SOx RECLAIM amendments (CMB-02).

(e) AQMD commits an additional 1 TPD of NOx, if necessary, as a backstop measure should U.S. EPA not voluntarily accept responsibility for federal sources in the 2007 SIP.

* NOx emission reductions taken in 2008; PM emission reductions taken in 2009; VOC emission reductions taken in 2010.

NA: Not applicable, no SIP Reductions quantified in the 2007 AQMP.
Revisions to PM2.5 and Ozone State Implementation Plan for South Coast Air Basin and Coachella Valley

10

Table-4

2007 AQMP Emission Reduction Commitment by Measure/Adoption Date (PM2.5)

Control 

Measure #

Control Measure Title

Adoption Date Implementation Date 2014 Reductions (TPD) 2023 Reductions (TPD)

Commitment Achieved Commitment Achieved Commitment Achieved Commitment Achieved

BCM-03

Emission Reductions from Wood 

Burning Fireplaces and Wood Stoves 

[PM2.5]

2007-2008 2008 2008-2014 2008-2014 1.0 1.0 1.6 1.6

FLX-02 Petroleum Refinery Pilot Program [VOC 

and PM2.5](a) 2008 2010 0.4 0.4

2008 Total 1.4 1.0 2 1.6

EGM-01

Emission Reductions from New or 

Redevelopment Projects [NOx, VOC, 

PM2.5](b)

2012 Beginning 

2014 0.5

MCS-01* Facility Modernization [NOx, VOC, 

PM](a)(c) On-going Beginning 2012 0.4 1.7

2009 Total 0.4 2.2

BCM-05 PM Emission Reductions from Underfired Charbroilers [PM2.5](d) 2011-2012 2014 1.1 1.2

2010 Total 1.1 1.2

Total SIP 2.9 1 5.4 1.6

(a) Reduction commitment for the PM2.5 SIP was met via excess reductions achieved from the 2010 SOx RECLAIM amendments.

(b) No SIP emission reduction commitment for the PM2.5 Plan. Rulemaking is delayed due to potential co-benefits of SB375 reduction targets. 

(c) R1155 was adopted as part of MCS-01 implementation in 2010, but PM2.5 reduction potential cannot be quantified. AQMD will continue to seek opportunities to further implement 

this measure.

(d) Reduction commitment for the PM2.5 SIP was met via excess reductions achieved from the 2010 SOx RECLAIM amendments (CMB-02) and VOC reductions from CTS-03. The 

rulemaking will entail two phases with control equipment testing, certification, and deployment in 2011 and development of regulatory requirements in 2012. 

* NOx emission reductions taken in 2008; PM emission reductions taken in 2009; VOC emission reductions taken in 2010.

NA: Not applicable, no SIP Reductions quantified in the 2007 AQMP.
Revisions to PM2.5 and Ozone State Implementation Plan for South Coast Air Basin and Coachella Valley

11

Table-5

2007 AQMP Emission Reduction Commitment by Measure/Adoption Date (SOx)

Control 

Measure #

Control Measure Title

Adoption Date Implementation Date 2014 Reductions (TPD) 2023 Reductions (TPD)

Commitment Achieved Commitment Achieved Commitment Achieved Commitment Achieved

CMB-02 Further SOx Reductions for RECLAIM 

(BARCT) [SOx] 2008 2010 2011-2014 2013-2019 2.9 4.0 2.9 5.7

BCM-03

Emission Reductions from Wood 

Burning Fireplaces and Wood Stoves 

[All]

2007-2008 2008 2008-2014 2008-2014 NA 0.01 NA 0.02

2008 Total 2.9 4.01 2.9 5.7

2009 Total --- ---

2010 Total --- ---

Total SIP 2.9 4.01 2.9 5.7

NA: Not applicable, no SIP Reductions quantified in the 2007 AQMP.
ATTACHMENT C

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

Addendum: Revisions to the PM2.5 and Ozone State Implementation Plan for 

the South Coast Air Basin and Coachella Valley

February 2011

SCAQMD No. 02022011SS

State Clearinghouse No.: 2006111064

Executive Officer

Barry R. Wallerstein, D. Env.

Deputy Executive Officer

Planning, Rule Development and Area Sources

Elaine Chang, DrPH

Assistant Deputy Executive Officer

Planning, Rule Development and Area Sources

Laki Tisopulos, Ph.D., P.E.

Planning and Rules Manager

Planning, Rule Development and Area Sources

Susan Nakamura

Author: Steve Smith, Ph.D. Program Supervisor, CEQA

Reviewed By: Barbara Baird District Counsel
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

GOVERNING BOARD

Chairman: DR. WILLIAM A. BURKE

Speaker of the Assembly Appointee

Vice Chairman: DENNIS YATES

Mayor, Chino

Cities of San Bernardino County

MEMBERS:

MICHAEL D. ANTONOVICH

Supervisor, Fifth District

County of Los Angeles

JOHN J. BENOIT

Supervisor, Fourth District

County of Riverside

MICHAEL A. CACCIOTTI

Councilmember, South Pasadena

Cities of Los Angeles County/Eastern Region

SHAWN NELSON

Supervisor, Fourth District

County of Orange

JANE W. CARNEY

Senate Rules Appointee

JOSIE GONZALES

Supervisor, Fifth District

County of San Bernardino

RONALD O. LOVERIDGE

Mayor, Riverside

Cities of Riverside County

JOSEPH K. LYOU, Ph.D.

Governor’s Appointee

JUDITH MITCHELL

Councilmember, Rolling Hills Estates

Cities of Los Angeles County/Western Region

JAN PERRY

Councilmember, Ninth District

Cities Representative

Los Angeles County/Western Region

MIGUEL A. PULIDO

Mayor, Santa Ana

Cities of Orange County

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env.
Table of Contents

TOC i

CHAPTER 1 - PROJECT DESCRIPTION

Introduction................................................................................................................ 1

California Environmental Quality Act....................................................................... 2

Project Location......................................................................................................... 2

Project Objectives...................................................................................................... 3

Project Background.................................................................................................... 4

Update of the 2007 AQMP Implementation Status....................................... 4

Project Description..................................................................................................... 9

Revisions to the Emissions Reduction Commitment..................................... 9

Revisions to the 2007 AQMP Control Measures Adoption Schedule........... 9

Requirements for Contingency Measures...................................................... 9

Federal Assignment ....................................................................................... 12

Environmental Analysis............................................................................................. 12

Environmental Checklist and Discussion .................................................................. 13

LIST OF FIGURES

Figure 1: South Coast Air Quality Management District .......................................... 3

LIST OF TABLES

Table 1: SCAQMD PM2.5 SIP Implementation Status for the 2007

AQMP (TPD)................................................................................................ 5

Table 2: 2007 AQMP Emission Reduction Commitment by 

Measure/Adoption Date (VOC)..................................................................... 6

Table 3: 2007 AQMP Emission Reduction Commitment by 

Measure/Adoption Date (NOx)...................................................................... 8

Table 4: 2007 AQMP Emission Reduction Commitment by 

Measure/Adoption Date (PM2.5)................................................................... 11

Table 5: 2007 AQMP Emission Reduction Commitment by 

Measure/Adoption Date (SOx)...................................................................... 11

Table 6: SCAQMD Air Quality Significance Thresholds......................................... 19
A D D E N D U M

Introduction

California Environmental Quality Act

Project Location

Project Objective

Project Background

Project Description

Universe of Affected Sources
Addendum

Revision to the PM2.5 and Ozone SIP 1 February 2011

INTRODUCTION

The California Legislature created the South Coast Air Quality Management District 

(SCAQMD) in 19771 as the agency responsible for developing and enforcing air pollution 

control rules and regulations in the South Coast Air Basin (Basin) and portions of the Salton Sea 

Air Basin and Mojave Desert Air Basin referred to herein as the district. By statute, the 

SCAQMD is required to adopt an air quality management plan (AQMP) demonstrating 

compliance with all federal and state ambient air quality standards for the district2. Furthermore, 

the SCAQMD must adopt rules and regulations that carry out the AQMP3

At a June 1, 2007 public hearing, the SCAQMD Governing Board approved the 2007 AQMP 

and certified the Final Program Environmental Impact Report (PEIR) for the 2007 AQMP. On 

September 27, 2007, the CARB Board adopted the State Strategy for the 2007 State 

Implementation Plan and the 2007 South Coast Air Quality Management Plan as part of the 

(SIP). The 2007 SIP was then forwarded to U.S. EPA for approval.

. The 2007 AQMP 

concluded that major reductions in emissions of oxides of sulfur (SOx), particulate matter (PM) 

2.5 and oxides of nitrogen (NOx) are necessary to attain the air quality standards for ozone and 

particulate matter. Emission reductions from volatile organic compounds (VOCs) are also 

necessary, but to a lesser extent because of the greater emphasis on NOx emission reductions, 

which is a precursor to both ozone and PM. Ozone, a criteria pollutant, is formed when VOCs 

react with NOx in the atmosphere and has been shown to adversely affect human health. NOx 

also contributes to the formation of PM10 and PM2.5.

On November 22, 2010, U.S. EPA issued a notice of proposed partial approval and partial 

disapproval of the 2007 South Coast SIP for the 1997 Fine Particulate Matter Standards and the 

corresponding 2007 State Strategy. Specifically, U.S. EPA proposed approving the SIP’s 

inventory and regional modeling analyses, but it also proposed disapproving the attainment 

demonstration because it relies too extensively on commitments to emission reductions in lieu of 

fully adopted, submitted, and SIP-approved rules. The notice also cited deficiencies in the SIP’s 

contingency measures specifying the need for measures that are either fully adopted or otherwise 

ready for quick implementation and a trigger mechanism that achieves emissions reductions 

equivalent to one year of Reasonable Further Progress (RFP). Finally, U.S. EPA affirmed that it 

would not accept the SIP’s assignment of 10 tons per day (tpd) of NOx emissions reductions to 

U.S. EPA as a contributing factor to its decision.

In response to U.S. EPA’s partial disapproval of the 2007 SIP, the SCAQMD is proposing to 

submit: revisions to the PM2.5 and Ozone SIP to update the implementation status of SCAQMD 

control measures necessary to meet the 2015 PM2.5 attainment date; revisions to the control 

measure adoption schedule; and reflect changes made to the inventory resulting from California 

Air Resources Board’s (CARB’s) December 2010 revisions to the on-road truck and off-road 

equipment rules. Also, the SCAQMD commits to its “fair share” of additional NOx emission 

reductions, if needed, in the event U.S. EPA does not voluntarily accept the “federal 

assignment.”

 1 The Lewis-Presley Air Quality Management Act, 1976 Cal. Stats., ch 324 (codified at Health & Safety Code, 

§§40400-40540). 2

 Health & Safety Code, §40460 (a). 3

 Health & Safety Code, §40440 (a).
Addendum

Revision to the PM2.5 and Ozone SIP 2 February 2011

The 2007 SIP was considered to be a project as defined by California Environmental Quality Act 

(CEQA Guidelines §15378), so a PEIR was prepared because the 2007 AQMP had the potential 

to generated significant adverse environmental impacts. Further, because the 2007 SIP is 

considered to be a plan that governs the conduct of a continuing program, a program EIR was 

prepared pursuant to CEQA Guidelines §15168. The proposed revisions to the 2007 are also 

considered to be a project as defined by CEQA and are, therefore, subject to an appropriate 

CEQA analysis. As explained in the following section, an Addendum prepared pursuant to 

CEQA Guidelines §15164 is the appropriate CEQA document and has been prepared to address 

potential environmental impacts from the proposed 2007 PM2.5 and ozone Revisions.

CALIFORNIA ENVIRONMENTAL QUALITY ACT

Revisions to the 2007 SIP which include: revising the PM2.5 and Ozone SIP to update the 

implementation status of SCAQMD control measures necessary to meet the 2015 PM2.5 

attainment date; revising the control measure adoption schedule; and reflecting changes made to 

the inventory resulting from CARB’s December 2010 revisions to the on-road truck and off-road 

equipment rules are considered to be a discretionary approval by a public agency and, therefore,

are considered to be a “project” as defined by CEQA) (CEQA Guidelines §15387). Staff has 

evaluated the proposed revisions to the 2007 PM2.5 and Ozone SIP and concluded that none of 

the revisions meet the conditions described in §15162 calling for preparation of a subsequent 

EIR have occurred and only minor technical changes or additions are necessary. Based on these 

conclusions, staff has determined that an Addendum prepared pursuant to CEQA Guidelines 

§15164 is the appropriate CEQA document for the proposed revisions to the 2007 PM2.5 and 

Ozone SIP.

When a lead agency has determined that a proposed project qualifies for an Addendum, CEQA 

Guidelines §15164(e) requires the lead agency to prepare a brief explanation of the decision not 

to prepare a subsequent EIR pursuant to §15162, which should be included in an addendum to an 

EIR, the lead agency’s findings on the project, or elsewhere in the record. The explanation must 

be supported by substantial evidence. Substantial evidence supporting the determination to 

prepare an Addendum to the proposed 2007 PM2.5 and Ozone SIP revisions is provided in the 

section below entitled “Environmental Checklist and Discussion.”

SCAQMD staff’s review of the proposed project shows that the project would not have any

significant adverse effects on the environment. Therefore, no alternatives or mitigation measures 

are required to be included in this Addendum. The analysis in subsequent sections supports the 

conclusion of no significant adverse environmental impacts. Finally, pursuant to CEQA 

Guidelines §15164(c) an addendum need not be circulated for public review.

PROJECT LOCATION

The SCAQMD has jurisdiction over an area of 10,473 square miles, consisting of the fourcounty South Coast Air Basin (Basin) and the Riverside County portions of the Salton Sea Air 

Basin (SSAB) and the Mojave Desert Air Basin (MDAB), hereinafter referred to as district. The 

Basin, which is a subarea of the district, is bounded by the Pacific Ocean to the west and the San 

Gabriel, San Bernardino, and San Jacinto Mountains to the north and east. The 6,745 square-
Addendum

Revision to the PM2.5 and Ozone SIP 3 February 2011

mile Basin includes all of Orange County and the non-desert portions of Los Angeles, Riverside, 

and San Bernardino counties. The Riverside County portion of the SSAB and MDAB is 

bounded by the San Jacinto Mountains in the west and spans eastward up to the Palo Verde 

Valley. The federal non-attainment area (known as the Coachella Valley Planning Area) is a 

subregion of both Riverside County and the SSAB and is bounded by the San Jacinto Mountains 

to the west and the eastern boundary of the Coachella Valley to the east (Figure 1). The 2007 

SIP and the currently proposed revisions to the 2007 PM2.5 and Ozone SIP apply to the entire 

district.

South Coast

Air Quality Management District

 SCAQMD Jurisdiction

Mojave Desert

Air Basin

Salton Sea

Air Basin

San Diego

Air Basin

South

 Central

 Coast Air Basin

South Coast

 Air Basin

San Diego County Imperial County

Riverside County

Los Angeles

 County

Kern County San Bernardino County

Orange

 County

Santa 

 Barbara

 County

Ventura 

 County

San Joaquin

 Valley

 Air Basin

Figure 1

Boundaries of the South Coast Air Quality Management District

PROJECT OBJECTIVES

The general project objectives of the proposed revisions to the 2007 PM2.5 and Ozone SIP are 

summarized in the following bullet points:

• Provide revisions to the 2007 PM2.5 and Ozone SIP that would allow U.S. EPA to 

expeditiously approve the portion of the 2007 PM2.5 SIP that it is currently proposing to 

disapprove;

• Revise the PM2.5 and Ozone SIPs to update the implementation status of SCAQMD 

control measures necessary to meet the 2015 PM2.5 attainment date;

• Revise the control measure adoption schedule; and

• Reflect changes made to the inventory resulting from CARB’s December 2010 revisions 

to the on-road truck and off-road equipment rules.
Addendum

Revision to the PM2.5 and Ozone SIP 4 February 2011

PROJECT BACKGROUND

The 2007 Air Quality Management Plan was adopted by the SCAQMD Governing Board at its 

June 22, 2007 meeting and forwarded to CARB for inclusion in the SIP. The California Air 

Resources Board adopted the SIP, and the State Strategy for emissions reductions to meet the 

2015 PM2.5 standard at its September 27, 2007 meeting. The two components of the SIP were 

submitted to U.S. EPA on November 16, 2007 for approval. As part of its share, the 2007 

AQMP committed the SCAQMD to reduce emissions to demonstrate attainment by 2014 in the 

following amounts: 18.8 tpd of NOx, 10.4 tpd of VOCs, 2.9 tpd of SOx and 2.9 tpd of PM2.5.

On November 22, 2010 U.S, EPA issued a notice of proposed partial approval and partial 

disapproval of the 2007 South Coast SIP for the 1997 Fine Particulate Matter Standards and the 

corresponding 2007 State Strategy. U.S. EPA proposed to approve the plan’s inventory and 

regional modeling analyses; however it proposed to disapprove the attainment demonstration 

because it relies too extensively on commitments to emissions reductions in lieu of fully adopted, 

submitted, and SIP approved rules. The notice also cited deficiencies in the SIP’s contingency 

measures specifying the need for measures that are either fully adopted or otherwise ready for 

quick implementation and a trigger mechanism that achieves emissions reduction equivalent to 

one year of Reasonable Further Progress (RFP). In addition, U.S. EPA affirmed that it would not 

accept the Plan’s assignment of 10 tons per day (TPD) NOx emissions reductions to U.S. EPA as 

a contributing factor to its decision.

At the January 7, 2011 Governing Board meeting, the Board approved a proposal to send a letter 

to U.S. EPA in response to the partial disapproval of the 2007 SIP. The letter provided a detailed 

legal discussion of why the SCAQMD considers the proposed disapproval based on enforceable 

commitments of more than 10 percent of the needed reductions is “arbitrary and capricious.” 

The letter noted further, that extension of the attainment date to 2015 is essential for the success 

of the SIP. Implementation of the adopted control measures listed in the AQMP/SIP has been 

structured to provide adequate lead time for a wide number of affected industries and mobile 

sources with the rules and regulations. For additional information on the content of SCAQMD’s 

letter to U.S. EPA, please refer to the January 7, 2011 Board meeting, agenda item #19 at: 

http://www.aqmd.gov/hb/attachments/2011-2015/2011Jan/2011-Jan7-019.pdf. 

Update of the 2007 A QM P I mplementation Status 

The SCAQMD has fulfilled the majority of its emissions reductions commitments specified in 

the 2007 SIP. Table 1 summarizes the progress achieved toward fulfilling SCAQMD’s emissions 

reductions commitments to attain the 1997 PM2.5 annual and federal 8-hour ozone standards by 

the required dates. Through January 31, 2011, the SCAQMD Governing Board has amended 

and adopted 13 rules achieving approximately 96 percent of the SCAQMD’s SIP commitment 

outlined in the 2007 AQMP. The majority of these rules have been submitted to U.S. EPA and 

approved as part of the SIP. Several recently adopted SCAQMD rules have been submitted to 

CARB and have been or are expected to be submitted to and subsequently evaluated by U.S. 

EPA. Overall, there are no proposed changes to the emissions reduction commitment for either 

2014 or 2023.
Addendum

Revision to the PM2.5 and Ozone SIP 5 February 2011

Table 1

SCAQMD PM2.5 SIP Implementation Status

for the 2007 AQMP (TPD)

SIP Commitment by 2014

Pollutant Commitment Achieved Balance*

VOC 10.40 14.40 +4.00

NOx 10.80 7.60 -3.20

PM2.5 2.90 1.00 -1.90

SOx 2.90 4.01 +1.11

* If the balance for each pollutant were converted to NOx-equivalent values, the 

remaining tons required to be obtained would be 3.53 TPD NOx, which are still 

scheduled to be obtained by 2014 in NOx-equivalent reductions. Or, they can be met by 

0.36 TPD of PM2.5 or 0.24 TPD of SOx, based on each pollutant’s effectiveness in 

PM2.5 formation. The District will continue to pursue further reductions of each of 

these pollutants.

The 96 percent achievement rate of the SCAQMD’s SIP commitment outlined in the 2007 

AQMP represents the balance of emissions reductions achieved by calculating the relative 

contributions of VOC, NOx, PM2.5, and SOx emissions based on PM2.5 formation potential. 

As indicated in CARB’s staff report Proposed 2007 State Implementation Plan for the South 

Coast Air Basin – PM2.5 Annual and 8-Hour Average Ozone National Ambient Air Quality 

Standards (Appendix C) and summarized in Tables 2 and 3, the relative contribution of the 

PM2.5 precursor emissions can be normalized to provide equivalent formation potential on a ton 

per day (TPD) basis. The common methodology chosen to express the formation potential is as 

equivalent NOx emissions reductions whereby one tpd VOC emission reduction is equivalent to 

0.43 tpd of NOx mission reductions, one tpd of directly emitted PM2.5 emissions is equivalent to 

9.86 tpd of NOx emissions, and one tpd of SOx emissions is equivalent to 15.03 tpd of NOx

emissions. By applying these factors to the 2007 AQMP PM2.5 SIP the SCAQMD committed to 

87.43 tpd of equivalent NOx emission reductions and through January, 2011, and has achieved 

83.89 tpd equivalent NOx emission reductions. If the balance were to be met by NOx alone, 

they would be equivalent to 3.53 tpd of NOx emissions. Similarly, the remaining emission 

reduction commitment can be met by reducing 0.36 tpd of PM2.5 emissions or 0.24 tpd of SOx, 

emissions based on each pollutant’s effectiveness in PM2.5 formation. The SCAQMD is 

committed to pursuing further reductions of each of these pollutants. For all measures in the 

2007 AQMP, their environmental impacts have already been analyzed as part of the Final PEIR 

for the 2007 AQMP. As each control measure has been promulgated into a rule or regulation, 

individual Environmental Assessments4

 4 Under its Certified Regulatory Program (Public Resources Code §21080.5), CEQA documents for SCAQMD 

regulatory projects are call environmental assessments rather than EIRs or mitigated/negative declarations.

have been prepared during each rulemaking that tier off 

of the Final PEIR for the 2007 AQMP.
Addendum

Revision to the PM2.5 and Ozone SIP 6 February 2011

Table 2

2007 AQMP Emission Reduction Commitment by Measure/Adoption Date (VOC)1

Control 

Measure 

#

Control Measure Title Adoption Date Implementation Date 2014 Reductions (TPD) 2023 Reductions (TPD)

Commitment Achieved Commitment Achieved Commitment Achieved Commitment Achieved

MOB-05

AB923 Light-Duty Vehicle 

High-Emitter Identification 

Program [NOx, VOC](a)(b)

On-going On-going 2007-2020 On-going 0.8 0 0.7 0

2007 Total 0.8 0 0.7 0

FLX-02 Petroleum Refinery Pilot 

Program [VOC and PM2.5] 2008 (a) 2010 0.7 0 1.6 0

CTS-01 Emission Reductions from 

Lubricants [VOC][R1144] 2008 2009 2010 2011 1.9 3.9 2.0 4.2

MOB-06

AB923 Medium-Duty Vehicle 

High-Emitter Identification 

Program [NOx, VOC](a)(b)

2008 On-going 2010-2020 On-going 0.5 0 0.6 0

FUG-04 Pipeline and Storage Tank 

Degassing[VOC]- R1149 2007 2008 2008-2009 2008 NA 0.04 NA 0.04

BCM-03

Emission Reductions from 

Wood Burning Fireplaces and 

Wood Stoves [All]

2007-2008 2008 2008-2014 2008-2014 NA 0.44 NA 0.70

MCS-07 All Feasible Measures (R1125) On-going 2008 2010-2020 2008 NA 0 NA 0

2008 Total 3.1 4.4 4.2 4.9

FUG-02

Emission Reductions from 

Gasoline Transfer and 

Dispensing Facilities [VOC]

2009 (c) 2010-2012 3.7 0 4.0 0

MCS-05 Emission Reductions from 

Livestock Waste [VOC] 2009 (a) 2011 0.8 0 0.6 00

EGM-01

Emission Reductions from New 

or Redevelopment Projects 

[NOx, VOC, PM2.5](d)

2012 Beginning 

2014 N/A 0 0.5 0

2009 Total 4.5 0.0 5.1 0.0
Addendum

Revision to the PM2.5 and Ozone SIP 7 February 2011

Table 2 Concluded

2007 AQMP Emission Reduction Commitment by Measure/Adoption Date (VOC) continued

Control 

Measure 

#

Control Measure Title

Adoption Date Implementation Date 2014 Reductions (TPD) 2023 Reductions (TPD)

Commitment Achieved Commitment Achieved Commitment Achieved Commitment Achieved

MCS01*Facility Modernization [NOx, 

VOC, PM]-R1110.2(a) (e) On-going 2008+ Beginning 2012 2011+ 2.0 0.3 9.2 0.3

CTS-03

Consumer Products Certification 

and Emissions Reductions from 

Use of Consumer Products at 

Institutional and Commercial 

Facilities [VOC](f)

2007-2010 2010-2020 NA 0 NA 0

CTS-04

Emission Reductions from the 

Reduction of VOC Content of 

Consumer Products not 

Regulated by the State Board 

[VOC[R1143](f)

2008-2010 2009 2010-2020 2011 NA 9.7 NA 10.1

2010 Total 2.0 10.0 9.2 10.4

Total SIP Commitment 10.4 14.4 17.9 15.3

1 2014 reductions estimated in average annual day, 2023 in planning inventory.

