Sacramento Regional 

8-Hour Ozone Attainment And 

Reasonable Further Progress Plan And 

Environmental Impact Report 

Public Comments and Responses on the Draft Plan 

January 8, 2009 
Attachment a 

Public Comments and Responses on the Draft Plan 
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Public Comments and Responses 

Public Workshop Comments (Vacaville, September 22, 2008) 

Participants: Jeanne LaPointe 

 Dave Wagenseil 

 Janice Stires 

 Toykea Jone 

 Aimee Pfohl 

 Mike Reed 

Comment #1: Why does Cool have a high level of ozone? (Plan presentation)

Response: Charles Anderson, Sacramento Metropolitan AQMD 

 The main reason that Cool is the peak ozone site is due to the effects of 

the region’s meteorology, geography, and air pollutant emission sources. 

Fresh pollutants of NOx and VOC are produced in upwind urbanized 

areas. As the day progresses, those pollutants accumulate in the air and 

react with sunlight under hot summer temperatures, which causes the 

formation of ozone. In the afternoon, ozone concentrations increase and 

Delta breezes tend to transport the ozone pollution to the Cool site later in 

the day. Grass Valley has a similar ozone