(a) SIP commitment for the PM2.5 Plan was met via excess reductions achieved from CTS-04 (R1143).

(b)The SOON and AB923 incentive programs are on track to achieve the targeted reductions by 2014. 

(c) AQMD lacks legal authority to adopt the control concept in the measure. SIP reduction commitment was met via excess reductions achieved from the CTS-04 (R1143).

(d)No SIP emission reduction commitment for the PM2.5 Plan. Rulemaking is delayed due to potential co-benefits of SB375 reduction targets. 

(e) AQMD will continue to implement this measure to meet the overall SIP reduction commitment for 2023.

(f) CTS-03 was adopted by CARB in November 2010. Emission Reductions from CTS-04 are not included in AQMD’s SIP commitments and there is no double counting in 

emission reductions relative to CARB regulations.

* NOx emission reductions taken in 2008; PM emission reductions taken in 2009; VOC emission reductions taken in 2010.

NA: Not applicable, no SIP Reductions quantified in the 2007 AQMP.
Addendum

Revision to the PM2.5 and Ozone SIP 8 February 2011

Table 3

2007 AQMP Emission Reduction Commitment by Measure/Adoption Date (NOx)1

Control 

Measure # Control Measure Title

Adoption Date Implementation Date 2014 Reductions (TPD) 2023 Reductions (TPD)

Commitment Achieved Commitment Achieved Commitment Achieved Commitment Achieved

MOB-05 AB923 Light-Duty Vehicle High-Emitter 

Identification Program [NOx, VOC](a) On-going On-going 2007-2020 On-going 0.4 0 0.4 0

2007 Total 0.4 0 0.4 0

CMB-01

NOx Reduction from Non-RECLAIM 

Ovens, Dryers ad Furnaces 

[NOx][R1147]

2008 2008 Beginning 

2010 2010 3.5 3.5 4.1 4.1

MOB-06

AB923 Medium-Duty Vehicle HighEmitter Identification Program [NOx, 

VOC](a)

2008 On-going 2010-2020 On-going 0.5 0 0.6 0

MCS-01* Facility Modernization [NOx, VOC, 

PM]-R1110.2, PR1146, PR1146.1 2008-2010 2008+ Beginning 

2012 2011 1.6 2.17 2.2 3.15

BCM-03

Emission Reductions from Wood 

Burning Fireplaces and Wood Stoves 

[All][R445]

2007-2008 2008 2008-2014 2008-2014 NA 0.06 NA 0.10

SOON Program(a)(b) 2008 2008 2014 2008-2014 4-8 1.8 NA NA

2008 Total 9.6 7.5 6.9 7.3

CMB-03 Further NOx Reductions from Space 

Heaters [NOx]) 2009 2009 Beginning 

2012 2012-2043 0.8 0.1 1.1 3.0

EGM-01

Emission Reductions from New or 

Redevelopment Projects [NOx, VOC, 

PM2.5] (c)

2012 Beginning 

2014 0 0.8

2009 Total 0.8 0.1 1.9 3.0

Total SIP Commitment(d)(e) 10.8 7.6 9.2 10.3

1 2014 reductions estimated in average annual day, 2023 in planning inventory.

(a) The SOON and AB923 incentive programs are on track to achieve the targeted reductions by 2014. 

(b) A revised SIP commitment of 4 tpd reflects ARB's update on the off-road emissions inventory in December 2010 and maintains the same control efficiency.

The upper range of 8 tpd excludes the impact of recession.

(c) No SIP emission reduction commitment for the PM2.5 Plan. Rulemaking is delayed due to potential co-benefits of SB375 reduction targets. 

(d) The SIP shortfall for the 2014 reduction commitment was met via excess reductions achieved from the SOx RECLAIM amendments (CMB-02).

(e) AQMD commits an additional 1 TPD of NOx, if necessary, as a backstop measure should U.S. EPA not voluntarily accept responsibility for federal sources in the 2007 SIP.

* NOx emission reductions taken in 2008; PM emission reductions taken in 2009; VOC emission reductions taken in 2010.

NA: Not applicable, no SIP Reductions quantified in the 2007 AQMP.
Addendum

Revision to the PM2.5 and Ozone SIP 9 February 2011

PROJECT DESCRIPTION

The proposed project consists of revisions to the PM2.5 and Ozone SIP to update the 

implementation status of the SCAQMD control measures to meet the 2015 PM2.5 attainment 

deadline, revisions to the control measure adoption schedule and modifications to the emissions 

reduction tonnage to reflect changes made to the inventory resulting from CARB’s December 

2010 revisions to the on-road truck and off road equipment rules. 

The proposed project also consists of a commitment to adopt SCAQMD’s “fair share” of NOx 

emission reductions if needed to replace the federal assignment. The SIP revision will retain the 

SCAQMD’s proposal for contingency measures and also reference and rely on CARB’s 

proposed contingency measures that rely on reductions achieved through adopted rules that go 

beyond the RFP requirement. The following sections summarize the modifications to the 2007 

PM2.5 and Ozone SIP that the SCAQMD is proposing to submit to CARB, which is expected to 

be forwarded to U.S. EPA.

R evisions to the E missions R eduction C ommitment

Table 3 shows that the 2014 emissions reduction commitment for the Surplus Off-Road Opt-In 

for NOx (SOON) Program (SCAQMD Rule 2449 – Control of Oxides of Nitrogen Emissions 

from Off-Road Diesel Vehicles) has been revised from 12 tpd NOx reduction to four tpd to 

reflect CARB’s update of the off-road emissions inventory adopted in December 2010. Due to 

better information on equipment population, load factors, and expected activity levels, the offroad mobile sources inventory has been revised to reflect lower baseline emissions. In effect, 

some of the reductions expected to be achieved by this measure have already been achieved due 

to reductions in the baseline inventory. Although SCAQMD’s funding commitment and percent 

control efficiency for the SOON program remain the same, the expected reductions are lowered 

from 12 tpd to 4 tpd. This change does not result in higher emissions in the air. Should the 

economy recover to the levels projected in the 2007 SIP by 2014, the expected reductions can 

reach 8 tpd.

R evisions to the 2007 A QM P C ontr ol M easur es A doption Schedule

SCAQMD is proposing to revise rule adoption dates for two AQMP control measures. These 

proposed revisions are shown in Tables 2 through 5. For example, the SCAQMD is proposing to 

modify the adoption date for control measure EGM-01 from 2010 to 2012 with full 

implementation by 2023. Similarly, the SCAQMD is proposing to modify the adoption date for 

control measure BCM-05 from 2010 to the 2011 – 2012 timeframe.

R equir ements for C ontingency M easur es

The federal Clean Air Act (CAA) requires that non-attainment area SIPs contain sufficient 

contingency measures such that upon implementation of those measures additional emissions 

reduction of up to three percent of the emissions in the adjusted base year would be achieved in 

the year following the year where the failure to meet milestone emission reduction targets or 

attain the National Ambient Air Quality Standards (NAAQS) was observed. 
Addendum

Revision to the PM2.5 and Ozone SIP 10 February 2011

Table-4

2007 AQMP Emission Reduction Commitment by Measure/Adoption Date (PM2.5)

Control 

Measure 

#

Control Measure Title

Adoption Date Implementation Date 2014 Reductions (TPD) 2023 Reductions (TPD)

Commitment Achieved Commitment Achieved Commitment Achieved Commitment Achieved

BCM03

Emission Reductions from 

Wood Burning Fireplaces 

and Wood Stoves [PM2.5]

2007-2008 2008 2008-2014 2008-

2014 1.0 1.0 1.6 1.6

FLX-02

Petroleum Refinery Pilot 

Program [VOC and 

PM2.5](a)

2008 2010 0.4 0.4

2008 Total 1.4 1.0 2 1.6

EGM01

Emission Reductions from 

New or Redevelopment 

Projects [NOx, VOC, 

PM2.5](b)

2012 Beginning 

2014 0.5

MCS01*Facility Modernization 

[NOx, VOC, PM](a)(c) On-going Beginning 2012 0.4 1.7

2009 Total 0.4 2.2

BCM05

PM Emission Reductions 

from Under-fired 

Charbroilers [PM2.5](d)

2011-2012 2014 1.1 1.2

2010 Total 1.1 1.2

Total SIP 2.9 1 5.4 1.6

(a) Reduction commitment for the PM2.5 SIP was met via excess reductions achieved from the 2010 SOx RECLAIM amendments.

(b)No SIP emission reduction commitment for the PM2.5 Plan. Rulemaking is delayed due to potential co-benefits of SB375 reduction targets. 

(c) R1155 was adopted as part of MCS-01 implementation in 2010, but PM2.5 reduction potential cannot be quantified. AQMD will continue to seek opportunities to 

further implement this measure.

(d)Reduction commitment for the PM2.5 SIP was met via excess reductions achieved from the 2010 SOx RECLAIM amendments (CMB-02) and VOC reductions from 

CTS-03. The rulemaking will entail two phases with control equipment testing, certification, and deployment in 2011 and development of regulatory requirements in 

2012. 

* NOx emission reductions taken in 2008; PM emission reductions taken in 2009; VOC emission reductions taken in 2010.

NA: Not applicable, no SIP Reductions quantified in the 2007 AQMP.
Addendum

2007 SIP – Revision 11 February 2011

Table-5

2007 AQMP Emission Reduction Commitment by Measure/Adoption Date (SOx)

Control 

Measure 

#

Control Measure Title

Adoption Date Implementation Date 2014 Reductions (TPD) 2023 Reductions (TPD)

Commitment Achieved Commitment Achieved Commitment Achieved Commitment Achieved

CMB-02 Further SOx Reductions for 

RECLAIM (BARCT) [SOx] 2008 2010 2011-2014 2013-2019 2.9 4.0 2.9 5.7

BCM-03

Emission Reductions from Wood 

Burning Fireplaces and Wood 

Stoves [All]

2007-2008 2008 2008-2014 2008-2014 NA 0.01 NA 0.02

2008 Total 2.9 4.01 2.9 5.7

2009 Total --- ---

2010 Total --- ---

Total SIP 2.9 4.01 2.9 5.7

NA: Not applicable, no SIP Reductions quantified in the 2007 AQMP.
Addendum

Revision to the PM2.5 and Ozone SIP 12 February 2011

The CAA requires that the contingency measures be fully adopted or otherwise ready for quick 

implementation, with a trigger mechanism and implementation schedule that quantifies 

emissions reductions. The Final 2007 AQMP contained four contingency control measures 

(2007 AQMP, Table 9-1) to address the requirements of the CAA. The contingency control 

measures will be retained with a trigger for their implementation based on non-attainment of the 

PM2.5 standard by 2015. To address U.S. EPA’s comments, the SCAQMD would also rely on 

implementation of CARB’s contingency measures for the 2007 SIP as a whole. 

F eder al Assignment

A final key element in the notice of disapproval of the 2007 SIP was the assignment to the U.S. 

EPA a 10 tpd NOx emissions reduction commitment. U.S. EPA rejected this commitment citing

the CAA, stating it does not authorize a state to assign responsibility to the federal government 

for meeting SIP requirements. U.S. EPA did however recognize that the authority and 

responsibility to regulate certain nationwide sources resides within its jurisdiction. The control 

measure in question requested federal funding to mitigate locomotive emissions in 2014 in lieu 

of implementation of the proposed new federal locomotive standard to meet the PM2.5 

attainment deadline. The sources in question would be those that are less well-controlled than 

California regulated sources and the measure would be implemented to acquire equivalent 

emissions reduction to those estimated if Tier 4 NOx locomotive engine standards were 

enforceable in 2014. 

SCAQMD understands that U.S. EPA’s position is that a state may not, under the current CAA

structure, unilaterally assign any portion of the SIP responsibility to U.S. EPA. However, 

SCAQMD staff does not find in the CAA any prohibition against U.S. EPA voluntarily accepting 

such a responsibility. In this case it is only fair to do so, given the large percentage of remaining 

PM2.5 precursor emissions, after implementation of SCAQMD and CARB measures that is 

attributable to federally-regulated sources. 

Should U.S. EPA continue to not accept assignment for this measure, SCAQMD will work with 

CARB to modify or develop control measures that commit equivalent emissions reductions to 

assure PM2.5 attainment to the extent needed. As part of its “fair share” the SCAQMD commits

to an additional one tpd of NOx emission reductions in 2014 with CARB assuming the 

remaining nine tpd reductions of the federal assignment.

ENVIRONMENTAL ANALYSIS

The environmental checklist provides a standard evaluation tool to identify a project's adverse 

environmental impacts. This checklist identifies and evaluates potential adverse environmental 

impacts that may be created by the proposed project. 
Addendum

Revision to the PM2.5 and Ozone SIP 13 February 2011

ENVIRONMENTAL CHECKLIST AND DISCUSSION

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

I. AESTHETICS. Would the project:

a) Have a substantial adverse effect on a 

scenic vista?

   

b) Substantially damage scenic resources, 

including, but not limited to, trees, 

rock outcroppings, and historic 

buildings within a state scenic 

highway?

   

c) Substantially degrade the existing 

visual character or quality of the site 

and its surroundings?

   

d) Create a new source of substantial 

light or glare which would adversely 

affect day or nighttime views in the 

area?

   

Significance C r iter ia

The proposed project impacts on aesthetics will be considered significant if:

- The project will block views from a scenic highway or corridor.

- The project will adversely affect the visual continuity of the surrounding area.

- The impacts on light and glare will be considered significant if the project adds lighting 

which would add glare to residential areas or sensitive receptors.

Discussion

I. a) – c): Overall, it was concluded in the Initial Study (IS) for the 2007 AQMP that AQMP

control measures are not expected to adversely affect scenic vistas in the district; damage scenic 

resources, including but not limited to trees, rock outcroppings, or historic buildings within a 

scenic highway; or substantially degrade the visual character of a site or its surroundings. The 

reason for this conclusion is that most of the AQMP control measures that would be 

implemented by the SCAQMD typically affect industrial, institutional, or commercial facilities 

located in appropriately zoned areas (e.g., industrial and commercial areas) that are not usually 

associated with scenic resources. Construction activities are expected to be limited to industrial 

and commercial areas. Further, modifications typically occur inside the buildings at the affected 

facilities, or because of the nature of the business (e.g., commercial or industrial) can easily 

blend with the facilities with little or no noticeable effect on adjacent areas. Some control 

measures that are under the jurisdiction of CARB or the U.S. EPA would establish exhaust 

emission standards. Establishing exhaust emission standards for mobile sources would also not 

be expected to adversely affect scenic resources.
Addendum

Revision to the PM2.5 and Ozone SIP 14 February 2011

Further, emission growth management control measures may require emission reductions from 

new or redevelopment land use projects. These control measures, however, do not initiate or 

promote land use projects, they may simply require emission reductions after the decision has 

already been made to pursue new or redevelopment projects. As a result, emission growth 

management control measures are not expected to adversely affect local land use policies or 

create aesthetic impacts.

It was concluded in the IS for the 2007 AQMP that it may have a beneficial effect on scenic 

resources by improving visibility as well as improving air quality, preventing smoke (BCM-03 

and BCM-04, limit opening burning and wood burning), and minimizing dust (BCM-02 and 

EGM-01, dust control).

I. d): The 2007 AQMP is not expected to create additional demand for new lighting or exposed 

combustion sources (e.g., flares) that could create glare that could adversely affect day or 

nighttime views in any areas. As noted in item I. a) – c) above, facilities affected by AQMP 

control measures typically make modifications in the interior of an affected facility so any new 

light sources would typically be inside a building or not noticeable because of the presence of 

existing outdoor light sources. Further, operators of commercial or industrial facilities who 

would make physical modifications to facilities and may require additional lighting would be 

located in appropriately zoned areas that are not usually located next to residential areas, so new 

light sources, if any, would not be noticeable to residents.

Conclusion

Based upon the above considerations, it was concluded in the 2007 AQMP IS that significant 

adverse project-specific aesthetic impacts would not be expected to occur due to implementation 

of the 2007 AQMP control measures. 

The proposed revisions to the 2007 PM2.5 and Ozone SIP are not expected to create any new 

aesthetics impacts or make substantially worse impacts identified in the 2007 AQMP IS for the 

following reasons. The proposed revisions would not change any of the above conclusions 

because they do not include incorporating any new types of control measures into the SIP that 

could create new adverse aesthetics impacts. Further, the proposed project does not contain any 

revisions to the substantive requirements of any 2007 AQMP control measures. As of January 

2011, the SCAQMD has achieved 96 percent of its emissions reductions commitment. Although 

the adoption dates for some of the remaining control measures have been delayed, the 

implementation dates have not; therefore, the SCAQMD is expected to achieve its remaining 

emission reduction commitments by both 2014 and 2023, in part, through reliance on greater 

than anticipated emission reductions from previously implemented control measures. The 

SCAQMD would also commit to retaining the contingency control measures, including triggers

for implementation in the event that the PM2.5 standard is not achieved by 2015. Finally, if U.S. 

EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the SCAQMD 

would commit to an additional one tpd of NOx emission reductions in 2014 with CARB 

assuming the remaining nine tpd reductions of the federal assignment in order to continue to 

demonstrate attainment of all applicable standards. This additional one tpd commitment would 

not foreseeably have any different impacts than existing 2007 AQMP control measures. These 

emission reductions would most likely occur as a result of greater reductions obtained from 

adopted regulations or early implementation of control measures in the 2007 AQMP. There are 
Addendum

Revision to the PM2.5 and Ozone SIP 15 February 2011

no provisions in the proposed project that would create new adverse impacts or make existing 

aesthetics impacts worse.

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

II. AGRICULTURE AND FOREST 

RESOURCES. Would the project:

a) Convert Prime Farmland, Unique 

Farmland, or Farmland of Statewide 

Importance (Farmland), as shown on 

the maps prepared pursuant to the 

Farmland mapping and Monitoring 

Program of the California Resources 

Agency, to non- agricultural use?

   

b) Conflict with existing zoning for 

agricultural use, or a Williamson Act 

contract? 

   

c) Conflict with existing zoning for, or 

cause rezoning of, forest land (as 

defined in Public Resources Code 

§12220(g)), timberland (as defined by 

Public Resources Code §4526), or 

timberland zoned Timberland 

Production (as defined by Government 

Code §51104 (g))?

   

d) Result in the loss of forest land or 

conversion of forest land to non-forest 

use?

   

Significance C r iter ia

Project-related impacts on agriculture and forest resources will be considered significant if any 

of the following conditions are met:

- The proposed project conflicts with existing zoning or agricultural use or Williamson Act

contracts.

- The proposed project will convert prime farmland, unique farmland or farmland of statewide 

importance as shown on the maps prepared pursuant to the farmland mapping and monitoring 

program of the California Resources Agency, to non-agricultural use.

- The proposed project conflicts with existing zoning for, or causes rezoning of, forest land (as 

defined in Public Resources Code §12220(g)), timberland (as defined in Public Resources 

Code §4526), or timberland zoned Timberland Production (as defined by Government Code 

§ 51104 (g)).
Addendum

Revision to the PM2.5 and Ozone SIP 16 February 2011

- The proposed project would involve changes in the existing environment, which due to their 

location or nature, could result in conversion of farmland to non-agricultural use or 

conversion of forest land to non-forest use.

Discussion

II. a) - c): It was concluded in the 2007 AQMP IS that control measures, which typically affect 

existing commercial or industrial facilities or establish specifications for fuels or mobile source 

exhaust emissions, are not expected to generate any new construction of buildings or other 

structures that would require conversion of farmland to non-agricultural use or conflict with 

zoning for agricultural uses or a Williamson Act contract. There are no provisions in the 2007 

AQMP that would affect or conflict with existing land use plans, policies, or regulations or 

require conversion of farmland to non-agricultural uses. Some control measures could affect

agricultural facilities and farmers (e.g., BCM-04, prohibit agricultural burning, and on-road and 

off-road mobile source control measures and MCS-05, reduce emissions from livestock wastes), 

however, these control measures are not expected to convert agricultural land uses to nonagricultural land uses. Land use, including agriculture-related uses, and other planning 

considerations are determined by local governments and no agricultural land use or planning 

requirements will be altered by the proposed project. AQMP control measures, including control 

measures related to mobile sources, would have no direct or indirect effects on agricultural 

resources. The 2007 AQMP could provide benefits to agricultural resources by reducing ozone 

emissions and, thus, reducing the adverse impacts of ozone on plants and animals. 

Emission growth management control measures may require emission reductions from new or 

redevelopment land use projects. These control measures, however, do not initiate or promote 

land use projects, they may simply require emission reductions after the decision has already 

been made to pursue new or redevelopment projects. As a result, emission growth management 

control measures are not expected to adversely affect local land use policies or result in the 

conversion of agricultural lands to non-agricultural land uses.

II. d): In March 2010, amendments to the CEQA Guidelines were finalized that added forest 

resources as a new topic in the environmental checklist to be evaluated along with agricultural 

resources. Because the 2007 AQMP Program EIR was certified in June 2007, there was no 

explicit evaluation of potential forestry resources impacts. It is expected that the 2007 AQMP 

would not generated significant adverse forestry resources impacts for the same reasons it would 

not adversely affect agricultural resources, i.e., control measures would typically affect existing 

commercial or industrial facilities or establish specifications for fuels or mobile source exhaust 

emissions, so are not expected to generate any new construction of buildings or other structures 

that would require conversion of forest resources to non-forest use or conflict with zoning for 

forestry uses. Further, there are no provisions in the proposed 2007 AQMP that would affect or 

conflict with existing land use plans, policies, or regulations or require conversion of forests to 

non-forest uses. 

Conclusion

Based upon the above considerations, it was concluded in the 2007 AQMP IS that significant 

adverse project-specific agricultural impacts would not be expected to occur due to 

implementation of the 2007 AQMP control measures. Impacts to forestry resources was added 

as an environmental topic for evaluation in 2010, after certification of the 2007 AQMP Final 

PEIR. However, it is not expected that the 2007 AQMP would create significant adverse forest 
Addendum

Revision to the PM2.5 and Ozone SIP 17 February 2011

resources impacts for the same reasons it is not expected to create significant adverse agricultural 

resources impacts.

The proposed revisions to the 2007 PM2.5 and Ozone SIP are not expected to create any new 

agriculture and forestry impacts or make substantially worse impacts identified in the 2007 

AQMP IS for the following reasons. The proposed revisions would not change any of the above 

conclusions because they do not include incorporating any new types of control measures into 

the SIP that could create new adverse agriculture and forestry impacts. Further, the proposed 

project does not contain any revisions to the substantive requirements of any 2007 AQMP 

control measures. As of January 2011, the SCAQMD has achieved 96 percent of its emissions 

reductions commitment. Although the adoption dates for some of the remaining control 

measures have been delayed, the implementation dates have not; therefore, the SCAQMD is 

expected to achieve its remaining emission reduction commitments by both 2014 and 2023, in 

part through reliance on greater than anticipated emission reductions from previously 

implemented control measures, and 2023. The SCAQMD would also commit to retaining the 

contingency control measures, including triggers for their implementation in the event that the 

PM2.5 standard is not achieved by 2015. Finally, if U.S. EPA fails to voluntarily accept the 10 

tpd emission reduction in the 2007 SIP, the SCAQMD would commit to an additional one tpd of 

NOx emission reductions in 2014 with CARB assuming the remaining nine tpd reductions of the 

federal assignment in order to continue to demonstrate attainment of all applicable standards. 

This additional one tpd commitment would not foreseeably have any different impacts than 

existing 2007 AQMP control measures. These emission reductions would most likely occur as a 

result of greater reductions obtained from adopted regulations or early implementation of control 

measures in the 2007 AQMP. There are no provisions in the proposed project that would create 

new adverse impacts or make existing agricultural or forestry resources impacts worse. 

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

III. AIR QUALITY AND 

GREENHOUSE GAS EMISSIONS 

Would the project:

a) Conflict with or obstruct implementation 

of the applicable air quality plan?

   

b) Violate any air quality standard or 

contribute to an existing or projected air 

quality violation?

   
Addendum

Revision to the PM2.5 and Ozone SIP 18 February 2011

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

c) Result in a cumulatively considerable 

net increase of any criteria pollutant for 

which the project region is nonattainment under an applicable federal 

or state ambient air quality standard 

(including releasing emissions that 

exceed quantitative thresholds for ozone 

precursors)?

   

d) Expose sensitive receptors to substantial 

pollutant concentrations?

   

e) Create objectionable odors affecting a 

substantial number of people?

   

f) Diminish an existing air quality rule or 

future compliance requirement resulting 

in a significant increase in air 

pollutant(s)? 

   

g) Generate greenhouse gas emissions, 

either directly or indirectly, that may 

have a significant impact on the 

environment?

   

h) Conflict with an applicable plan, policy 

or regulation adopted for the purpose of 

reducing the emissions of greenhouse 

gases?

   

Discussion

III. a) The IS for the 2007 AQMP concluded that implementing AQMP control measures is, in 

effect, an update of the SCAQMD’s 2003 AQMP, which is required pursuant to state law. By 

revising and updating emission inventories and control strategies, the SCAQMD is complying 

with state law, and furthering development and implementation of AQMP control measures, 

which are expected to reduce emissions and make progress towards attaining and maintaining all 

state and federal ambient air quality standards in the district. Consequently, it was concluded 

that implementing the 2007 AQMP would not create significant adverse impacts as a result of 

obstructing implementation of the applicable AQMP.

III. b) Potential adverse air quality impacts from adopting the proposed project are discussed in 

the following subsections.
Addendum

Revision to the PM2.5 and Ozone SIP 19 February 2011

Air Quality Significance Criteria

To determine whether or not air quality impacts from adopting and implementing the proposed 

project are significant, impacts will be evaluated and compared to the criteria in Table 6. The 

project will be considered to have significant adverse air quality impacts if any one of the 

thresholds in Table 6 are equaled or exceeded. 

Table 6

SCAQMD Air Quality Significance Thresholds

Mass Daily Thresholds a

Pollutant C onstr uction b Operation c

NOx 100 lbs/day 55 lbs/day

VOC 75 lbs/day 55 lbs/day

PM10 150 lbs/day 150 lbs/day

PM2.5 55 lbs/day 55 lbs/day

SOx 150 lbs/day 150 lbs/day

CO 550 lbs/day 550 lbs/day

Lead 3 lbs/day 3 lbs/day

Toxic Air Contaminants (TACs), Odor and GHG Thresholds

TACs

(including carcinogens and non-carcinogens)

Maximum Incremental Cancer Risk ≥ 10 in 1 million

Hazard Index ≥ 1.0 (project increment)

Odor Project creates an odor nuisance pursuant to SCAQMD Rule 402

GHG 10,000 metric tons per year for industrial facilities

Ambient Air Quality for Criteria Pollutants d

NO2

1-hour average

annual average

SCAQMD is in attainment; project is significant if it causes or 

contributes to an exceedance of the following attainment standards:

0.25 ppm (state – peak hour); 0.10 ppm (federal – 98th percentile)

0.053 ppm (federal)

PM10

24-hour average

annual geometric average

annual arithmetic mean

10.4 μg/m3 (construction)

e & 2.5 μg/m3 (operation)

1.0 μg/m3

20 μg/m3

PM2.5

24-hour average 10.4 μg/m3 (construction)

e & 2.5 μg/m3 (operation)

Sulfate

24-hour average 25 μg/m3

CO

1-hour average

8-hour average

SCAQMD is in attainment; project is significant if it causes or 

contributes to an exceedance of the following attainment standards:

20 ppm (state)

9.0 ppm (state/federal)

a Source: SCAQMD CEQA Handbook (SCAQMD, 1993) b Construction thresholds apply to both the South Coast Air Basin and Coachella Valley (Salton Sea and Mojave Desert Air 

Basins). 

c For Coachella Valley, the mass daily thresholds for operation are the same as the construction thresholds. d Ambient air quality thresholds for criteria pollutants based on SCAQMD Rule 1303, Table A-2 unless otherwise stated. e Ambient air quality threshold based on SCAQMD Rule 403.

KEY: lbs/day = pounds per day ppm = parts per million μg/m3 = microgram per cubic meter ≥ greater than or equal to
Addendum

Revision to the PM2.5 and Ozone SIP 20 February 2011

Construction Impacts

The analysis of air quality impacts in the PEIR for the 2007 AQMP concluded that for most air 

quality impact areas, e.g., operational secondary impacts from increased electricity demand, 

mobile sources, etc., would be less than applicable significance thresholds and, therefore, would 

not contribute to significant adverse cumulative impacts. Construction air quality impacts 

(PM10) were concluded to be significant. Nine mitigation measures were identified to reduce 

construction air quality impacts. However, the analysis concluded that implementing the nine 

mitigation measures would not reduce construction air quality impacts to less than significant. 

The proposed revisions to the 2007 PM2.5 and Ozone SIP are not expected to create any new 

construction air quality impacts or make substantially worse impacts identified in the 2007 

AQMP PEIR for the following reasons. Construction air quality impacts identified in the 2007 

AQMP PEIR were primarily the result of installing control equipment to comply with the control 

requirements in the 2007 AQMP control measures. For some types of control equipment, it may 

be necessary to use heavy-duty diesel off-road equipment and perform substantial site 

preparation. The proposed revisions to the 2007 PM2.5 and Ozone SIP do not include 

incorporating any new control measures or modifying the substantive requirements of any 2007 

AQMP control measures. Since the proposed project does include any new or modified control 

measures, no changes to the conclusions regarding construction air quality impacts from 

implementing the 2007 AQMP control measures are anticipated.

Operational Impacts

The analysis of operational air quality impacts in the 2007 AQMP PEIR concluded that, overall, 

implementing 2007 AQMP control measures would produce beneficial air quality benefits 

through reducing emissions from stationary and on-road and off-road sources. 

As of January 2011, the SCAQMD has achieved 96 percent of its emissions reductions 

commitment. Although the adoption dates for some of the remaining control measures have 

been delayed, the implementation dates have not; therefore, the SCAQMD is expected to achieve 

its remaining emission reduction commitments by both 2014 and 2023, in part, through reliance 

on greater than anticipated emission reductions from previously implemented control measures. 

Further, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. The 

proposed revisions would not change any of the above conclusions because they do not include 

incorporating any new types of control measures into the SIP that could create new adverse air 

quality impacts. Further, the proposed project does not contain any revisions to the substantive 

requirements of any 2007 AQMP control measures. 

Consequently, the proposed project would not create significant adverse construction air quality 

impacts or substantially contribute to significant adverse project-specific or cumulative 

construction air quality impacts identified in the PEIR for the 2007 AQMP.
Addendum

Revision to the PM2.5 and Ozone SIP 21 February 2011

III. c) As noted in the discussions of construction and operational air quality impacts in item III. 

b) above, the proposed project would not create any construction or operational air quality 

impacts not already evaluated in the 2007 AQMP. Specifically, no new or additional 

construction activities to install control equipment to comply with the proposed project would be 

required because the proposed project does not include any new or modified control measures. 

As a result, construction air quality impacts from the proposed project are not considered to be 

cumulatively considerable and, therefore, are concluded to be cumulatively insignificant. The 

proposed revisions do not include incorporating any new control measures into the SIP that could 

create new adverse cumulative air quality impacts. Further, the proposed project does not 

contain any revisions to the substantive requirements of any 2007 AQMP control measures. 

The analysis of air quality impacts in the PEIR for the 2007 AQMP concluded that for most air 

quality impact areas, e.g., operational secondary impacts from increased electricity demand, 

mobile sources, etc., would be less than applicable significance thresholds and, therefore, would 

not contribute to significant adverse cumulative impacts. Implementing the currently proposed 

project is not expected to create significant adverse cumulative operational air quality impacts or 

to change the conclusion regarding cumulative impacts in the PEIR for the 2007 AQMP in any 

way. 

III. d) Potential air quality impacts from exposing sensitive receptors to substantial criteria 

pollutant and air toxic concentrations were evaluated in the Program EIR for the 2007 AQMP.

In general, the modeling performed for the 2007 AQMP showed improvements, i.e., declining 

concentrations, from the baseline year (2005) compared to future milestone years (2015 and 

2024) for all criteria pollutants, VOC, and air toxics emissions.

As of January 2011, the SCAQMD has achieved 96 percent of its emissions reductions 

commitment. Although the adoption dates for some of the remaining control measures have 

been delayed, the implementation dates have not; therefore, the SCAQMD is expected to achieve 

its remaining emission reduction commitments by both 2014 and 2023, in part, through reliance 

on greater than anticipated emission reductions from previously implemented control measures. 

Further, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. The proposed revisions would not change 

any of the above conclusions because they do not include incorporating any new types of control 

measures into the SIP that could create new adverse air quality impacts that could expose 

sensitive receptors to substantial pollutant concentrations. Further, the proposed project does not 

contain any revisions to the substantive requirements of any 2007 AQMP control measures. 

Consequently, the proposed project would not create significant adverse air quality impacts from 

exposing sensitive receptors to substantial criteria pollutant and air toxic concentrations or 

change any of the conclusions regarding potential impacts to sensitive receptors evaluated in the 

Program EIR for the 2007 AQMP.

III. e) The IS for the 2007 AQMP concluded that implementing AQMP control measures 

would not create significant adverse odor impacts for the following reasons. Promulgation of 

AQMP control measures into rules or regulations may involve reformulated coatings or solvents, 

which may have noticeable odors. It is typically the case, however, that reformulated products 
Addendum

Revision to the PM2.5 and Ozone SIP 22 February 2011

have less noticeable odors than the products they are replacing. Reformulated products tend to 

have reduced VOC content and reduced emissions and, therefore, fewer potential odors. As a 

result, significant adverse odor impacts have not been associated with reformulated products 

compared to conventional high VOC products. However, owners/operators of industries affected 

by control measures in the proposed 2007 AQMP would still be subject to existing air quality 

rules and regulations, including SCAQMD's Rule 402 - Nuisance, which prohibits creating odor 

nuisances. For these reasons, implementing the 2007 AQMP is not expected to create significant 

adverse odor impacts and, therefore, will not be further addressed in the Draft PEIR. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse odor impacts. Further, the proposed project does not contain any revisions to the 

substantive requirements of any 2007 AQMP control measures that generate odor impacts. 

II. f) The 2007 AQMP contains control measures that are expected to bring the district into 

compliance with all ambient air quality standards as required by the federal and California Clean 

Air Acts. For this reason the IS for the 2007 AQMP concluded that implementing AQMP 

control measures would not create significant adverse impacts by diminishing existing air quality 

rules or future compliance requirements. The currently proposed revisions do not include 

incorporating any new control measures into the SIP that could diminish existing rules or future 

compliance requirements. Although the adoption schedule for some control measures would be 

delayed, the implementation dates and associated emission reductions would not be delayed. 

Finally, The proposed project does not contain any revisions to the substantive requirements of 

any 2007 AQMP control measures. 

III. g) & h) Global warming is the observed increase in average temperature of the earth’s 

surface and atmosphere. The primary cause of global warming is an increase of GHG emissions 

in the atmosphere. The six major types of GHG emissions identified in the Kyoto Protocol and 

in CARB’s RMP regulation are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), 

sulfur hexafluoride (SF6), hydrofluorocarbons (HFCs), and perfluorocarbons (PFCs). The GHG 

emissions absorb longwave radiant energy emitted by the earth, which warms the atmosphere. 

The GHGs also emit longwave radiation both upward to space and back down toward the surface 

of the earth. The downward part of this longwave radiation emitted by the atmosphere is known 

as the "greenhouse effect."

The current scientific consensus is that the majority of the observed warming over the last 50 

years can be attributable to increased concentration of GHG emissions in the atmosphere due to 

human activities. Events and activities, such as the industrial revolution and the increased 

consumption of fossil fuels (e.g., combustion of gasoline, diesel, coal, etc.), have heavily 

contributed to the increase in atmospheric levels of GHG emissions. As reported by the 

California Energy Commission (CEC), California contributes 1.4 percent of the global and 6.2 

percent of the national GHG emissions (CEC, 2004). Further, approximately 80 percent of GHG 

emissions in California are from fossil fuel combustion (e.g., gasoline, diesel, coal, etc.).

The 2007 AQMP did not include any control measures that specifically address controlling 

GHGs. However, reducing certain criteria pollutants, especially combustion pollutants, has the 

potential of generating substantial GHG emission reduction co-benefits. For example, 

SCAQMD staff evaluated the GHG emission reduction potential of four control measures and 
Addendum

Revision to the PM2.5 and Ozone SIP 23 February 2011

concluded that by 2020, they have the potential of reducing over 1.5 million metric tons of CO2 

emissions. This analysis did not include potential N2O or CH4 GHG emission reductions, nor 

did it include an evaluation of other 2007 AQMP control measures that may have GHG emission 

reduction co-benefits.

The proposed revisions to the 2007 AQMP do not include incorporating any new control 

measures into the SIP that could create new adverse GHG emission reduction impacts. Further, 

the proposed project does not contain any revisions to the substantive requirements of any 2007 

AQMP control measures that could limit their effectiveness in reducing GHG emissions. 

Conclusion

It was concluded in the PEIR for 2007 AQMP that implementing AQMP control measures could 

result in significant adverse construction air quality impacts (PM10), while operational air 

quality impacts were concluded to be less than significant. 

The proposed revisions to the 2007 PM2.5 and Ozone SIP are not expected to create any new air 

impacts or make substantially worse impacts identified in the 2007 AQMP for the following 

reasons. The proposed revisions would not change any of the above conclusions because they do 

not include incorporating any new types of control measures into the SIP that could create new 

adverse air quality impacts. Further, the proposed project does not contain any revisions to the 

substantive requirements of any 2007 AQMP control measures. As of January 2011, the 

SCAQMD has achieved 96 percent of its emissions reductions commitment. Although the 

adoption dates for some of the remaining control measures have been delayed, the 

implementation dates have not; therefore, the SCAQMD is expected to achieve its remaining 

emission reduction commitments by both 2014 and 2023, in part, through reliance on greater 

than anticipated emission reductions from previously implemented control measures. The 

SCAQMD would also commit to retaining the contingency control measures, including triggers 

for their implementation in the event that the PM2.5 standard is not achieved by 2015. Finally, if 

U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing air quality impacts worse.
Addendum

Revision to the PM2.5 and Ozone SIP 24 February 2011

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

IV. BIOLOGICAL RESOURCES. 

Would the project:

a) Have a substantial adverse effect, 

either directly or through habitat 

modifications, on any species 

identified as a candidate, sensitive, or 

special status species in local or 

regional plans, policies, or regulations, 

or by the California Department of 

Fish and Game or U.S. Fish and 

Wildlife Service?

   

b) Have a substantial adverse effect on 

any riparian habitat or other sensitive 

natural community identified in local 

or regional plans, policies, or 

regulations, or by the California 

Department of Fish and Game or U.S. 

Fish and Wildlife Service?

   

c) Have a substantial adverse effect on 

federally protected wetlands as 

defined by §404 of the Clean Water 

Act (including, but not limited to, 

marsh, vernal pool, coastal, etc.) 

through direct removal, filling, 

hydrological interruption, or other 

means?

   

d) Interfere substantially with the 

movement of any native resident or 

migratory fish or wildlife species or 

with established native resident or 

migratory wildlife corridors, or 

impede the use of native wildlife 

nursery sites?

   

e) Conflicting with any local policies or 

ordinances protecting biological 

resources, such as a tree preservation 

policy or ordinance? 

   
Addendum

Revision to the PM2.5 and Ozone SIP 25 February 2011

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

f) Conflict with the provisions of an 

adopted Habitat Conservation plan, 

Natural Community Conservation 

Plan, or other approved local, regional, 

or state habitat conservation plan? 

   

Significance Criteria

Impacts on biological resources will be considered significant if any of the following criteria 

apply:

- The project results in a loss of plant communities or animal habitat considered to be rare, 

threatened or endangered by federal, state or local agencies.

- The project interferes substantially with the movement of any resident or migratory wildlife 

species.

- The project adversely affects aquatic communities through construction or operation of the 

project.

Discussion

IV. a), b), & d) In the 2007 AQMP IS, no direct or indirect impacts from implementing AQMP 

control measures were identified that could adversely affect plant and/or animal species in the 

district. The effects of implementing AQMP control measures would typically result in reducing 

mobile source exhaust emissions, modifying fuel specifications, or modifications at existing 

commercial or industrial facilities to control or further control emissions. Such existing 

commercial or industrial facilities are generally located in appropriately zoned commercial or 

industrial areas, which typically do not support candidate, sensitive, or special status species in 

local or regional plans, policies, or regulations, or by the California Department of Fish and 

Game or U.S. Fish and Wildlife Service. Similarly, modifications at existing facilities would not 

interfere substantially with the movement of any native resident or migratory fish or wildlife 

species or with native or resident or migratory wildlife corridors, or impede the use of native 

wildlife nursery sites. Further, since some control measures in the 2007 AQMP regulate 

stationary emission sources at existing commercial or industrial facilities, they do not directly or 

indirectly affect land use policy that may adversely affect riparian habitat or other sensitive 

natural communities identified in local or regional plans, policies, or regulations, or identified by 

the California Department of Fish and Game or U.S. Fish and Wildlife Service. Improving air 

quality is expected to provide health benefits to plant and animal species in the district. There 

are no control measures contained in the proposed project that would alter this determination.

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse biological resources impacts to plant and/or animal species in the district. Further, the 

proposed project does not contain any revisions to the substantive requirements of any 2007 

AQMP control measures that could adversely affect biological resources. 
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Revision to the PM2.5 and Ozone SIP 26 February 2011

IV. c) As noted in the previous item, promulgating control measures in the 2007 AQMP may 

require modifications at existing industrial or commercial facilities to control or further control 

emissions at these affected facilities. Similarly, the 2007 AQMP contains control measures that 

establish emission standards for mobile sources, result in additional control of emissions from 

mobile sources, or revise fuel specifications. As a result, the proposed project will not affect 

land use policies or designations. Some control measures could result in the installation of 

additional controls at port facilities, which are located on the coast. However, the port facilities 

are considered to be heavy industrial facilities and the installation of additional controls would be 

consistent with this land use. For these reasons the proposed project will not adversely affect 

protected wetlands as defined by §404 of the Clean Water Act, including, but not limited to 

marshes, vernal pools, coastal wetlands, etc., through direct removal, filling, hydrological 

interruption or other means.

IV. e) & f) Implementing the 2007 AQMP is not expected to affect land use plans, local policies 

or ordinances, or regulations protecting biological resources such as a tree preservation policy or 

ordinance for the reasons already given, i.e. control measures promulgated as rules or regulations 

primarily affect existing facilities located in appropriately zoned areas or establish emission 

standards for mobile sources or fuel specifications. Land use and other planning considerations 

are determined by local governments and no land use or planning requirements will be altered by 

the proposed project. Similarly, the proposed amendments to the 2007 PM2.5 and Ozone SIP are

not expected to affect in any way habitat conservation or natural community conservation plans, 

agricultural resources or operations, and would not create divisions in any existing communities.

Conclusion

It was concluded in the 2007 AQMP IS that significant adverse project-specific biological 

resources impacts would not be expected to occur due to implementation of the 2007 AQMP 

control measures. Based upon the above considerations, it is concluded that the proposed 

revisions to the 2007 PM2.5 and Ozone SIP are not expected to create any new biological 

resources impacts or make substantially worse impacts identified in the 2007 AQMP for the 

following reasons. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse biological resources impacts. Further, the proposed project does not contain any 

revisions to the substantive requirements of any 2007 AQMP control measures. As of January 

2011, the SCAQMD has achieved 96 percent of its emissions reductions commitment. Although 

the adoption dates for some of the remaining control measures have been delayed, the 

implementation dates have not; therefore, the SCAQMD is expected to achieve its remaining 

emission reduction commitments by both 2014 and 2023, in part, through reliance on greater 

than anticipated emission reductions from previously implemented control measures. Therefore, 

emission reduction benefits to biological resources would be expected to occur on the same 

schedule as projected in the 2007 AQMP Final PEIR.

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 
Addendum

Revision to the PM2.5 and Ozone SIP 27 February 2011

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing biological resources impacts worse. 

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

V. CULTURAL RESOURCES. Would 

the project:

a) Cause a substantial adverse change in 

the significance of a historical 

resource as defined in §15064.5?

   

b) Cause a substantial adverse change in 

the significance of an archaeological 

resource as defined in §15064.5?

   

c) Directly or indirectly destroy a unique 

paleontological resource, site, or 

feature?

   

d) Disturb any human remains, including 

those interred outside formal 

cemeteries?

   

Significance Criteria

Impacts to cultural resources will be considered significant if:

- The project results in the disturbance of a significant prehistoric or historic archaeological 

site or a property of historic or cultural significance to a community or ethnic or social group.

- Unique paleontological resources are present that could be disturbed by construction of the 

proposed project.

- The project would disturb human remains.

Discussion

V. a), b), c), & d) As noted in the IS for the 2007 AQMP, implementing the 2007 AQMP

control measures is primarily expected to result in controlling stationary source emissions at 

existing commercial or industrial facilities, establish emission standards for mobile sources, or 

establish fuel standards. Affected facilities where physical modifications may occur are typically 

located in appropriately zoned commercial or industrial areas that have previously been 

disturbed. Because potentially affected facilities are existing facilities and controlling stationary 

source emissions does not typically require extensive cut-and-fill activities or excavation, it is 

unlikely that implementing control measures in the proposed 2007 AQMP will: adversely affect 
Addendum

Revision to the PM2.5 and Ozone SIP 28 February 2011

historical or archaeological resources as defined in CEQA Guidelines §15064.5, destroy unique 

paleontological resources or unique geologic features, or disturb human remains interred outside 

formal cemeteries.

Emission growth management control measures may require emission reductions from new or 

redevelopment land use projects. These control measures, however, do not initiate or promote 

land use projects, they may simply require emission reductions after the decision has already 

been made to pursue new or redevelopment projects. As a result, emission growth management 

control measures are not expected to adversely affect local land use policies or create addition 

development that would impact cultural resources.

Conclusion

It was concluded in the 2007 AQMP IS that significant adverse project-specific cultural 

resources impacts would not be expected to occur due to implementation of the 2007 AQMP 

control measures. Based upon the above considerations, it is concluded that the proposed 

revisions to the 2007 PM2.5 and Ozone SIP are not expected to create any new cultural resources 

impacts or make substantially worse impacts identified in the 2007 AQMP for the following 

reasons. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse cultural resources impacts. Further, the proposed project does not contain any revisions 

to the substantive requirements of any 2007 AQMP control measures. As of January 2011, the 

SCAQMD has achieved 96 percent of its emissions reductions commitment. Although the 

adoption dates for some of the remaining control measures have been delayed, the 

implementation dates have not; therefore, the SCAQMD is expected to achieve its remaining 

emission reduction commitments by both 2014 and 2023, in part, through reliance on greater 

than anticipated emission reductions from previously implemented control measures. Therefore, 

emission reduction benefits to cultural resources (e.g., improving air quality reduces the 

destructive effects of ozone on culturally significant structures) would be expected to occur on 

the same schedule as projected in the 2007 AQMP Final PEIR.

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing cultural resources impacts worse.
Addendum

Revision to the PM2.5 and Ozone SIP 29 February 2011

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

VI. ENERGY. Would the project:

a) Conflict with adopted energy 

conservation plans? 

   

b) Result in the need for new or 

substantially altered power or natural 

gas utility systems? 

   

c) Create any significant effects on local 

or regional energy supplies and on 

requirements for additional energy? 

   

d) Create any significant effects on peak 

and base period demands for 

electricity and other forms of energy? 

   

e) Comply with existing energy 

standards? 

   

Significance Criteria

Impacts to energy and mineral resources will be considered significant if any of the following 

criteria are met:

- The project conflicts with adopted energy conservation plans or standards.

- The project results in substantial depletion of existing energy resource supplies.

- An increase in demand for utilities impacts the current capacities of the electric and natural 

gas utilities.

- The project uses non-renewable resources in a wasteful and/or inefficient manner.

Discussion

VI. a) & e) It was concluded in the 2007 AQMP IS that AQMP control measures are not 

anticipated to result in any conflicts with adopted energy conservation plans or violations of any 

energy conservation standards by affected facilities. In some cases facilities complying with 

2007 AQMP control measures may need to install various types of control equipment, which 

could potentially increase energy demand in the district. It is expected, however, that 

owners/operators of affected facilities would comply with any applicable energy conservation 

standards in effect at the time of installation. Alternatively, implementing the proposed 2007 

AQMP may result in owners/operators of affected facilities replacing old inefficient equipment 

with newer more energy efficient equipment (e.g., MCS-01, Facility Modernization and MCS03, Energy Efficiency and Conservation), thus providing beneficial impacts on energy demand. 

Based upon these considerations, however, the net effect of implementing the 2007 AQMP is 

that it is not expected to conflict with any adopted energy conservation plans or energy 

efficiency standards. The proposed project does not contain any revisions to the substantive 
Addendum

Revision to the PM2.5 and Ozone SIP 30 February 2011

requirements of any remaining 2007 AQMP control measures and is not expected to change this 

conclusion in any way. Similarly, the proposed revisions would not change any of the above 

conclusions because they do not include incorporating any new types of control measures into 

the SIP that could create new adverse impacts. Further, the proposed project does not contain 

any revisions to the substantive requirements of any 2007 AQMP control measures that would 

conflict with adopted energy conservation plans or violate any energy conservation standards by 

affected facilities. 

VI. b), c), & d) The IS for the 2007 AQMP indicated that 2007 AQMP control measures may

interfere with energy conservation efforts in the district. Further, implementing some AQMP 

control measures could increase energy demand in the region at affected facilities. As a result, 

these topics were further analyzed in the PEIR. The analysis concluded that energy impacts as a 

result of implementing control measures in the 2007 AQMP would not be significant for the 

following reasons. Although implementing AQMP control measures may increase demand for 

electricity, natural gas, and alternative fuels, it is expected that local utilities have the capacity to 

supply future demand. Further, installing new less polluting and more efficient equipment as a 

result of complying with AQMP control measures may provide beneficial reductions in future 

demand. Finally, greater reliance on electricity, natural gas, and alternative fuels would reduce 

demand for other fossil fuels. The proposed project does not contain any revisions to the 

substantive requirements of any remaining 2007 AQMP control measures and is not expected to 

change this conclusion in any way. Similarly, the proposed revisions do not include 

incorporating any new control measures into the SIP that could create new adverse impacts to 

energy supplies or energy production facilities. 

Conclusion

It was concluded in the 2007 AQMP IS that significant adverse project-specific energy impacts 

may occur due to implementation of the 2007 AQMP control measures. Further analysis in the 

2007 AQMP Final PEIR of potential energy impacts from implementing 2007 AQMP control 

measures concluded that impacts to energy conservation programs, energy supplies, and energy 

production facilities would be less than significant. Based upon the above considerations, it is 

concluded that the proposed revisions to the 2007 PM2.5 and Ozone SIP are not expected to 

create any new impacts or make substantially worse impacts to energy conservation programs, 

energy supplies, and energy production facilities identified in the 2007 AQMP for the following 

reasons. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse impacts to energy conservation programs, energy supplies, and energy production 

facilities. Further, the proposed project does not contain any revisions to the substantive 

requirements of any 2007 AQMP control measures. As of January 2011, the SCAQMD has 

achieved 96 percent of its emissions reductions commitment. Although the adoption dates for 

some of the remaining control measures have been delayed, the implementation dates have not; 

therefore, the SCAQMD is expected to achieve its remaining emission reduction commitments 

by both 2014 and 2023, in part, through reliance on greater than anticipated emission reductions 

from previously implemented control measures. Therefore, potential non-significant energy 

impacts from implementing 2007 AQMP control measures would be expected to occur on the 

same schedule as projected in the 2007 AQMP Final PEIR.
Addendum

Revision to the PM2.5 and Ozone SIP 31 February 2011

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing impacts to energy conservation programs, energy supplies, and energy production 

facilities worse.

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

VII. GEOLOGY AND SOILS. Would 

the project:

a) Expose people or structures to 

potential substantial adverse effects, 

including the risk of loss, injury, or 

death involving:

   

• Rupture of a known earthquake 

fault, as delineated on the most 

recent Alquist-Priolo Earthquake 

Fault Zoning Map issued by the 

State Geologist for the area or 

based on other substantial 

evidence of a known fault?

   

• Strong seismic ground shaking?    

• Seismic–related ground failure, 

including liquefaction?

   

b) Result in substantial soil erosion or the 

loss of topsoil?

   

c) Be located on a geologic unit or soil 

that is unstable or that would become 

unstable as a result of the project, and 

potentially result in on- or off-site 

landslide, lateral spreading, 

subsidence, liquefaction or collapse?

   
Addendum

Revision to the PM2.5 and Ozone SIP 32 February 2011

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

d) Be located on expansive soil, as 

defined in Table 18-1-B of the 

Uniform Building Code (1994), 

creating substantial risks to life or 

property?

   

e) Have soils incapable of adequately 

supporting the use of septic tanks or 

alternative wastewater disposal 

systems where sewers are not 

available for the disposal of 

wastewater?

   

Significance Criteria

Impacts on the geological environment will be considered significant if any of the following 

criteria apply:

- Topographic alterations would result in significant changes, disruptions, displacement, 

excavation, compaction or over covering of large amounts of soil.

- Unique geological resources (paleontological resources or unique outcrops) are present that 

could be disturbed by the construction of the proposed project.

- Exposure of people or structures to major geologic hazards such as earthquake surface 

rupture, ground shaking, liquefaction or landslides.

- Secondary seismic effects could occur which could damage facility structures, e.g., 

liquefaction.

- Other geological hazards exist which could adversely affect the facility, e.g., landslides, 

mudslides.

Discussion

VII. a), c) & d) It was concluded in the 2007 AQMP IS that the control measures will not 

directly or indirectly expose people or structures to earthquake faults, seismic shaking, seismicrelated ground failure including liquefaction, landslides, mudslides or substantial soil erosion for 

the following reasons. When implemented as rules or regulations, AQMP control measures do 

not directly or indirectly result in construction of new structures. Some structural modifications

at existing affected facilities may occur as a result of installing control equipment or making 

process modifications. In any event, existing affected facilities or modifications to existing 

facilities would be required to comply with relevant Uniform Building Code requirements in 

effect at the time of initial construction or modification of a structure.

New structures must be designed to comply with the Uniform Building Code Zone 4 

requirements since the district is located in a seismically active area. The local cities or counties 
Addendum

Revision to the PM2.5 and Ozone SIP 33 February 2011

are responsible for assuring that projects comply with the Uniform Building Code as part of the 

issuance of the building permits and can conduct inspections to ensure compliance. The 

Uniform Building Code is considered to be a standard safeguard against major structural failures 

and loss of life. The goal of the Code is to provide structures that will: (1) resist minor 

earthquakes without damage; (2) resist moderate earthquakes without structural damage but with 

some non-structural damage; and (3) resist major earthquakes without collapse but with some 

structural and non-structural damage. 

The Uniform Building Code bases seismic design on minimum lateral seismic forces ("ground 

shaking"). The Uniform Building Code requirements operate on the principle that providing 

appropriate foundations, among other aspects, helps to protect buildings from failure during 

earthquakes. The basic formulas used for the Uniform Building Code seismic design require 

determination of the seismic zone and site coefficient, which represents the foundation 

conditions at the site. 

Any potentially affected facilities that are located in areas where there has been historic 

occurrence of liquefaction, e.g., coastal zones, or existing conditions indicate a potential for 

liquefaction, including expansive or unconsolidated granular soils and a high water table, may 

have the potential for liquefaction-induced impacts at the project sites. The Uniform Building 

Code requirements consider liquefaction potential and establish more stringent requirements for 

building foundations in areas potentially subject to liquefaction. Therefore, compliance with the 

Uniform Building Code requirements is expected to minimize the potential impacts associated 

with liquefaction. The issuance of building permits from the local cities or counties will assure 

compliance with the Uniform Building Code requirements. Therefore, no significant impacts 

from liquefaction are expected and this potential impact will not be considered further.

Because facilities affected by any AQMP control measures are typically located in industrial or 

commercial areas, which are not typically located near known geological hazards (e.g., landslide, 

mudflow, seiche, tsunami or volcanic hazards), no significant adverse geological impacts are 

expected. Tsunamis at the ports, i.e., Port of Los Angeles and Port of Long Beach, are not 

expected because the ports are surrounded by breakwaters that protect the area from wave action. 

In any event, AQMP control measures will not increase potential exposures to tsunamis. The 

proposed project does not contain any revisions to the substantive requirements of any remaining 

2007 AQMP control measures and is not expected to change this conclusion in any way. 

Similarly, the proposed revisions do not include incorporating any new control measures into the 

SIP that could create new adverse geological hazards impacts. 

VII. b) Although the 2007 AQMP control measures may require modifications at existing 

industrial or commercial facilities, it was concluded in the IS for the 2007 AQMP that such 

modifications are not expected to require substantial grading or construction activities. Soil 

stabilization methods and paving of unpaved areas could be required under control measure 

BCM-02 which would further reduce PM10 emissions from paved and unpaved roads. Soil 

compaction or over covering with a hard-ground cover such as asphalt or concrete pavement 

could contribute to surface water erosion of soils in areas adjacent to paved or other impervious 

surface areas. However, these potential impacts from paving of unpaved roads are not 

anticipated from the 2007 AQMP. Further, the control measure (BCM-02) is expected to reduce 

wind erosion of soil. The proposed project does not have the potential to substantially increase 

the area subject to compaction or overcovering since the subject areas would be limited in size 
Addendum

Revision to the PM2.5 and Ozone SIP 34 February 2011

and, typically, have already been graded or displaced in some way (e.g., shoulders of roadways). 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse soil or erosion impacts. 

VII. e) Septic tanks or other similar alternative waste water disposal systems are typically 

associated with small residential projects in remote areas. As noted in the IS for the 2007 

AQMP, the 2007 AQMP does not contain any control measures that generate construction of 

residential projects in remote areas. AQMP control measures typically affect existing industrial 

or commercial facilities that are already hooked up to appropriate sewerage facilities. The 

proposed project does not contain any revisions to the substantive requirements of any remaining 

2007 AQMP control measures and is not expected to change this conclusion in any way. 

Similarly, the proposed revisions do not include incorporating any new control measures into the 

SIP that require alternative wastewater treatment equipment. 

Conclusion

It was concluded in the 2007 AQMP IS that significant adverse project-specific geology and 

soils impacts would not be expected to occur due to implementation of the 2007 AQMP control 

measures. Based upon the above considerations, it is concluded that the proposed revisions to 

the 2007 PM2.5 and Ozone SIP are not expected to create any new geology or soils impacts or 

make substantially worse impacts identified in the 2007 AQMP for the following reasons. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse geology or soils impacts. Further, the proposed project does not contain any revisions to 

the substantive requirements of any 2007 AQMP control measures. As of January 2011, the 

SCAQMD has achieved 96 percent of its emissions reductions commitment. Although the 

adoption dates for some of the remaining control measures have been delayed, the 

implementation dates have not; therefore, the SCAQMD is expected to achieve its remaining 

emission reduction commitments by both 2014 and 2023, in part, through reliance on greater 

than anticipated emission reductions from previously implemented control measures. 

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing geology or soils impacts worse.
Addendum

Revision to the PM2.5 and Ozone SIP 35 February 2011

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

VIII.HAZARDS AND HAZARDOUS 

MATERIALS. Would the project:

a) Create a significant hazard to the 

public or the environment through the 

routine transport, use, and disposal of 

hazardous materials?

   

b) Create a significant hazard to the 

public or the environment through 

reasonably foreseeable upset 

conditions involving the release of 

hazardous materials into the 

environment?

   

c) Emit hazardous emissions, or handle 

hazardous or acutely hazardous 

materials, substances, or waste within 

one-quarter mile of an existing or 

proposed school?

   

d) Be located on a site which is included 

on a list of hazardous materials sites 

compiled pursuant to Government 

Code §65962.5 and, as a result, would 

create a significant hazard to the 

public or the environment?

   

e) For a project located within an airport 

land use plan or, where such a plan has 

not been adopted, within two miles of 

a public use airport or a private 

airstrip, would the project result in a 

safety hazard for people residing or 

working in the project area?

   

f) Impair implementation of or 

physically interfere with an adopted 

emergency response plan or 

emergency evacuation plan?

   

g) Expose people or structures to a 

significant risk of loss, injury or death 

involving wildland fires, including 

where wildlands are adjacent to 

urbanized areas or where residences 

are intermixed with wildlands?

   
Addendum

Revision to the PM2.5 and Ozone SIP 36 February 2011

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

h) Significantly increased fire hazard in 

areas with flammable materials?

   

Significance Criteria

Impacts associated with hazards will be considered significant if any of the following occur:

- Non-compliance with any applicable design code or regulation.

- Non-conformance to National Fire Protection Association standards.

- Non-conformance to regulations or generally accepted industry practices related to operating 

policy and procedures concerning the design, construction, security, leak detection, spill 

containment or fire protection.

- Exposure to hazardous chemicals in concentrations equal to or greater than the Emergency 

Response Planning Guideline (ERPG) 2 levels.

Discussion

VIII. a), b) & c) The 2007 AQMP PEIR indicated that the 2007 AQMP control measures have 

the potential to create direct or indirect hazard impacts in several ways, including potential 

hazardous impacts that may result from the reformulation of products with materials that are low 

or exempt VOC materials, ammonia use in selective catalytic reduction equipment, use of fuel 

additives, etc., could generate significant offsite hazard impacts. The analysis of hazard impacts 

concluded that only potential impacts from modifications at refineries to produce a modified 

CARB Phase 3 gasoline (ONRD-03) and/or reformulated diesel fuel (ONRD-07) that could 

require equipment modifications or new equipment could generate significant offsite hazard 

impacts. One mitigation measure was identified to reduce this significant hazard impact, but 

hazard impacts remained significant. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new significant adverse hazardous materials impacts or make 

existing significant hazardous materials impacts substantially worse. 

VIII. d) Government Code §65962.5 typically refers to a list of facilities that may be subject to 

Resource Conservation and Recovery Act (RCRA) permits or site cleanup activities. For any 

facilities affected by control measures that are on the list, it is anticipated that they would be required 

to manage any and all hazardous materials in accordance with federal, state and local regulations. 

According to the IS for the 2007 AQMP, implementing AQMP control measures is not expected to 

interfere with site cleanup activities or create additional site contamination. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could interfere with a facility listed on Government Code §65962.5 complying 
Addendum

Revision to the PM2.5 and Ozone SIP 37 February 2011

with site cleanup activities that could create new significant adverse impacts or make existing site 

contamination impacts substantially worse.

VIII. e) According to the IS for the 2007 AQMP, implementing AQMP control measures is not 

expected to adversely affect any airport land use plan or result in any safety hazard for people 

residing or working in the district. U.S. Department of Transportation – Federal Aviation 

Administration Advisory Circular AC 70/7460-2K provides information regarding the types of 

projects that may affect navigable airspace. Projects that involve construction or alteration of 

structures greater than 200 feet above ground level within a specified distance from the nearest 

runway; objects within 20,000 feet of an airport or seaplane base with at least one runway more 

than 3,200 feet in length and the object would exceed a slope of 100:1 horizontally (100 feet 

horizontally for each one foot vertically from the nearest point of the runway); etc., may 

adversely affect navigable airspace. Control measures in the 2007 AQMP are not expected to 

require construction of tall structures near airports so potential impacts to airport land use plans 

or safety hazards to people residing or working in the vicinity of local airports are not 

anticipated. These controls are expected to establish emission standards or increase the use of 

electrical equipment, but are not expected to interfere with airport activities. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new significant adverse safety hazard impacts or make existing 

safety hazard impacts for people living and working within the vicinity of public or private 

airports substantially worse.

VIII. f) According to the IS for the 2007 AQMP, implementing AQMP control measures is not 

expected to interfere with any emergency response procedures or evacuation plans. Operators of 

any existing commercial or industrial facilities affected by the AQMP control measures will 

typically have their own emergency response plans for their facilities already in place. 

Emergency response plans are typically prepared in coordination with the local city or county 

emergency plans to ensure the safety of not only the public, but the facility employees as well. 

The implementation of certain control measures could result in the need for additional storage of 

hazardous materials (e.g., ammonia). Such modifications may require revisions to emergency 

response plans if new hazardous are introduced to a facility. However, these modifications 

would not be expected to interfere with emergency response procedures and would not impair 

implementation of, or physically interfere with any adopted emergency response plan or 

emergency evacuation plan. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new significant adverse impacts or make existing impacts to 

business emergency response plans substantially worse.

VIII. g) Control measures in the 2007 AQMP would typically affect existing commercial or 

industrial facilities in appropriately zoned areas. Since commercial and industrial areas are not 

typically located near wildland or forested areas, according to the IS prepared for the 2007 
Addendum

Revision to the PM2.5 and Ozone SIP 38 February 2011

AQMP, implementing AQMP control measures has no potential to increase the risk of wildland 

fires. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new significant adverse wildland fire impacts or make existing 

wildland fire impacts by substantially worse.

VIII. h) The 2007 AQMP IS concluded that some control measures in the 2007 AQMP that 

require add-on control equipment or reformulated products may increase potential fire hazards in 

areas with flammable materials and may be a potentially significant impact. The PEIR, however, 

concluded that potential fire hazard impacts would be less than significant through complying 

with applicable laws and regulations regarding storage, handling and transport of flammable 

materials. Further, increased use of some types of flammable substances, e.g., alternative fuels, 

would result in a commensurate reduction in other types of flammable substances e.g., fossil 

fuels.

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new significant adverse flammability impacts or make existing 

flammability impacts substantially worse.

Conclusion

With the exception of accidental releases of hazardous materials it was concluded in the 2007 

AQMP Final PEIR that significant adverse project-specific hazards and hazardous materials 

impacts could occur due to implementation of the 2007 AQMP control measures. One 

mitigation measure was identified to reduce significant hazardous materials impacts, but impacts 

remained significant. It was concluded in the 2007 AQMP IS that significant adverse projectspecific hazards or hazardous materials impacts would not be expected to occur due to 

implementation of the 2007 AQMP control measures. Based upon the above considerations, it is 

concluded that the proposed revisions to the 2007 PM2.5 and Ozone SIP are not expected to 

create any new hazards or hazardous materials impacts or make substantially worse impacts 

identified in the 2007 AQMP for the following reasons. Further, the IS for the 2007 AQMP 

concluded that implementing 2007 AQMP control measures would not create other types of 

hazard or hazardous materials impacts such as interfering with site cleanup, increasing the 

potential for wildfires, increasing flammability impacts, etc.

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. As of January 2011, the SCAQMD has achieved 96 percent of its emissions reductions 

commitment. Although the adoption dates for some of the remaining control measures have 

been delayed, the implementation dates have not; therefore, the SCAQMD is expected to achieve 

its remaining emission reduction commitments by both 2014 and 2023, in part, through reliance 

on greater than anticipated emission reductions from previously implemented control measures. 
Addendum

Revision to the PM2.5 and Ozone SIP 39 February 2011

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing hazards or hazardous materials impacts worse.

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

IX. HYDROLOGY AND WATER 

QUALITY. Would the project:

a) Violate any water quality standards, 

waste discharge requirements, exceed 

wastewater treatment requirements of 

the applicable Regional Water Quality 

Control Board, or otherwise 

substantially degrade water quality?

   

b) Substantially deplete groundwater 

supplies or interfere substantially with 

groundwater recharge such that there 

would be a net deficit in aquifer 

volume or a lowering of the local 

groundwater table level (e.g. the 

production rate of pre-existing nearby 

wells would drop to a level which 

would not support existing land uses 

or planned uses for which permits 

have been granted)?

   

c) Substantially alter the existing 

drainage pattern of the site or area, 

including through alteration of the 

course of a stream or river, or 

substantially increase the rate or 

amount of surface runoff in a manner 

that would result in substantial erosion 

or siltation on- or off-site or flooding 

on- or off-site?

   
Addendum

Revision to the PM2.5 and Ozone SIP 40 February 2011

Potentially

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

d) Create or contribute runoff water 

which would exceed the capacity of 

existing or planned storm water 

drainage systems or provide 

substantial additional sources of 

polluted runoff?

   

e) Place housing or other structures 

within a 100-year flood hazard area as 

mapped on a federal Flood Hazard 

Boundary or Flood Insurance Rate 

Map or other flood hazard delineation 

map, which would impede or redirect 

flood flows?

   

f) Expose people or structures to a 

significant risk of loss, injury or death 

involving flooding, including flooding 

as a result of the failure of a levee or 

dam, or inundation by seiche, tsunami, 

or mudflow?

   

g) Require or result in the construction of 

new water or wastewater treatment 

facilities or new storm water drainage 

facilities, or expansion of existing 

facilities, the construction of which 

could cause significant environmental 

effects?

   

h) Have sufficient water supplies 

available to serve the project from 

existing entitlements and resources, or 

are new or expanded entitlements 

needed?

   

i) Result in a determination by the 

wastewater treatment provider which 

serves or may serve the project that it 

has adequate capacity to serve the 

project’s projected demand in addition 

to the provider’s existing 

commitments?

   
Addendum

Revision to the PM2.5 and Ozone SIP 41 February 2011

Significance Criteria

Potential impacts on water resources will be considered significant if any of the following 

criteria apply:

Water Demand:

- The existing water supply does not have the capacity to meet the increased demands of the 

project, or the project would use more than 262,820 gallons per day of potable water.

- The project increases demand for total water by more than five million gallons per day.

Water Quality:

- The project will cause degradation or depletion of ground water resources substantially 

affecting current or future uses.

- The project will cause the degradation of surface water substantially affecting current or 

future uses.

- The project will result in a violation of National Pollutant Discharge Elimination System 

(NPDES) permit requirements.

- The capacities of existing or proposed wastewater treatment facilities and the sanitary sewer 

system are not sufficient to meet the needs of the project.

- The project results in substantial increases in the area of impervious surfaces, such that 

interference with groundwater recharge efforts occurs.

- The project results in alterations to the course or flow of floodwaters.

Discussion

IX. a) & i) The 2007 AQMP IS concluded that some control measures in the 2007 AQMP that 

would control particulate and/or SOx emissions could require additional wastewater discharge 

from devices like wet gas scrubbers (e.g., BCM-01, PM Control Devices, and CMB-02, SOx 

Controls). Facilities, such as refineries, could also require modifications to supply reformulated 

gasoline (ONRD-03), reformulated diesel fuels (ONRD-07), and cleaner marine fuels (ONRD06), and these modifications could generate additional wastewater discharge. Further, affected 

facilities that generate waste water and are subject to waste discharge or pretreatment 

requirements currently comply with and will continue to comply with all relevant waste water 

requirements, waste discharge regulations and standards for stormwater runoff, and any other 

relevant requirements for direct discharges into sewer systems. These standards and permits 

require water quality monitoring and reporting for onsite water-related activities. The analysis in 

the PEIR for the 2007 AQMP concluded that implementing five mitigation measures would 

reduce water quality impacts to less than significant.

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new significant adverse water quality impacts or make existing 

water quality impacts substantially worse.

IX. b), g) & h) The 2007 AQMP IS concluded that some control measures in the 2007 AQMP 

that would control particulate (fugitive dust) and/or SOx emissions could require additional 

water use from affected facilities (e.g., BCM-01, CMB-02, ONRD-03, ONRD-06, MCS-07, 

EGM-01, EGM-02, and MOB-01). The analysis in the Final PEIR concluded, however, that 
Addendum

Revision to the PM2.5 and Ozone SIP 42 February 2011

potential water demand impacts from implementing AQMP control measures would not exceed 

applicable significance thresholds.

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse water demand impacts or make existing water demand

impacts substantially worse.

IX. c), & d) Soil stabilization methods and paving unpaved areas could be required under control 

measure BCM-02 which would further reduce PM10 emissions from paved and unpaved roads. 

Soil compaction or over covering with a hard-ground cover such as asphalt or concrete pavement 

could contribute to surface water runoff since additional impervious surface areas would be 

created. However, the 2007 AQMP IS concluded that potential impacts from paving unpaved 

areas from the 2007 AQMP are not expected to be significant because project would also include 

curbs and gutters that would direct runoff to storm drains. The proposed project does not have 

the potential to substantially increase the area subject to runoff since the subject areas would be 

limited in size and, typically, have already been graded or displaced in some way (e.g., shoulders 

of roadways and curbs).

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new significant adverse water runoff or drainage pattern impacts or 

make existing significant water runoff or drainage pattern impacts substantially worse.

IX. e), & f) The IS for the 2007 AQMP concluded that implementing AQMP control measures 

would not require the construction of new, or relocation of existing housing or other types of 

facilities and, as such, would not require the construction or the placement of housing or other 

structures within a 100-year flood area as mapped on a federal Flood Hazard Boundary or Flood 

Insurance Rate Map or other flood delineation map (See also XIII “Population and Housing”). 

Consequently, the 2007 AQMP would not be expected to create or substantially increase risks 

from flooding; expose people or structures to significant risk of loss, injury or death involving 

flooding; or increase existing risks, if any, of inundation by seiche, tsunami, or mudflow. 

The proposed project does not contain any revisions to the substantive requirements of any

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse flooding impacts or make existing flooding impacts 

substantially worse.

Conclusion

It was concluded in the 2007 AQMP IS that significant adverse project-specific hydrology and 

water quality impacts may occur due to implementation of the 2007 AQMP control measures. 

Five mitigation measures were identified that would reduce significant hydrology/water quality

impacts to less than significant. Based upon the above considerations, it is concluded that the 

proposed revisions to the 2007 PM2.5 and Ozone SIP are not expected to create any new 
Addendum

Revision to the PM2.5 and Ozone SIP 43 February 2011

hydrology or water quality impacts or make substantially worse impacts identified in the 2007 

AQMP for the following reasons. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse impacts. Further, there are no revisions to the substantive requirements of any 2007 

AQMP control measures. As of January 2011, the SCAQMD has achieved 96 percent of its 

emissions reductions commitment. Although the adoption dates for some of the remaining 

control measures have been delayed, the implementation dates have not; therefore, the 

SCAQMD is expected to achieve its remaining emission reduction commitments by both 2014 

and 2023, in part, through reliance on greater than anticipated emission reductions from 

previously implemented control measures. 

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse hydrology or 

water quality impacts or make existing hydrology or water impacts worse.

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

X. LAND USE AND PLANNING. 

Would the project:

a) Physically divide an established 

community? 

   

b) Conflict with any applicable land use 

plan, policy, or regulation of an 

agency with jurisdiction over the 

project (including, but not limited to 

the general plan, specific plan, local 

coastal program or zoning ordinance) 

adopted for the purpose of avoiding or 

mitigating an environmental effect? 

   

Significance Criteria

Land use and planning impacts will be considered significant if the project conflicts with the 

land use and zoning designations established by local jurisdictions.
Addendum

Revision to the PM2.5 and Ozone SIP 44 February 2011

Discussion

X. a) The IS for the 2007 AQMP concluded that implementing AQMP control measures would 

not create significant adverse impacts that could physically divide a community because,

generally, control measures would be expected to impose control requirements on stationary 

sources at existing commercial or institutional facilities or establish emission exhaust 

specifications for mobile sources. As a result, the 2007 AQMP does not require construction of 

structures for new land uses in any areas of the district and, therefore, is not expected to create 

divisions in any existing communities or conflict with any applicable habitat conservation or 

natural community conservation plans. Implementing the currently proposed project is not 

expected to change this conclusion in any way. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse land use and planning impacts or make existing land 

use and planning impacts substantially worse.

X. b) The IS for the 2007 AQMP concluded that implementing AQMP control measures would 

not create significant adverse impacts that could interfere with complying with any applicable 

land use plans, zoning ordinances, habitat conservation or natural community conservation plans

for the following reasons. No control measures were identified that would directly affect these 

plans, policies, or regulations. The SCAQMD is specifically excluded from infringing on 

existing city or county land use authority (California Health & Safety Code §40414). Land use 

and other planning considerations are determined by local governments and no present or 

planned land uses in the region or planning requirements will be altered by the proposed project 

in any way. There are existing links between population growth, land development, housing, 

traffic, and air quality. SCAG’s Regional Comprehensive Plan accounts for these links when 

designing ways to improve air quality, transportation systems, land use, compatibility and 

housing opportunities in the region. Land use planning is handled at the local level and 

contributes to development of the AQMP growth projections, for example, but the AQMP does 

not affect local government land use planning decisions. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could conflict with land use plans, policies, or regulations.

Conclusion

It was concluded in the 2007 AQMP IS that significant adverse project-specific land use and 

planning impacts would not be expected to occur due to implementation of the 2007 AQMP 

control measures. Based upon the above considerations, it is concluded that the proposed 

revisions to the 2007 PM2.5 and Ozone SIP are not expected to create any new land use or 

planning impacts that could conflict with land use plans, policies, or regulations for the following 

reasons. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse land use and planning impacts. Further, there are no revisions to the substantive 
Addendum

Revision to the PM2.5 and Ozone SIP 45 February 2011

requirements of any 2007 AQMP control measures. As of January 2011, the SCAQMD has 

achieved 96 percent of its emissions reductions commitment. Although the adoption dates for 

some of the remaining control measures have been delayed, the implementation dates have not; 

therefore, the SCAQMD is expected to achieve its remaining emission reduction commitments 

by both 2014 and 2023, in part, through reliance on greater than anticipated emission reductions 

from previously implemented control measures. 

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing land use impacts worse.

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

XI. MINERAL RESOURCES. Would 

the project:

a) Result in the loss of availability of a 

known mineral resource that would be 

of value to the region and the residents 

of the state? 

   

b) Result in the loss of availability of a 

locally-important mineral resource 

recovery site delineated on a local 

general plan, specific plan or other 

land use plan? 

   

Significance Criteria

Project-related impacts on mineral resources will be considered significant if any of the 

following conditions are met:

- The project would result in the loss of availability of a known mineral resource that would be 

of value to the region and the residents of the state. 

- The proposed project results in the loss of availability of a locally-important mineral resource 

recovery site delineated on a local general plan, specific plan or other land use plan. 
Addendum

Revision to the PM2.5 and Ozone SIP 46 February 2011

Discussion

XI. a) & b) The IS for the 2007 AQMP concluded that implementing AQMP control measures 

would not create significant adverse impacts that would directly result in the loss of availability 

of a known mineral resource of value to the region and the residents of the state, or of a locallyimportant mineral resource recovery site delineated on a local general plan, specific plan or other 

land use plan. Further, implementing AQMP control measures is not expected to deplete nonrenewable mineral resources, such as aggregate materials, metal ores, etc., at an accelerated rate 

or in a wasteful manner because AQMP control measures are typically not mineral resource 

intensive measures. Therefore, it was concluded in the IS for the 2007 AQMP that significant 

adverse impacts to mineral resources from implementing 2007 AQMP control measures would

not be expected to occur. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse impacts to mineral resources or make existing impacts 

to mineral resources substantially worse.

Conclusions

It was concluded in the 2007 AQMP IS that significant adverse project-specific mineral 

resources impacts would not be expected to occur due to implementation of the 2007 AQMP 

control measures. Based upon the above considerations, it is concluded that the proposed 

revisions to the 2007 PM2.5 and Ozone SIP are not expected to create any new mineral resources 

impacts or make substantially worse impacts identified in the 2007 AQMP for the following 

reasons. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse mineral resources impacts. Further, there are no revisions to the substantive 

requirements of any 2007 AQMP control measures. As of January 2011, the SCAQMD has 

achieved 96 percent of its emissions reductions commitment. Although the adoption dates for 

some of the remaining control measures have been delayed, the implementation dates have not; 

therefore, the SCAQMD is expected to achieve its remaining emission reduction commitments 

by both 2014 and 2023, in part, through reliance on greater than anticipated emission reductions 

from previously implemented control measures. 

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing mineral resources impacts worse.
Addendum

Revision to the PM2.5 and Ozone SIP 47 February 2011

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

XII. NOISE. Would the project result in:

a) Exposure of persons to or generation 

of permanent noise levels in excess of 

standards established in the local 

general plan or noise ordinance, or 

applicable standards of other agencies?

   

b) Exposure of persons to or generation 

of excessive groundborne vibration or 

groundborne noise levels? 

   

c) A substantial temporary or periodic 

increase in ambient noise levels in the 

project vicinity above levels existing 

without the project?

   

d) For a project located within an airport 

land use plan or, where such a plan has 

not been adopted, within two miles of 

a public use airport or private airstrip, 

would the project expose people 

residing or working in the project area 

to excessive noise levels?

   

Significance Criteria

Impacts on noise will be considered significant if:

- Construction noise levels exceed the local noise ordinances or, if the noise threshold is 

currently exceeded, project noise sources increase ambient noise levels by more than three 

decibels (dBA) at the site boundary. Construction noise levels will be considered significant 

if they exceed federal Occupational Safety and Health Administration (OSHA) noise 

standards for workers.

- The proposed project operational noise levels exceed any of the local noise ordinances at the 

site boundary or, if the noise threshold is currently exceeded, project noise sources increase 

ambient noise levels by more than three dBA at the site boundary.

Discussion

XII. a), b) & c) It was concluded in the 2007 AQMP IS that certain control measures may 

require existing commercial or industrial owners/operators of affected facilities to install air 

pollution control equipment or modify their operations to reduce stationary source emissions. 

Potential modifications will occur at facilities typically located in appropriately zoned industrial 

or commercial areas. The 2007 AQMP could require additional control equipment that could 

generate noise impacts, but virtually all of the control equipment would be installed at industrial 

and commercial facilities.
Addendum

Revision to the PM2.5 and Ozone SIP 48 February 2011

The IS for the 2007 AQMP noted that ambient noise levels in commercial and industrial areas 

are typically driven primarily by freeway and/or highway traffic in the area and any heavy-duty 

equipment used for materials manufacturing or processing at nearby facilities. It is not expected 

that any modifications to install air pollution control equipment would substantially increase 

ambient [operational] noise levels in the area, either permanently or intermittently, or expose 

people to excessive noise levels that would be noticeable above and beyond existing ambient 

levels. It is not expected that affected facilities would exceed noise standards established in local 

general plans, noise elements, or noise ordinances currently in effect. Affected facilities would 

be required to comply with local noise ordinances and elements, which may require construction 

of noise barriers or other noise control devices.

In addition to the above, the IS noted that some control measures would provide an incentive for 

the early retirement of older equipment, replacing it with newer technologies. In most cases, 

newer equipment and newer engines are more efficient and generate less noise than older 

equipment. For example, electric and hybrid vehicles generate less noise than standard gasoline 

fueled vehicles. Therefore, some control measures could result in noise reductions at 

industrial/commercial facilities or along freeways/highways/streets as a result of quieter engines 

(e.g., MCS-01, Facility Modernization, and ONRD-06, Accelerated Penetration of Partial ZeroEmission and Zero Emission Vehicles).

It was concluded in the IS for the 2007 AQMP that implementing AQMP control measures 

would not cause an increase in groundborne vibration levels because air pollution control 

equipment is not typically vibration intensive equipment. Consequently, the 2007 AQMP would

not directly or indirectly cause substantial noise or excessive groundborne vibration impacts. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse noise impacts or make existing noise impacts 

substantially worse.

XII. d) The IS for the 2007 AQMP concluded that implementing AQMP control measures would 

not create significant adverse impacts at affected facilities because they would still be expected 

to comply, and not interfere, with any applicable airport land use plans and disclose any 

excessive noise levels to affected residences and workers pursuant to existing rules, regulations 

and requirements, such as CEQA. It is assumed that operations in these areas near airports are 

subject to and in compliance with existing community noise ordinances and applicable OSHA or 

Cal/OSHA workplace noise reduction requirements. In addition to noise generated by current 

operations, noise sources in each area may include nearby freeways, truck traffic to adjacent 

businesses, and operational noise from adjacent businesses. It was concluded that none of the 

control measures in the 2007 AQMP would locate residents or commercial buildings or other 

sensitive noise source closer to airport operations. Consequently, there are no components of the 

2007 AQMP that would substantially increase ambient noise levels, either intermittently or 

permanently. The proposed project does not contain any revisions to the substantive 

requirements of any remaining 2007 AQMP control measures and is not expected to change this 

conclusion in any way. Similarly, the proposed revisions do not include incorporating any new 

control measures into the SIP that could create new adverse noise impacts or make existing noise 

impacts substantially worse to people residing or working in the vicinity of local airports.
Addendum

Revision to the PM2.5 and Ozone SIP 49 February 2011

Conclusions

It was concluded in the 2007 AQMP IS that significant adverse project-specific noise impacts 

would not be expected to occur due to implementation of the 2007 AQMP control measures. 

Based upon the above considerations, it is concluded that the proposed revisions to the 2007 

PM2.5 and Ozone SIP are not expected to create any new noise impacts or make substantially 

worse impacts identified in the 2007 AQMP for the following reasons. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse noise impacts. Further, there are no revisions to the substantive requirements of any 

2007 AQMP control measures. As of January 2011, the SCAQMD has achieved 96 percent of 

its emissions reductions commitment. Although the adoption dates for some of the remaining 

control measures have been delayed, the implementation dates have not; therefore, the 

SCAQMD is expected to achieve its remaining emission reduction commitments by both 2014 

and 2023, in part, through reliance on greater than anticipated emission reductions from 

previously implemented control measures.

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing noise impacts worse.

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

XIII.POPULATION AND HOUSING. 

Would the project:

a) Induce substantial growth in an area 

either directly (for example, by 

proposing new homes and businesses) 

or indirectly (e.g. through extension of 

roads or other infrastructure)? 

   

b) Displace substantial numbers of 

people or existing housing, 

necessitating the construction of 

replacement housing elsewhere? 

   
Addendum

Revision to the PM2.5 and Ozone SIP 50 February 2011

Significance Criteria

Impacts of the proposed project on population and housing will be considered significant if the 

following criteria are exceeded:

- The demand for temporary or permanent housing exceeds the existing supply.

- The proposed project produces additional population, housing or employment inconsistent 

with adopted plans either in terms of overall amount or location.

Discussion

XIII. a) The IS for the 2007 AQMP noted that, according to SCAG (2004), population growth in 

the SCAG region (which includes all of the district) is expected to grow to 22.9 million due to 

immigration and births within the region. Consistent with SCAG’s population growth 

projections, the proposed project is not anticipated to generate any significant effects, either 

directly or indirectly, on the district’s population or population distribution. The 2007 AQMP 

generally affects existing commercial or industrial facilities located in predominantly industrial 

or commercial urbanized areas throughout the district. It is expected that the existing labor pool 

within the areas surrounding any affected facilities would accommodate the labor requirements 

for any modifications at affected facilities. In addition, it is not expected that affected facilities 

would be required to hire additional personnel to operate and maintain new control equipment on 

site because air pollution control equipment is typically not labor intensive equipment. In the 

event that new employees are hired, it is expected that the existing local labor pool in the district 

can accommodate any increase in demand for workers that might occur as a result of the 2007 

AQMP. As a result, implementing AQMP control measures is not expected to result in 

significant adverse changes in population densities or induce significant growth in population. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse population or housing impacts or make existing 

population or housing impacts substantially worse.

XIII. b) The IS for the 2007 AQMP concluded that implementing AQMP control measures 

would not create significant adverse impacts that would increase demand for new workers in the 

district. Any demand for new employees is expected to be accommodated from the existing labor 

pool so no substantial population displacement is expected. Construction activities generated by 

the 2007 AQMP are expected to be limited to stationary sources within industrial and 

commercial areas for the installation of new technology or equipment. The 2007 AQMP is not 

expected to require construction activities that would displace people or existing housing. 

Implementing the currently proposed project is not expected to change this conclusion in any 

way. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse impacts or make existing impacts substantially worse

because the 2007 AQMP does not displace existing people or housing.
Addendum

Revision to the PM2.5 and Ozone SIP 51 February 2011

Conclusions

It was concluded in the 2007 AQMP IS that significant adverse project-specific population and 

housing impacts would not be expected to occur due to implementation of the 2007 AQMP 

control measures. Based upon the above considerations, it is concluded that the proposed 

revisions to the 2007 PM2.5 and Ozone SIP are not expected to create any new population or 

housing impacts or make substantially worse impacts identified in the 2007 AQMP for the 

following reasons. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse housing or population impacts. Further, there are no revisions to the substantive 

requirements of any 2007 AQMP control measures. As of January 2011, the SCAQMD has 

achieved 96 percent of its emissions reductions commitment. Although the adoption dates for 

some of the remaining control measures have been delayed, the implementation dates have not; 

therefore, the SCAQMD is expected to achieve its remaining emission reduction commitments 

by both 2014 and 2023, in part, through reliance on greater than anticipated emission reductions 

from previously implemented control measures. 

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing population or housing impacts worse.
Addendum

Revision to the PM2.5 and Ozone SIP 52 February 2011

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

XIV. PUBLIC SERVICES. Would the 

proposal result in substantial adverse 

physical impacts associated with the 

provision of new or physically altered 

governmental facilities, need for new 

or physically altered government 

facilities, the construction of which 

could cause significant environmental 

impacts, in order to maintain 

acceptable service ratios, response 

times or other performance objectives 

for any of the following public 

services:

a) Fire protection?    

b) Police protection?    

c) Schools?    

d) Other public facilities?    

Significance Criteria

Impacts on public services will be considered significant if the project results in substantial 

adverse physical impacts associated with the provision of new or physically altered 

governmental facilities, or the need for new or physically altered government facilities, the 

construction of which could cause significant environmental impacts, in order to maintain 

acceptable service ratios, response time or other performance objectives.

Discussion

XIV. a), b), & d) It was concluded in the 2007 AQMP IS that there is no potential for 

significant adverse public service impacts to fire departments, police departments, or other public 

services as a result of implementing AQMP control measures. Similarly, the proposed project 

would not result in the need for new or physically altered government facilities in order to 

maintain acceptable service ratios, response times or other performance objectives. Similarly, 

most industrial facilities have on-site security that controls public access to facilities so no 

increase in the need for police services are expected. Most industrial facilities have on-site fire 

protection personnel and/or have agreements for fire protection services with local fire 

departments. For these reasons, implementing the 2007 AQMP is not expected to require 

additional fire or police protection services. As a result, the analysis in the IS for the 2007 

AQMP concluded that existing resources at services such as fire departments, police departments 

and local governments would not be significantly adversely affected as a result of implementing 

AQMP control measures. 
Addendum

Revision to the PM2.5 and Ozone SIP 53 February 2011

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse public service impacts to local fire or police 

departments or make existing public service impacts substantially worse.

XIV. c) The IS for the 2007 AQMP concluded that implementing AQMP control measures 

would not create significant adverse impacts to schools because implementing AQMP control 

measures is not expected to induce population growth and, therefore, would not increase or 

otherwise alter the demand for schools in the district. The proposed project does not contain any 

revisions to the substantive requirements of any remaining 2007 AQMP control measures and is 

not expected to change this conclusion in any way. Similarly, the proposed revisions do not 

include incorporating any new control measures into the SIP that could create new adverse 

impacts to schools or make existing impacts to schools substantially worse.

Conclusions 

It was concluded in the 2007 AQMP IS that significant adverse project-specific public service 

impacts would not be expected to occur due to implementation of the 2007 AQMP control 

measures. Based upon the above considerations, it is concluded that the proposed revisions to 

the 2007 PM2.5 and Ozone SIP are not expected to create any new public service impacts or 

make substantially worse impacts identified in the 2007 AQMP for the following reasons. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse public service impacts. Further, there are no revisions to the substantive requirements of 

any 2007 AQMP control measures. As of January 2011, the SCAQMD has achieved 96 percent 

of its emissions reductions commitment. Although the adoption dates for some of the remaining 

control measures have been delayed, the implementation dates have not; therefore, the 

SCAQMD is expected to achieve its remaining emission reduction commitments by both 2014 

and 2023, in part, through reliance on greater than anticipated emission reductions from 

previously implemented control measures. 

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing public service impacts worse.
Addendum

Revision to the PM2.5 and Ozone SIP 54 February 2011

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

XV. RECREATION.

a) Would the project increase the use of 

existing neighborhood and regional 

parks or other recreational facilities 

such that substantial physical 

deterioration of the facility would 

occur or be accelerated?

   

b) Does the project include recreational 

facilities or require the construction or 

expansion of recreational facilities that 

might have an adverse physical effect 

on the environment or recreational 

services?

   

Significance Criteria

Impacts to recreation will be considered significant if:

- The project results in an increased demand for neighborhood or regional parks or other 

recreational facilities.

- The project adversely affects existing recreational opportunities.

Discussion

XV. a) & b) The IS for the 2007 AQMP concluded that implementing AQMP control 

measures would not create significant adverse impacts to recreational resources for the following 

reasons. As discussed under “Land Use and Planning” and “Population and Housing” in the IS 

for the 2007 AQMP, there are no provisions that would affect land use plans, policies, 

ordinances, or regulations. Land use and other planning considerations are determined by local 

governments. No land use or planning requirements, including those related to recreational 

facilities, will be altered by the proposal. The IS for the 2007 AQMP concluded that 

implementing AQMP control measures would not have the potential to directly or indirectly 

induce population growth or redistribution. As a result, implementing AQMP control measures

would not increase the use of, or demand for existing neighborhood and/or regional parks or 

other recreational facilities or require the construction or expansion of recreational facilities that 

might have an adverse physical effect on the environment. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse recreation impacts or make existing recreation impacts 

substantially worse.
Addendum

Revision to the PM2.5 and Ozone SIP 55 February 2011

Conclusions

It was concluded in the 2007 AQMP IS that significant adverse project-specific recreational 

impacts would not be expected to occur due to implementation of the 2007 AQMP control 

measures. Based upon the above considerations, it is concluded that the proposed revisions to 

the 2007 PM2.5 and Ozone SIP are not expected to create any new recreation impacts or make 

substantially worse impacts identified in the 2007 AQMP for the following reasons. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse recreation impacts. Further, there are no revisions to the substantive requirements of any 

2007 AQMP control measures. As of January 2011, the SCAQMD has achieved 96 percent of 

its emissions reductions commitment. Although the adoption dates for some of the remaining 

control measures have been delayed, the implementation dates have not; therefore, the 

SCAQMD is expected to achieve its remaining emission reduction commitments by both 2014 

and 2023, in part, through reliance on greater than anticipated emission reductions from 

previously implemented control measures. 

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing recreation impacts worse.

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

XVI. SOLID/HAZARDOUS WASTE. 

Would the project:

a) Be served by a landfill with sufficient 

permitted capacity to accommodate 

the project’s solid waste disposal 

needs?

   

b) Comply with federal, state, and local 

statutes and regulations related to solid 

and hazardous waste?

   
Addendum

Revision to the PM2.5 and Ozone SIP 56 February 2011

Significance Criteria

The proposed project impacts on solid/hazardous waste will be considered significant if the 

following occurs:

- The generation and disposal of hazardous and non-hazardous waste exceeds the capacity of 

designated landfills.

Discussion

XVI. a) The 2007 AQMP IS concluded that implementing control measures in the 2007 AQMP 

could create significant adverse solid waste impacts for the following reasons. Implementing 

AQMP control measures could require facilities to install air pollution control equipment, such 

as carbon adsorption devices, particulate filters, catalytic incineration, selective catalytic 

reduction or other types of control equipment that could increase the amount of solid/hazardous 

wastes generated in the district due to the disposal of spent catalyst, filters or other mechanisms 

used in the control equipment. Solid waste impacts were further analyzed in the PEIR for the 

2007 AQMP. The analysis in the PEIR concluded that most solid waste impacts resulting from 

implementing AQMP control would not exceed applicable significance thresholds. The analysis 

also concluded that potentially significant adverse solid waste impacts from disposal of spent 

batteries from increasing penetration of electric vehicles into the district fleet and disposal of 

spent carbon from carbon adsorption control equipment could result in significant adverse solid 

waste impacts. However, three mitigation measures were identified that could reduce potentially 

significant adverse impacts to less than significant. To the extent applicable, mitigation 

measures would continue to be required for future projects. Therefore, it was concluded in the 

PEIR for the 2007 AQMP that solid waste impacts from implementing AQMP control measures, 

along with implementing mitigation measures as applicable, would not create significant adverse 

solid waste impacts. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse solid waste impacts or make existing solid waste

impacts substantially worse.

XVI. b) The 2007 AQMP IS concluded that the 2007 AQMP control measures are not expected 

to interfere with affected facilities’ abilities to comply with federal, state, or local statutes and 

regulations related to solid and hazardous waste handling or disposal. The proposed project does 

not contain any revisions to the substantive requirements of any remaining 2007 AQMP control 

measures and is not expected to change this conclusion in any way. Similarly, the proposed 

revisions do not include incorporating any new control measures into the SIP that could create 

new adverse impacts that could interfere with complying with applicable regulations related to 

handling solid and hazardous waste handling or disposal or make such existing impacts 

substantially worse.

Conclusions

It was concluded in the 2007 AQMP IS that significant adverse project-specific solid/hazardous 

waste impacts may occur due to implementation of the 2007 AQMP control measures. Based 

upon the above considerations, it is concluded that the proposed revisions to the 2007 PM2.5 and 

Ozone SIP are not expected to create any new solid waste impacts or make substantially worse 

impacts identified in the 2007 AQMP for the following reasons. 
Addendum

Revision to the PM2.5 and Ozone SIP 57 February 2011

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse solid waste impacts. Further, there are no revisions to the substantive requirements of 

any 2007 AQMP control measures. As of January 2011, the SCAQMD has achieved 96 percent 

of its emissions reductions commitment. Although the adoption dates for some of the remaining 

control measures have been delayed, the implementation dates have not; therefore, the 

SCAQMD is expected to achieve its remaining emission reduction commitments by both 2014 

and 2023, in part, through reliance on greater than anticipated emission reductions from 

previously implemented control measures. 

The SCAQMD would also commit to retaining the contingency control measures, including 

triggers for their implementation in the event that the PM2.5 standard is not achieved by 2015. 

Finally, if U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the 

SCAQMD would commit to an additional one tpd of NOx emission reductions in 2014 with 

CARB assuming the remaining nine tpd reductions of the federal assignment in order to continue 

to demonstrate attainment of all applicable standards. This additional one tpd commitment 

would not foreseeably have any different impacts than existing 2007 AQMP control measures. 

These emission reductions would most likely occur as a result of greater reductions obtained 

from adopted regulations or early implementation of control measures in the 2007 AQMP. 

There are no provisions in the proposed project that would create new adverse impacts or make 

existing solid waste impacts worse.

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

XVII.TRANSPORTATION/TRAFFIC.

 Would the project:

a) Conflict with an applicable plan, 

ordinance or policy establishing 

measures of effectiveness for the 

performance of the circulation system, 

taking into account all modes of 

transportation including mass transit 

and non-motorized travel and relevant 

components of the circulation system, 

including but not limited to 

intersections, streets, highways and 

freeways, pedestrian and bicycle 

paths, and mass transit?

   

b) Conflict with an applicable congestion 

management program, including but 

not limited to level of service 

standards and travel demand measures, 

or other standards established by the 

   
Addendum

Revision to the PM2.5 and Ozone SIP 58 February 2011

county congestion management 

agency for designated roads or 

highways?

c) Result in a change in air traffic 

patterns, including either an increase 

in traffic levels or a change in location 

that results in substantial safety risks?

   

d) Substantially increase hazards due to a 

design feature (e.g. sharp curves or 

dangerous intersections) or 

incompatible uses (e.g. farm 

equipment)?

   

e) Result in inadequate emergency 

access?

   

f) Conflict with adopted policies, plans, 

or programs regarding public transit, 

bicycle, or pedestrian facilities, or 

otherwise decrease the performance or 

safety of such facilities?

   

Significance Criteria

Impacts on transportation/traffic will be considered significant if any of the following criteria 

apply:

- Peak period levels on major arterials are disrupted to a point where level of service (LOS) is 

reduced to D, E or F for more than one month.

- An intersection’s volume to capacity ratio increase by 0.02 (two percent) or more when the 

LOS is already D, E or F.

- A major roadway is closed to all through traffic, and no alternate route is available.

- The project conflicts with applicable policies, plans or programs establishing measures of 

effectiveness, thereby decreasing the performance or safety of any mode of transportation.

- There is an increase in traffic that is substantial in relation to the existing traffic load and 

capacity of the street system.

- The demand for parking facilities is substantially increased.

- Water borne, rail car or air traffic is substantially altered.

- Traffic hazards to motor vehicles, bicyclists or pedestrians are substantially increased.

- The need for more than 350 employees

- An increase in heavy-duty transport truck traffic to and/or from the facility by more than 350 

truck round trips per day

- Increase customer traffic by more than 700 visits per day.

Discussion

XVII. a) & b) It was concluded in the IS for the 2007 AQMP that implementing AQMP control 

measures would not be expected to adversely affect transportation and traffic in the district. The 

IS for the 2007 AQMP noted that implementing AQMP control measures is not expected to 

substantially increase vehicle trips or vehicle miles traveled in the district. The 2007 AQMP 

relies on transportation and related control measures developed by SCAG (SCAG, 2004). These 

transportation control measures include strategies to enhance mobility by reducing congestion 
Addendum

Revision to the PM2.5 and Ozone SIP 59 February 2011

through transportation infrastructure improvements, mass transit improvements, increasing 

telecommunications products and services, enhanced bicycle and pedestrian facilities, etc. 

Specific strategies that serve to reduce vehicle trips and vehicle miles traveled, such as strategies 

resulting in greater reliance on mass transit, ridesharing, telecommunications, etc., are expected 

to result in reducing traffic congestion. Although population in the district will continue to 

increase, implementing the transportation control measures (in conjunction with the Regional 

Transportation Plan) will ultimately result in greater percentages of the population using 

transportation modes other than single occupant vehicles. As a result, relative to population 

growth, existing traffic loads and the level of service designation for intersections district-wide 

would not be expected to decline at current rates, but could possibly improve to a certain extent. 

Therefore, implementing AQMP control measures could ultimately provide transportation 

improvements and congestion reduction benefits. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse transportation or traffic impacts or make existing 

traffic or transportation impacts substantially worse.

XVII. c) The IS for the 2007 AQMP concluded that implementing AQMP control measures 

would not create significant adverse impacts to air traffic or air traffic patterns because control 

measures typically do not require transporting materials by air. Further, controlling emissions at 

existing commercial or industrial facilities and establishing mobile source exhaust and fuel 

specifications do not require constructing any structures that could impede air traffic patterns in 

any way. Therefore, implementing AQMP control measures is not expected to generate 

significant adverse air traffic impacts. Implementing the currently proposed project is not 

expected to change this conclusion in any way. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse impacts to air traffic or air traffic patterns or make 

existing impacts to air traffic or air traffic patterns substantially worse.

XVII. d) It was concluded in the 2007 AQMP IS that the 2007 AQMP will not directly or 

indirectly increase roadway design hazards or incompatible risks. To the extent that 

implementing components of the transportation control measure and related measures further 

develop roadway infrastructure, it is expected that there would ultimately be a reduction in 

roadway hazards or incompatible risks as part of any roadway infrastructure improvements and 

reduced congestion. Implementing the currently proposed project is not expected to change this 

conclusion in any way. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse roadway hazard impacts or make existing roadway 

hazard impacts substantially worse.
Addendum

Revision to the PM2.5 and Ozone SIP 60 February 2011

XVII. e) The IS for the 2007 AQMP concluded that implementing AQMP control measures 

would not create significant impacts that could adversely affect affected facilities’ emergency 

access routes or plans. Controlling emissions at existing commercial or industrial facilities and 

establishing mobile source exhaust and fuel specifications are not expected to affect in any way 

emergency access routes at any affected commercial or industrial facilities. The reason for this 

conclusion is that controlling emissions (from stationary sources in particular) is not expected to 

require construction of any structures that might obstruct emergency access routes at any 

affected facilities. Implementing the currently proposed project is not expected to change this 

conclusion in any way. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse impacts to emergency access routes or plans or make 

existing impacts to emergency access routes or plans substantially worse.

XVII. f) The 2007 AQMP IS concluded that adopting the proposed 2007 AQMP will not conflict 

with adopted policies, plans or programs supporting alternative transportation programs. In fact, 

the transportation and related control measures would specifically encourage and provide 

incentives for implementing alternative transportation programs and strategies. Therefore, 

implementing AQMP control measures will not significantly adversely affect alternative 

transportation programs. Implementing the currently proposed project is not expected to change 

this conclusion in any way. 

The proposed project does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures and is not expected to change this conclusion in any 

way. Similarly, the proposed revisions do not include incorporating any new control measures 

into the SIP that could create new adverse impacts resulting from conflicts with adopted policies, 

plans or programs supporting alternative transportation programs or make such existing impacts 

substantially worse.

Conclusions

It was concluded in the 2007 AQMP IS that significant adverse project-specific 

transportation/traffic impacts would not be expected to occur due to implementation of the 2007 

AQMP control measures. Based upon the above considerations, it is concluded that the proposed 

revisions to the 2007 PM2.5 and Ozone SIP are not expected to create any new transportation or 

traffic impacts or make substantially worse impacts identified in the IS for the 2007 AQMP for 

the following reasons. 

The proposed revisions would not change any of the above conclusions because they do not 

include incorporating any new types of control measures into the SIP that could create new 

adverse transportation impacts. Further, there are no revisions to the substantive requirements of 

any 2007 AQMP control measures. As of January 2011, the SCAQMD has achieved 96 percent 

of its emissions reductions commitment. Although the adoption dates for some of the remaining 

control measures have been delayed, the implementation dates have not; therefore, the 

SCAQMD is expected to achieve its remaining emission reduction commitments by both 2014 

and 2023, in part, through reliance on greater than anticipated emission reductions from 

previously implemented control measures. 
Addendum

Revision to the PM2.5 and Ozone SIP 61 February 2011

The SCAQMD would also commit to retaining the contingency control measures, including triggers 

for their implementation in the event that the PM2.5 standard is not achieved by 2015. Finally, if 

U.S. EPA fails to voluntarily accept the 10 tpd emission reduction in the 2007 SIP, the SCAQMD 

would commit to an additional one tpd of NOx emission reductions in 2014 with CARB assuming 

the remaining nine tpd reductions of the federal assignment in order to continue to demonstrate 

attainment of all applicable standards. This additional one tpd commitment would not foreseeably 

have any different impacts than existing 2007 AQMP control measures. These emission reductions 

would most likely occur as a result of greater reductions obtained from adopted regulations or early 

implementation of control measures in the 2007 AQMP. There are no provisions in the proposed 

project that would create new adverse impacts or make existing transportation or traffic impacts 

worse.

Potentially 

Significant 

Impact

Less Than 

Significant 

With 

Mitigation

Less Than 

Significant 

Impact

No Impact

XVIII. MANDATORY FINDINGS OF

 SIGNIFICANCE.

a) Does the project have the potential to 

degrade the quality of the 

environment, substantially reduce the 

habitat of a fish or wildlife species, 

cause a fish or wildlife population to 

drop below self-sustaining levels, 

threaten to eliminate a plant or animal 

community, reduce the number or 

restrict the range of a rare or 

endangered plant or animal or 

eliminate important examples of the 

major periods of California history or 

prehistory?

   

b) Does the project have impacts that are 

individually limited, but cumulatively 

considerable? ("Cumulatively 

considerable" means that the 

incremental effects of a project are 

considerable when viewed in 

connection with the effects of past 

projects, the effects of other current 

projects, and the effects of probable 

future projects)

   

c) Does the project have environmental 

effects that will cause substantial 

adverse effects on human beings, 

either directly or indirectly?

   
Addendum

Revision to the PM2.5 and Ozone SIP 62 February 2011

XVIII.a) In the 2007 AQMP IS, no direct or indirect impacts from implementing the 2007 

AQMP control measures were identified that could potentially degrade the quality of the 

environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife 

population to drop below self-sustaining levels, threaten to eliminate a plant or animal 

community, reduce the number or restrict the range of a rare or endangered plant or animal or 

eliminate important examples of the major periods of California history or prehistory. The 

effects of implementing AQMP control measures are typically reducing mobile source exhaust 

emissions, modifying fuel specifications, or modifications at existing commercial or industrial 

facilities to control or further control emissions. Such existing commercial or industrial facilities 

are generally located in appropriately zoned commercial or industrial areas, which typically do 

not support candidate, sensitive, or special status species in local or regional plans, policies, or 

regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife 

Service. Similarly, modifications at existing facilities would not interfere substantially with the 

movement of any native resident or migratory fish or wildlife species or with native or resident 

or migratory wildlife corridors, or impede the use of native wildlife nursery sites. Further, since 

the 2007 AQMP primarily regulates stationary emission sources at existing commercial or 

industrial facilities, it does not directly or indirectly affect land use policy that may adversely 

affect riparian habitat or other sensitive natural communities identified in local or regional plans,

policies, or regulations, or identified by the California Department of Fish and Game or U.S. 

Fish and Wildlife Service. Improving air quality is expected to provide health benefits to plant 

and animal species in the district. There are no control measures contained in the 2007 AQMP 

that would significantly adversely affect biological resources. Although the adoption dates for 

some of the remaining control measures have been delayed, the implementation dates have not; 

therefore, the SCAQMD is expected to achieve its remaining emission reduction commitments 

by both 2014 and 2023, in part, through reliance on greater than anticipated emission reductions 

from previously implemented control measures. Therefore, implementing the currently proposed 

project is not expected to change this conclusion in any way because it does not contain any 

revisions to the substantive requirements of any remaining 2007 AQMP control measures the 

proposed revisions do not include incorporating any new control measures into the SIP that could 

create new adverse impacts or make existing impacts substantially worse.

XVIII. b)As noted in the 2007 AQMP Final PEIR, with the exception of the environmental 

topic areas discussed below, implementing AQMP control measures would not generate projectspecific adverse impacts for the environmental topics on the environmental checklist (CEQA 

Guidelines, Appendix G). Cumulative impacts are not considered to be "cumulatively 

considerable” as defined by CEQA guidelines §15065(a)(3) for these environmental topics. For 

example, the environmental topics checked ‘No Impact’ in the IS for the 2007 AQMP (e.g., 

agriculture, biological resources, land use and planning, mineral resources, population and 

housing, public services, recreation, and transportation and traffic) would not be expected to 

make any contribution to potential cumulative impacts whatsoever. Therefore, implementing the 

currently proposed project is not expected to change this conclusion in any way because it does 

not contain any revisions to the substantive requirements of any remaining 2007 AQMP control 

measures the proposed revisions do not include incorporating any new control measures into the 

SIP that could create new adverse impacts or make existing impacts substantially worse.

For the environmental topics checked ‘Less than Significant Impact’ (e.g., aesthetics, geology 

and soils, and noise), the analysis indicated that proposed project impacts would not exceed any 
Addendum

Revision to the PM2.5 and Ozone SIP 63 February 2011

project-specific significance thresholds. These determinations are based on the fact that the 

analyses for each of these environmental areas concluded that the incremental effects of the 

proposed project would be minor and, therefore, not considered to be cumulatively considerable

and would not contribute significantly to cumulative impacts. Therefore, implementing the 

currently proposed project is not expected to change this conclusion in any way because it does 

not contain any revisions to the substantive requirements of any remaining 2007 AQMP control 

measures the proposed revisions do not include incorporating any new control measures into the 

SIP that could create new adverse impacts or make existing impacts substantially worse.

The following topics were checked potentially significant on the IS for the 2007 AQMP and

were further analyzed in the PEIR: air quality, energy, hazards and hazardous materials, 

hydrology and water quality, and solid/hazardous waste. The analysis of energy impacts in the 

PEIR for the 2007 AQMP concluded that project-specific impacts would not be significant and

were not considered to be cumulative considerable. Therefore, cumulative energy impacts were 

concluded to be less than significant. Therefore, implementing the currently proposed project is 

not expected to change this conclusion in any way because it does not contain any revisions to 

the substantive requirements of any remaining 2007 AQMP control measures the proposed 

revisions do not include incorporating any new control measures into the SIP that could create 

new adverse impacts or make existing impacts substantially worse.

The analysis of hydrology and water quality and solid/hazardous waste impacts in the PEIR for 

the 2007 AQMP concluded that impacts to these environmental topic areas would be significant. 

Five mitigation measures were identified to that could reduce project-specific hydrology and 

water quality impacts to less than significant and three mitigation measures were identified that 

could reduce project-specific solid/hazardous waste impacts to less than significant. Based on 

these conclusions, implementing AQMP control measures was not expected to contribute to 

significant adverse cumulative hydrology and water quality or solid/hazardous waste impacts. 

Therefore, implementing the currently proposed project is not expected to change this conclusion 

in any way because it does not contain any revisions to the substantive requirements of any 

remaining 2007 AQMP control measures the proposed revisions do not include incorporating 

any new control measures into the SIP that could create new adverse impacts or make existing 

impacts substantially worse.

The analysis of air quality impacts in the PEIR for the 2007 AQMP concluded that for most air 

quality impact areas, e.g., operational secondary impacts from increased electricity demand, 

mobile sources, etc., would be less than applicable significance thresholds and, therefore, would 

not contribute to significant adverse cumulative impacts. Construction air quality impacts 

(PM10) were concluded to be significant. Nine mitigation measures were identified to reduce 

construction air quality impacts. However, the analysis concluded that implementing the nine 

mitigation measures would not reduce construction air quality impacts to less than significant. 

As a result, construction air quality impacts were considered to be cumulatively considerable. 

Therefore, it was concluded that implementing the 2007 AQMP contributed to significant 

adverse cumulative construction air quality impacts. However, implementing the currently 

proposed project is not expected to change this conclusion in any way because it does not contain 

any revisions to the substantive requirements of any remaining 2007 AQMP control measures 

the proposed revisions do not include incorporating any new control measures into the SIP that 

could create new adverse impacts or make existing impacts substantially worse.
Addendum

Revision to the PM2.5 and Ozone SIP 64 February 2011

The 2007 AQMP included an analysis of GHG impacts from implementing AQMP control 

measures. An analysis of GHG impacts is considered to be a cumulative impact analysis because 

it cannot be demonstrated that project-specific GHG emissions contribute to global climate 

change. The analysis concluded that implementing AQMP control measures to reduce criteria 

pollutants would also produce GHG emission reduction co-benefits. Consequently, cumulative 

GHG emission impacts were concluded to be less than significant. Therefore, implementing the 

currently proposed project is not expected to change this conclusion in any way because it does 

not contain any revisions to the substantive requirements of any remaining 2007 AQMP control 

measures the proposed revisions do not include incorporating any new control measures into the 

SIP that could create new adverse impacts or make existing impacts substantially worse.

The analysis of hazards and hazardous materials impacts in the PEIR for the 2007 AQMP 

concluded that for most hazards and hazardous materials impact areas, e.g., use of alternative 

fuels, use of ammonia in air pollution control equipment, etc., would be less than applicable 

significance thresholds and, therefore, would not contribute to significant adverse cumulative 

impacts. Impacts to modifications at refineries to produce alternative fuels could result in 

significant exposures to flammable materials and, therefore, were concluded to be significant. 

Five mitigation measures were identified to reduce the severity of hazards and hazardous 

materials impacts. However, the analysis concluded that implementing the five mitigation 

measures would not reduce hazards and hazardous materials impacts to less than significant. As 

a result, hazards and hazardous materials impacts were considered to be cumulatively 

considerable. Therefore, it was concluded that implementing the 2007 AQMP contributed to 

significant adverse cumulative hazards and hazardous materials impacts. However, 

implementing the currently proposed project is not expected to change this conclusion in any 

way because it does not contain any revisions to the substantive requirements of any remaining 

2007 AQMP control measures the proposed revisions do not include incorporating any new 

control measures into the SIP that could create new adverse impacts or make existing impacts 

substantially worse.

XVIII. c) Based on the foregoing analyses, implementing AQMP control measures may cause 

significant adverse effects on human beings. However, implementing the currently proposed 

project is not expected to increase the severity in any way of impacts to human beings that might 

result from implementing other AQMP control measures. 

Based on the preceding analyses in items I through XVIII above, the proposed project is not 

expected to contribute to, or make substantially worse project-specific or cumulative impacts to 

the following environmental topic areas: aesthetics, agriculture and forest resources, air quality 

and greenhouse gas emissions, biological resources, cultural resources, energy, geology and 

soils, hazards and hazardous materials, hydrology and water quality, land use and planning, 

mineral resources, noise, population and housing, public services, recreation, solid/hazardous 

waste and transportation. 

5610 Pacific Blvd., Suite 203 y Huntington Park, CA. 90255 y (323) 826-9771

In Northern California: 1904 Franklin St., Suite 600 y Oakland, CA 94612 y (510) 302-0430 

1

Clerk of the Boards 

21865 Copley Drive 

Diamond Bar, CA 91765-4178 

Via email to cob@aqmd.gov 

February 22, 2011 

Re: Revisions to the PM2.5 and Ozone State Implementation Plan for the South 

Coast Air Basin and Coachella Valley

To Whom it May Concern: 

Thank you for the opportunity to comment on the adequacy of the South Coast 

Air Quality Management District (SCAQMD) PM2.5 (particulate matter) portion of the 

2007 Air Quality Management Plan (AQMP). In its Technical Support Document for the 

Proposed Action on the South Coast 2007 AQMD for PM2.5 and the South Coast 

Portions of the Revised 2007 State Strategy (TSD), EPA stated: “The South Coast 

nonattainment area’s degree of PM2.5 nonattainment can fairly be characterized as 

severe.” 1

 These serious air quality issues merit prompt attention by the SCAQMD to 

make sure we meet the annual PM2.5 on time. 

For context regarding the actual experience of neighbors in heavily industrial 

areas disproportionately affected by PM2.5 and other air pollution, CBE Community 

Organizer Alicia Rivera describes her experience as reported by neighbors as follows: 

PM 2.5 reductions and strict regulation are badly needed in the community 

of Wilmington where I organize. Despite the fact that I encounter residents 

suffering from asthma so often, each case strikes me differently. Two 

weeks ago, Eduardo Castillo, a Wilmington resident, approached me at a 

community meeting. He mentioned that his three children suffer from 

asthma. I asked him about their ages and how he feels about it. With a 

very somber face he told me how sad it is for him to see his six-month-old 

baby being treated with the oxygen mask to control his asthma attacks. 

His other two children are younger than six. He said he feels impotent 

about all the pollution, living in the backdrop of Valero, Tesoro, and 

Conoco Phillips, the railroad trucks, the auto dismantling facility and the 

Alameda corridor. He told me that all his nieces and nephews also suffer 

from asthma. “All of us here in Wilmington are plagued with asthma,” he 

said. 

 

1

 United States Environmental Protection Agency, Technical Support Document for the Proposed Action 

on the South Coast 2007 AQMP for PM2.5 and the South Coast Portions of the Revised 2007 State Strategy, 

[hereinafter, “TSD”] p. 64. http://www.epa.gov/region9/air/actions/pdf/ca/South-Coast-PM25-TSD.pdf 

COMMUNITIES FOR A 

BETTER

ENVIRONMENT

ATTACHMENT E
5610 Pacific Blvd., Suite 203 y Huntington Park, CA. 90255 y (323) 826-9771

In Northern California: 1904 Franklin St., Suite 600 y Oakland, CA 94612 y (510) 302-0430 

2

People in Wilmington are exposed to flaring emissions regularly. 

Although we have been letting them know about the importance to report 

to 1-800 CUT SMOG, some of them have become skeptical about doing 

so, because they do not believe that their complaints go anywhere. 

"Inspectors come and give us the same reason that the refineries give us 

for having flared,” Patricia Ramos told me. They believe that no real 

measures are taken to prevent new flaring events. There are so many 

sources that Wilmington residents are exposed to less than a mile away 

from them. They are in close proximity to refineries, railroad tracks, 

freeways, the port, and the Alameda corridor traffic, all emitters of PM2.5. 

The levels of asthma, respiratory illnesses, allergies and cancer that I 

encounter in almost every household would be treated as an epidemic if it 

was some other type of a contagious illness. To me, PM2.5 is an epidemic 

affecting almost every home. 

The combined effect of PM2.5 from many sources is potent and its cumulative impacts 

should be addressed. The public depends on the AQMD to develop and implement 

strategies and measures that reduce and prevent PM2.5, and on EPA to make sure the 

AQMD does this according to the Clean Air Act. 

EPA found that the SIP relies too heavily on unenforceable commitments, rather 

than adopted, submitted, and SIP approved rules to meet PM2.5 attainment. EPA also 

found that sufficient RACM/RACT are not demonstrated in the plan: 

As discussed below, however, we are proposing to disapprove the 

RACM/RACT demonstration in the South Coast 2007 AQMP because we 

cannot approve the attainment demonstration. As stated in the PM2.5 

implementation rule preamble at 20601, EPA cannot grant an extension of 

the attainment date beyond the initial five years provided by section 

172(a)(2(A) if the State has not adequately considered and evaluated the 

implementation of RACM and RACT in the area. By definition, 

RACM/RACT are those controls that are necessary to demonstrate 

attainment as expeditiously as practicable and meet any RFP requirements. 

40 CFR § 51.10101(a).2

The SCAQMD’s revisions to the SIP are an attempt to correct the deficiencies EPA 

pointed to in the AQMP. Unfortunately, the revisions continue to ignore RACM/RACT 

and continue to rely on unenforceable commitments. It is crucial for public health that 

the Governing Board reject the current revisions to the PM2.5 and ozone SIP for the 

South Coast Air Basin and Coachella Valley until SCAQMD makes the needed 

improvements to reach attainment. 

A. The PM2.5 and Ozone Plan Cannot Rely on Unenforceable Commitments 

 

2

 Ibid, p. 65. 
5610 Pacific Blvd., Suite 203 y Huntington Park, CA. 90255 y (323) 826-9771

In Northern California: 1904 Franklin St., Suite 600 y Oakland, CA 94612 y (510) 302-0430 

3

The SCAQMD argues that the Clean Air Act (CAA) does not specifically define an 

acceptable ratio of adopted rules to commitments above which EPA will approve a SIP.3

To the contrary, under the Clean Air Act, SIPs must include “enforceable emission 

limitations, and such other control measures . . . as may be necessary or appropriate to 

provide for attainment of such standard in such area by the applicable attainment date 

specified in this part.”4

 Moreover, in a recent Ninth Circuit case, the court found EPA’s 

approval of the Pesticide Element of the SCAQMD’s ozone SIP was arbitrary and 

capricious, because EPA approved the element even though EPA knew it failed to 

include enforceable commitments necessary to achieve the required reductions.5

 The 

CAA and case law both state that EPA cannot approve a SIP that relies on unenforceable 

commitments. 

The SCAQMD complains that 10% as the maximum amount of commitments 

allowed in an approvable plan is not a fixed number, that EPA is engaging in 

underground rulemaking by sticking to that number, and that the plan includes dozens of 

measures which can only feasibly be adopted over many years. 

A. The PM2.5 and Ozone Plan Must Include all RACM/RACT Necessary to Reach 

Attainment 

Since EPA found that the AQMD has not completed the required attainment 

demonstration, and since all RACM/RACT measures are required to be included, 

including those measures that significantly reduce the PM2.5 precursor pollutants NOx, 

VOC, and SOx,6

 SCAQMD must complete a new RACM/RACT assessment. This 

should include an updated assessment of all available control measures for direct 

emissions of PM 2.5, in addition to measures for control of secondary PM2.5 resulting 

from NOx, SOx, and VOC precursor emissions. 

Furthermore, since the 2007 AQMP is now a few years old and since we are 

almost at the point of the required “mid-course review” of the plan, it is important to 

reassess and update new measures, especially given the SCAQMD’s failure to 

demonstrate attainment. EPA describes the mid-course review below: 

 

3 SCAQMD, Comments on Docket No. EPA‐R09‐OAR‐2009‐0366, January 20, 2011, p. 3.   4

 42 U.S.C. § 7502(c)(6); 42 U.S.C. § 7410(a)(2)(A)

5 Assoc. of Irritated Residents v. U.S. Environmental Protection Agency, 2011 WL 310357, 8-9 (9th Cir. 

2011). See also Environmental Defense v. U.S. EPA, 396 F.3d 193, 210 (2d Cir. 2004) (EPA could “accept 

enforceable commitments in view of the fact that they represented only a small portion of an otherwise 

thorough plan”); Natural Resources Defense Council v. U.S. EPA, 22 F.3d 1125, 1134 (D.C. Cir. 1994) 

(EPA approval “cannot reasonably be made unless the conditionally approved submittal contains 

something more than a mere promise to take appropriate but unidentified measures in the future.”); Sierra 

Club v. U.S. EPA, 356 F.3d 296, 302-304 (D.C. Cir. 1994) (Where SIPs were missing elements, including 

a RACM analysis and implementation of RACM necessitated by the analysis, and “specific enforceable 

measures to offset growth in vehicle emissions and reasonably available control technology for additional 

major sources,” EPA could not “conditionally approve” the SIPs based on other, included measures and 

unenforceable commitments by the states. EPA may not grant conditional approval based “on nothing 

more than the States' promise to do next year what the Clean Air Act requires them to have already done.”). 6

 Ibid, pp. 64-65. 
5610 Pacific Blvd., Suite 203 y Huntington Park, CA. 90255 y (323) 826-9771

In Northern California: 1904 Franklin St., Suite 600 y Oakland, CA 94612 y (510) 302-0430 

4

Under 40 CFR § 51.1011 of the PM2.5 implementation rule, each area 

with an approved attainment date in 2014 or 2015 is required to submit a 

mid-course review by April 2011. The midcourse review is to include an 

updated attainment demonstration as well as a review of the 

implementation status of measures included in the April 2008 submittal 

and a review of recent air quality data, as well as new or revised control 

measures necessary to ensure attainment by the applicable attainment date. 

The midcourse review is in lieu of RFP milestone reviews or any other 

form of tracking to ensure reasonable progress in reducing emissions is 

occurring. See 72 FR 20586, 20641. 

A list of additional RACM/RACT measures, as part of a new, broader, and complete 

RACM/RACT assessment to demonstrate attainment expeditiously, includes, but is not 

limited to: 

• Industrial Boilers and Heaters. The AQMP must set BARCT standards for 

NOx and other precursors, and require replacement of old and severely inefficient 

equipment at oil refineries and for other large sources. This measure would not 

only help bring the region into attainment for criteria pollutants, but also serve to 

reduce CO2 emissions, making these measures more cost-effective. 

• Implement Industrial Energy Efficiency Audit standards. For example, under 

AB32, the State requires that audits be conducted, but does not yet require that 

any findings of these audits be implemented. Again, this measure would be 

doubly effective because it would reduce all pollutants, including criteria 

pollutants, toxics, and greenhouse gases. 

• Supplement SOx reductions. The AQMD must implement measures that were 

identified in the recent SOx RECLAIM regulation, but not adopted. 

• Improvements to the existing refinery Flare Regulation. The AQMD must 

require that each refinery have a Flare Minimization Plan that truly minimizes 

flaring, according to the methods demonstrated to be achievable by the Shell 

Martinez, CA and Flint Hills, TX facilities. Shell has shown that it could reduce 

flaring to almost zero, including in emergencies. While such episodic measures 

will probably not make a major dent in annual emissions levels, they could easily 

make a major difference in daily exceedances. Major flaring episodes that still 

occur regularly in the region not only cause very significant NOx and VOC 

emissions, but can also be major smoking events, that badly and directly increase 

particulate matter levels in the air. 

• Removal of methane exemption for VOCs. There is no longer an excuse for 

such exemptions in the VOC regulations. Harvard and Princeton studies show 

that methane is actually a reactive VOC. Methane is also a potent greenhouse 

gas. Removing these exemptions in the regulation is a reasonably available 

control measure, since the SCAQMD rules already control other VOCs. 
5610 Pacific Blvd., Suite 203 y Huntington Park, CA. 90255 y (323) 826-9771

In Northern California: 1904 Franklin St., Suite 600 y Oakland, CA 94612 y (510) 302-0430 

5

• Alternative energy use for oil refinery grid electricity use. Oil refineries use 

substantial electricity from the grid, which contributes to PM2.5 emitted by 

electrical power plants. Dependence on grid electricity has also caused major 

particulate matter emissions during power outages, because flares can be 

overwhelmed by the large volume of gases during unplanned complete shutdown 

and cause extreme heavy smoking for hours.. The solution is to have backup 

power. Requiring clean alternative energy backup power would provide the 

lowest emissions source of energy, and at the same time prevent refinery power 

outage emissions when grid power becomes unavailable. 

• Coke Drum Emissions control (not coke handling). The SCAQMD is in the 

process of developing a regulation controlling emissions from refinery coke 

drums. This rule controls emissions when coke drums are opened at the end of 

each cycle (close to twice a day). The amount of refinery coking (processing of 

the heaviest portion crude oil) is increasing due to the use of increasingly heavier 

crude used at oil refineries. The SCAQMD will likely complete the rule this 

year, and should adopt stringent limits for this source. The rule should also be 

added to the AQMP and SIP. 

• Require 33% RPS for all power plants within the SCAQMD. 

• Comply with RACM for Locomotive Measures. 

Several of these measures are detailed below. 

// 

// 

Industrial Boilers and Heaters

It is well known that there are varying degrees of age and efficiency of industrial boilers 

in use, in the South Coast District, and throughout the state. Newer boilers are 

generally far less polluting. Some are many decades old and extremely inefficient, 

others are less efficient for other reasons. Instead of requiring oil refineries to directly 

clean up emissions from boilers and heaters, oil refineries in the South Coast are allowed 

to buy credits through the AQMD’s RECLAIM process. This measure, by definition, 

does not produce the full reduction that is achievable and needed in the region, since it is 

clearly feasible to achieve the reductions from both the facilities selling credits to the 

refineries and, at the same time, from cleaning up refinery boilers and heaters. In that 

case, double the reductions that occur under RECLAIM would be achieved. An 

evaluation providing a listing of each industrial boiler and heater, the age, the type of fuel 

used and the emissions per unit of fuel should be carried out as part of a RACM 

demonstration. 

The State of California’s AB32 greenhouse gas regulatory process has recently 

performed part of such an evaluation, identifying quantities of emissions and means for 
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reducing fuel use and resultant greenhouse gas (GHG) emissions from these sources. The 

measures identified by CARB would also reduce criteria pollutants, including PM2.5 

precursors. In 2007-2008, CBE originally proposed to California Air Resources Board 

(CARB) a plan for replacing old industrial boilers and heaters and adding further controls 

to others, and the state responded by finding that such measures would be feasible. 

However, CARB ultimately decided instead to include these sources in a Cap and Trade 

regulation, where facilities could buy credits rather than be subject to direct controls. 

The attached CARB spreadsheet lists the measures they identified for reducing energy 

use from boilers and heaters.7

 For boilers, these include: replacing old boilers, 

optimizing efficiency by reducing excess air, retrofitting boilers with feedwater 

economizers, preheating air, blowdown reduction and feedwater cleanup, blowdown heat 

recovery, optimizing steam quality, optimizing condensate recovery, minimizing vented 

steam, insulation maintenance, steam trap maintenance, and steam leak maintenance. For 

heaters, the spreadsheet quantified achievable reductions from replacing old heaters, 

optimizing combustion, recovering flue gas heat, replacing refractory brick, and 

insulation maintenance. 

The spreadsheet provided by CARB does not separate out the SCAQMD sources from 

the statewide total, but certainly the SCAQMD could provide the separated data to show 

the reductions in energy use that would be achievable using the same means identified by 

CARB. The greenhouse gas emissions identified in the spreadsheet are calculated based 

on the fuel use, and by multiplying times an emission factor for CO2. The criteria 

pollutant emissions can also be determined doing the same calculations with criteria 

pollutant emissions factors. CBE performed those calculations for the statewide Cap and 

Trade public comment.8

 CBE calculated some co-pollutant emissions as a result of this 

process based on the CARB statewide data. EPA should require the same evaluation of 

fuel use, criteria pollutants, toxics, and GHGs to be done by the SCAQMD. Furthermore, 

EPA should require the SCAQMD to identify the age of all its boilers and heaters. The 

SCAQMD should demonstrate RACM for all Industrial Boilers and Heaters, and identify 

whether these measures have been applied. This RACM demonstration should not 

depend on buying or selling credits. Direct controls can achieve additional reductions. 

The State of California also previously found in its Early Action Items evaluation that 

measures for reducing energy use at Boilers and Heaters could save money:9

 

 

7

 California Air Resources Board, spreadsheets available on CARB website, under “Supplemental 

Materials: Compliance Pathways Analysis – Boilers, and Compliance Pathways Analysis –Heaters.” 

http://www.arb.ca.gov/regact/2010/capandtrade10/capandtrade10.htm. The two original CARB 

spreadsheets are also attached as “CBE Attach 01 to EPA PM2.5 - CARB Boilers Spreadsheet,” and “CBE 

Attach 02 to EPA PM2.5 - CARB Heaters Spreadsheet.” 8 CBE Comments on Draft Cap and Trade Regulation: Draft Cap & Trade Regulation Misses California 

GHG and Pollution Reduction Opportunities, Job Opportunities, and Contains Egregious Errors, 

December 14, 2010, attached as “CBE Attach 03 to EPA PM2.5 - Cap and Trade comments,” available at: 

http://www.arb.ca.gov/lispub/comm/bccommlog.php?listname=capandtrade10. 9 Expanded List of Early Action measures to Reduce Greenhouse Gas Emissions in California, 

Recommended for Board Consideration (attached, pages D-16 and D-17), California Air Resources Board, 

October, 2007, attached as “CBE Attach 04 to EPA PM2.5 - CARB Early Action Items,” available at 

http://www.arb.ca.gov/cc/ccea/meetings/ea_final_report.pdf. 
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ARB staff has identified two potential measures that could generate 

energy savings with minimal investment. The U.S. Department of 

Energy’s (DOE) Industrial Technologies Program helps industrial plants 

operate more efficiently and profitably by identifying ways to reduce 

energy use in key process systems. The program has identified that 

minimal improvements in burner efficiency can result in significant 

savings. The following case from the DOE website 

(www.eere.energy.gov/industry) provides an example of the potential 

savings: 

Case: Consider a 50,000 lb/hr process boiler with a combustion efficiency 

of 79% (E1). The boiler annually consumes 500,000 million Btu (MMBtu) 

of natural gas. 

At a price of $8.00/MMBtu, the annual fuel cost is $4 million. The 

installed cost is $75,000 for a new burner that provides an efficiency 

improvement of 2% (E2). 

The cost savings is: 

Cost Savings = Fuel Consumption x Fuel Price x (1 - E1/E2) 

= 500,000 MMBtu/year x $8/MMBtu x (1 – 0.79/0.81) 

= $98,760/year 

The simple payback on investment is: 

Simple Payback = $75,000 / $98,760/year = 0.76 year 

The table below shows the annual dollar savings for 1% and 3% efficiency 

improvements. 

Another paper authored by the John Zink Company and Chevron also found that there are 

methods available for reaching ultra-low NOx levels, while alsoat the same time saving 

money:10

 

10 Tim Webster, John Zink Company, Jim Seebold, et al, Chevron, Jerry Lang, Combustion Consulting, 

The Application of Gas Conditioning Technology for NOx Reduction on Five Water Tube Boilers, AFRC 

2001 Joint International Combustion Symposium, attached as “CBE Attach 05 to EPA PM2.5 - Chevron 

Boilers Gas Conditioning,” available at 

http://furnacesimulator.johnzink.com/products/burners/pdfs/tp_todd_app_gascond.pdf. 
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The result of this cooperative venture between Chevron’s NOx Reduction 

Project Team, Jerry Lang Combustion Consulting, and the John Zink 

Company was an innovative and cost-effective solution to a tough 

emissions reduction application. The LCF burners developed as part of 

this project have demonstrated the ability to provide over 90% NOx 

reduction and maintain safe reliable combustion performance. In addition, 

with the use of additional steam sparging, the burners are capable of 

reaching Ultra Low NOx levels of less than 7ppm. As a result of taking 

this innovative approach to finding a solution to their NOx problem, 

Chevron has seen a savings of over $7 million for the cost of the project 

and avoided an additional $1 million to $1.5 million a year in operating 

expenses. 

Such methods should be evaluated as part of a RACM/RACT process for industrial 

boilers and heaters as part of completing the required RACM/RACT analysis for the 

AQMP. 

Implement Industrial Energy Efficiency Audits Standards 

CBE proposed adding industrial energy efficiency audits and implementation for the 

2007 AQMP in order to reduce energy use and consequently reduce all pollutants, but the 

SCAQMD did not evaluate or include these proposals in the AQMP. CBE also proposed 

industrial energy efficiency audits at the State level. The State agreed and adopted a 

regulation requiring that these audits be performed in order to reduce GHGs, but stopped 

short of requiring that the measures identified in the audits be implemented. 

Because these audits will be carried out under CARB’s AB32 program, the SCAQMD 

has an excellent head start for supplementing CARB’s work in two ways: by requiring 

that the results of the audits be implemented; and, by expanding the regulation to cover 

more industrial sources, since the State’s proposal has some loopholes that leave out very 

large sources. An example of a loophole is the rule that if an oil refining company 

operates two halves of a refinery, but one of them does not sell products directly on the 

market, that one does not have to perform an audit, regardless of how big the emissions 

are or how inefficient the facility is. This is an illogical and unjustified exemption. The 

SCAQMD has an opportunity to close this loophole, and ensure that all large industrial 

sources, including oil refineries in the District, are audited. 

Energy efficiency audits and implementation are a very useful and important 

approach to reduce emissions because: 

1) Each refinery is customized; each has its own unique strengths, but also 

weaknesses, which can be corrected in a facility-wide energy use audit. 

Source-by-source regulatory programs might miss opportunities for reduction, 

because of the uniqueness of each refinery. For example, some refineries have 

boilers and heaters that are several decades old, and are completely outdated. 

These boilers and heaters have often been grandfathered into the regulations, thus 

able to avoid modern standards. Indeed, they are often hoarded as a source to 
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trade for emissions reductions during a refinery expansion, even though these 

sources could and should have been cleaned up long ago. Some refineries have 

most of their Pressure Relief Devices vented to controls, others dump them to 

atmosphere. As another example, the Bay Area AQMD (BAAQMD) did an audit 

of refinery gas systems after EPA found in 2001 that the AQMP did not include 

all RACM. The District was surprised to find that one of its refineries had an 

uncontrolled blowdown system with no flare attached, causing it to dump major 

emissions directly to the open air, unlike any other refinery in the Bay Area. 

2) Implementing energy efficiency measures reduces all pollutants, including 

PM2.5, as well as NOx, SOx, CO, VOCs, toxics, CO2, methane, and others. 

3) Energy efficiency audits have been demonstrated to result in big 

improvements. Several efficiency audits demonstrations are attached. For 

example, the Shell Martinez audit11 achieved more than 6,000,000 MMBtu (Mega 

British Thermal Units) per year reduction in energy use (that’s six million million 

Btus!). It reviewed the entire energy supply and use chain, including procurement 

of supplemental energy (usually natural gas and electrical power), conversion of 

chemical to thermal energy (combustion efficiency or conversion from electricity 

to horsepower), distribution efficiency (losses in getting the heat or power to its 

process use), and end use of energy in the refining process. Please see the 

attached sheet which identifies specific energy saving measures this audit 

identified as effective, including hydrogen system optimization (an important one, 

because hydrogen systems in refineries use a very large amount of energy, and 

hydrogen production is increasing to accommodate increasingly heavier, more 

contaminated crude oil). The list also includes minimizing pressure in distillation, 

waste minimization in boilers, flares, use of heat exchangers, etc., and many other 

specific measures. Another energy efficiency audit paper is also attached 

(Chevron Salt Lake City12). 

Since industrial energy audits reduce not only pollution, but also energy costs, they 

actually save money and should be required to be implemented as part of RACM/RACT 

in order to meet PM 2.5 requirements, as well as RACM for other criteria pollutants and 

GHGs. 

CBE took part in a public workshop at CARB regarding the development of CARB’s 

energy efficiency audit regulation. Because there are many unnecessary weaknesses in 

that final regulation, CBE objected to the form of the regulation. However, these 

weaknesses are easily fixed. For example, while CARB required companies to carry out 

the audits, it allowed the facilities to report only very vague information to CARB, and to 

 

11 U.S. Department of Energy, Martinez Refinery Completes Plant-Wide Energy Assessment, May 2001, 

Best Practices Assessment Case Studies, DOE/GO-102002-1618, attached as “CBE Attach 06 to EPA 

PM2.5 - 32615 Martinez energy efficiency,” available at http://www.nrel.gov/docs/fy03osti/32615.pdf. 12 U.S. Department of Energy, Chevron: Refinery Identifies $4.4 Million in Annual Savings by Using 

Process Simulation Models to Perform Energy-Efficiency Assessment, DOE/GO-102004-1759, May 2004, 

attached as “CBE Attach 07 to EPA PM2.5 - Chevron_Utah energy efficiency,” available at 

https://www.eecbg.energy.gov/industry/bestpractices/pdfs/petrol_cs_chevron_utah.pdf. 
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keep the details of the audit in the company’s possession, secret from the public. The 

reporting requirements are so weak as to make it impossible for the public to be able to 

verify the accuracy of the audits. The regulation also requires no reductions at all – no 

actual implementation of the audit findings. 

Importantly, however, the program demonstrates the feasibility of doing such audits, and 

CARB does publish information on its website about the program and the regulation, 

including reporting requirements and the types of energy efficiency measures that CARB 

evaluated, among other information. CARB’s website states: 

The AB 32 Scoping Plan approved by the ARB in December 2008, 

includes a measure requiring facilities emitting more than 0.5 million 

metric tons of carbon dioxide equivalent (MMTCO2E) annually to conduct 

an energy efficiency assessment of individual combustion and other direct 

sources of greenhouse gases to determine the potential reduction 

opportunities, including those for criteria pollutants and toxic air 

contaminants. This site is dedicated to the proposed regulatory effort for 

the Scoping Plan measure.

13

CARB found audits as a feasible measure; it is also Reasonably Available to the 

SCAQMD for reducing criteria pollutants, including PM 2.5. EPA should require audits 

be added to the AQMP in a strengthened form, with reduction targets attached. 

// 

Improvements to the Refinery Flare Regulations Requiring Flare Minimization 

Plans

CBE has been intensively involved in the development of refinery flare regulations for 

the last two decades. These regulations and preventive measures are important for local 

community health, and accident prevention. The SCAQMD and BAAQMD have both 

adopted important flare monitoring and control regulations, but with at least two 

differences. The BAAQMD requires all refineries to carry out Flare Minimization Plans 

(FMP).14 The SCAQMD only requires an FMP if the annual flaring emissions exceed 

certain thresholds. So far only one FMP has been performed in the South Coast. 

Performing an FMP at each refinery is a Reasonably Available measure. Shell Martinez 

is the model, as its FMP provides a rigorous method for achieving the tightest flaring 

limits. Shell Martinez achieved very low levels of flaring compared to all the other 

refineries due to it’s Flare Minimization Planning process, published in 2007.15 

 

13 http://www.arb.ca.gov/cc/energyaudits/energyaudits.htm. 14 Regulation 12, Miscellaneous Standards of Performance, Rule 12, Flares At Petroleum Refineries, 

attached as CBE Attach 08 to EPA Pm2.5 - BAAQMD rg1212 flares , also available at 

http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/Rules%20and%20Regs/reg%2012/r

g1212.ashx 

15 Shell Martinez Refinery, Regulation 12 Rule 12, Flare Minimization Plan, Redacted Version, submitted 

to the BAAQMD, Revised March 25 2007, attached as “`CBE Attach 09 to EPA PM2.5 -

shell_completed_fmp,” available at 
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The Flint Hills Texas facility also performed a rigorous FMP, and the methods have been 

published in the attached document.16 Even though adding a requirement for FMPs to the 

AQMP is not likely to achieve large annual reductions compared to emissions from 

continuous emissions sources, it is likely to achieve large reductions from short term 

PM2.5 emission levels. Because the SCAQMD focuses heavily on the annual emissions 

threshold, it allows large individual flaring events to occur without requiring an FMP. 

This is in contrast to the BAAQMD rule, and particularly contrasts with the achievements 

of the Shell Martinez refinery. 

There have been many very large flaring events occurring over the last several years in 

the District. CBE requested the flare data from the SCAQMD through a Public Records 

Act request two years ago, and a compilation of the large flaring events is attached.17 In 

addition, CBE put together the chart below from the SCAQMD data, showing that large 

flaring events continue to occur. The largest one was over 44,000 lbs in one day of SOx. 

(Flares are designed to be able to put out large emissions in a short time, even hours or 

minutes.) This figure charted SCAQMD SOx emission data, so it does not show whether 

smoking also occurred during these flaring events, but major flaring with smoking is 

common and has certainly occurred. The total reported SOx from these episodic events 

for 2009 was at least 175,000 lbs. This chart only includes the large flaring events. 

 http://www.baaqmd.gov/~/media/Files/Compliance%20and%20Enforcement/Flares/Redacted%20Update%

2010-15-09%20Submittal.ashx. Shell’s flaring emissions history is available on the BAAQMD website, 

where the flare data is published: http://hank.baaqmd.gov/enf/flares/. 16 Minimize Facility Flaring - Flares are Safety Devices that Prevent the Release of Unburned Gases to 

Atmosphere, 

J. Peterson, Flint Hills Resources, Texas, N. Tuttle, et al, John Zink Co., LLC, Oklahoma , Hydrocarbon 

Processing, 2007, attached as “CBE Attach 10 to EPA PM2.5 - Minimize Flaring Flint Hills 

hydro_proc_june_2007,” available at 

http://www.zinkco.com/products/flares/pdfs/flare_hydro_proc_june_2007.pdf. 17 “CBE Attach 11 to EPA PM2.5 - SCAQMD data compiled large flaring events 2009.” 
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Here are a few photos of smoking events that can occur due to oil refinery flaring and 

explosions (including events in the SCAQMD in recent years). The SCAQMD is also in 

possession of such photos and has taken air samples during such events. This shows 

graphically just how bad the particulate matter can get during a bad flaring event or other 

refinery accident. A good Flare Minimization Plan not only minimizes flaring, but 

improves safety, and minimizes such bad flaring events. 
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The EPA should require that the SCAQMD include modeling of large flaring events with 

heavy smoking to determine what PM2.5 levels would occur during a bad flaring event. 

EPA should require the SCAQMD to add a supplement to the flare regulation, requiring 

FMPs meeting the best of Shell Martinez or Flint Hills Texas BARCT limits for flaring. 

Removal of Methane Exemption for VOCs 

For many years, CBE has been asking the SCAQMD to remove the exemptions for 

methane from its rules during the rulemaking process. So far, the SCAQMD has done so 

for a single rule. CBE also asked CARB to require that methane exemptions in VOC 

regulations be removed statewide. CARB found this feasible, but did not carry out this 

proposal. 

Since EPA and SCAQMD have both found that additional VOC reductions are necessary 

to meet RACM/RACT requirements for the 2007 AQMP, and because it is now known 

that methane is a smog precursor in addition to being a potent GHG, EPA should require 

the SCAQMD to begin phasing out methane exemptions in its smog rules. 

CBE submitted comments to the SCAQMD during the 2007 comment period on this 

matter:18

Currently AQMD regulations exempt methane from the definition of VOCs:19

VOLATILE ORGANIC COMPOUND (VOC) is any volatile compound of 

carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic acid, 

metallic carbides or carbonates, ammonium carbonate, and exempt compounds. 

The exemption for methane can no longer be justified in any sense for oil 

refineries or any pollution source. Methane is not only a highly potent 

greenhouse gas (20 times more potent than CO2, and warranting aggressive 

control for this reason alone), it is also a key smog precursor (for ground-level 

ozone), and its reduction is highly effective in reducing smog. A Harvard study, 

Linking ozone pollution and climate change: The case for controlling methane20

found: 

“Methane (CH4) emission controls are found to be a powerful lever for 

reducing both global warming and air pollution via decreases in background 

tropospheric ozone (O3) ” 

 

18 CBE, Comments on Draft 2007 AQMP, (with comments opposing the Refinery Pilot Project pollution 

trading proposal and proposing direct refinery controls instead) March 30, 2007, attached as CBE Attach 12 

to EPA PM2.5 -CBE Comments SCAQMD 2007 AQMP Refineries.

19 SCAQMD Regulation 1, General Provisions, Rule 102, Definition of Terms (Amended Dec 3, 2004). 20 Fiore, et al, Harvard University, Linking ozone pollution and climate change: The case for controlling 

methane, 2002, USEPA/OAQPS MC: D243-01, attached as “CBE Attach 13 to EPA PM2.5 -fiore Harvard 

methane study,” available at http://www.gfdl.noaa.gov/bibliography/related_files/amf0201.pdf.
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The report was summarized in Environmental Science & Technology, Dec. 1, 

2002: 

“Aggressive efforts to improve urban air quality could be undermined by rising 

levels of methane, a compound more closely linked to global warming than air 

pollution. Using a global model of tropospheric chemistry, researchers at 

Harvard University, Argonne National Laboratory, and the U.S. EPA determined 

that higher methane levels could increase ozone background levels worldwide, 

lead to a greater frequency of days with high ozone levels in the summer, and 

produce a longer “season of ozone pollution days.”

“It is already known that methane is a major source of worldwide tropospheric 

ozone background concentrations, and this study supports that finding. However, 

the surprise is that a 50% reduction in anthropogenic methane in their scenario 

is as effective as a 50% drop in anthropogenic NOx concentrations at lowering 

summer afternoon ozone levels over the United States.” (page 452A) 

There is no longer any excuse for exempting this pollutant. The methane 

exemption in District regulations also makes enforcement more difficult – 

regulators must continually subtract methane from VOCs in order to apply 

controls. The subtraction of methane also makes VOC control look less costeffective than it actually is. It is essential that the VOC definition be modified to 

remove the exemption for methane. This will assist the AQMD in identifying 

additional VOC reductions. 

The AQMP21 separates the following individual refinery sources into Total 

Organic Gases (TOG which includes methane), and VOCs, which do not. This 

list is not inclusive of all refinery sources, for example, some refinery emissions 

are included in the RECLAIM category but not separately identified as refinery 

emissions. 

CODE 

Source 

Category 

TOG VOC CO NOx SOx TSP PM10 PM2.5 

40 PetroleumRefining 

(Combustion) 3.58 1.31 13.62 0.00 0.00 1.76 1.69 1.66 

320 PetroleumRefining 6.49 4.68 8.27 0.36 6.96 1.64 1.08 0.87 

Total 10.1 6.0 21.9 0.4 7.0 3.4 2.8 2.5 

According to the emissions sources listed in the chart above, TOG for refineries 

for these sources (presumably including methane as well as other organic gases) 

are 68% higher than VOCs (or ROG, not including methane). It is time for the 

District to control all organic gases from oil refineries. The District should also 

 

21 Attachment A to Proposed Modifications to Draft 2007 AQMP Appendix III, Annual Average Emissions 

by Major Source Cateogry, Table A-1, 2002 Annual Average Emissions by Source Category in South 

Coast Air Basin (Tons/Day) -- Excerpts related to Refineries. 
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review its current list of other TOG compounds now exempt, some of which 

although of lower reactivity, become more reactive after a few days of high 

temperature. 

Alternative energy use for oil refinery grid electricity use 

Like the methane exemption, CBE commented on this measure during the 2007 AQMP 

process, but this measure was not included in the AQMP by the SCAQMD, even though 

the District has made efforts to identify this problem. These efforts should be formalized 

into a RACM measure in the plan to avoid refinery power outages that cause major 

emissions, and to do this with clean alternative energy. CBE’s 2007 AQMP comments 

are still relevant: 

Electrical energy use at oil refineries results in many tons per day of air 

pollution 

Oil refineries use substantial amounts of electricity which is generated at power 

plants by burning fossil fuels. These emissions occur near the power plants, but 

also cause regional smog. Also, when reliability problems bring down the 

electrical grid, oil refineries shut down, causing upset conditions and huge air 

emissions near the oil refineries. Such an event happened in the fall of 2005, 

when major flaring occurred at several oil refineries in the District. 

Alternative energy sources including wind and solar energy are now readily 

available and viable alternatives for replacing fossil-fuel electricity generation 

used at oil refineries. Such alternatives need to be evaluated and required by the 

AQMD, and included in the AQMP. 

The following table was presented to the AQMD October 2006 AQMD Working 

Group. Those with moderate or higher risk of experiencing power outages can 

cause massive air emissions of dozens of tons of air pollution when power is lost 

and refineries shut down. Furthermore, on an ongoing basis, electrical energy 

use at refineries results in many tons per day of power plant emissions. 
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If the oil refineries were to replace either the percentage of electricity demand not 

covered by cogeneration capacity at each refinery (115 megawatts - MW), or 

replace all the electrical demand (452 MW) by clean alternative energy regardless 

of cogeneration capacity at the refineries, electricity not generated through fossil 

fuels or nuclear energy would result in many tons per day of emissions reductions 

calculated below. 

Information is available on emissions caused by power plants generated per 

megawatt hour. For example, PG&E published its 2002 Environmental report 

online22 which provides estimations of air emissions associated with generation 

of electrical energy. A table from the report is provided below, with air 

emissions in terms of pounds per megawatt-hour of energy. The two columns at 

the right are added to calculate daily emissions by power plants generating 

115MW or 452MW. 

 

22 PG&E 2002 Environmental Report, 2002 Performance Results , Air Emissions: NOx, SO2, Mercury, and 

Greenhouse Gases, available at 

http://www.pgecorp.com/corp_responsibility/environmental/report/2002/perf_results/02.html. 
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In a 24-hour period, refineries using 115 MW of electric energy continuously 

from fossil-fueled power plants results in 2.6 to 4.4 tons per day of SOx 

emissions and 1.1 to 1.8 tons per day of NOx emissions according to the data 

above. The total electrical energy use at the oil refineries of 452 MW 

continuously results in 10.3 to 17.4 tons/day of SOX emissions and 4.4 to 7.1 

tons per day of NOx emissions. This calculation assumes that emission rates at 

the power plants generating this electricity are similar to PG&E’s rates, and not 

similar to the higher National Average pollution rates on the chart above. Either 

way, clearly the large air emissions caused by fossil fuel generation at Power 

Plants due to oil refinery electricity demand is worthy of phaseout requirements 

by the AQMD as a measure in the AQMP. 

These calculations do not include VOC, CO, mercury emissions, greenhouse gas 

emissions or SF6 (sulfur hexafluoride) emissions, also identified by PG&E’s 

report. The emissions probably do not represent peak electricity use, which 

causes higher emissions. 

Please also note that the CBE 2007 AQMP comments discussed above and attached to 

this letter also identify additional measures that were not added to the plan by the 

SCAQMD. Please refer to these attached comments, which we incorporate by 

reference. 

RACM for Locomotive and Railyard Measures

The 2007 South Coast SIP Fails to Comply with RACM for Locomotive and 

Railyard Measures. Three documents attached to these comments provide evidence that 

the RACM analysis for locomotive emissions is deficient.23 These attached technical 

 

23 East Yard Communities for Environmental Justice, Comments to Mary Nichols and CARB re: “9/25/09 

Board Hearing Agenda Item No. 09-8-5: Public Meeting to Consider Staff Recommendations to Provide 
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reports and letters articulate several measures to reduce locomotive and other railyard 

emissions. The SCAQMD failed to analyze these Reasonably Available technologies in 

the AQMP, and accordingly, California and the District have not complied with RACM 

requirements. Assessment of these provisions to control locomotive emissions is timely 

given the recent ruling in Association of American Railroads v. South Coast Air Quality 

Management District, 622 F.3d 1094 (9th Cir. 2010). In that case, the Ninth Circuit 

determined that, although some local air district rules were preempted by federal law, 

“[b]ecause the District's rules have not become a part of California's EPA-approved state 

implementation plan, they do not have the force and effect of federal law, even if they 

might in the future. Accordingly, there is no authority for the courts to harmonize the 

District's rules with ICCTA.” Id. at 1098. Thus, the Ninth Circuit has indicated that the 

SCAQMD and the State of California have the authority to reduce emissions from 

locomotive sources through its determination that ICCTA may not preempt some 

measures included in a federally approved SIP. Accordingly, EPA should direct 

California and the SCAQMD to cure this defect. 

For these reasons, CBE supports EPA’s decision to disapprove part of the 

SCAQMD’s and the State’s for PM2.5 attainment, and urges EPA to require further 

RACT/RACM measures in the plan. 

Thank you for your attention to these matters, which are so crucial to the health of 

people in the region. We look forward to your response. 

Sincerely, 

 

 /s/ /s/ 

Julia May Maya Golden-Krasner 

Senior Scientist, CBE Staff Attorney, CBE 

 Further Locomotive and Railyard Emissions Reductions,” September 23, 2009, attached as “CBE Attach 

14 to EPA PM2.5 –EYCE 2009 Locomotive Comments,”; California Air Resources Board, Technical 

Options to Achieve Additional Emissions and Risk Reductions from California Locomotives and Railyards, 

August 2009, attached as “CBE Attach 15 to EPA PM2.5 –CARB Technical Options for Emissions and 

Risk Reductions for Locomotives and Railyards,”; Soil/Water/Air Protection Enterprise, Comments to 

Mary Nichols and CARB re: “Recommendations To Improve Air Quality And Reduce Cancer Risk To 

Communities Surrounding California Rail Yards,” September 22, 2009, attached as “CBE Attach 16 to 

EPA PM2.5 –SWAP 2009 Railyard Comments.”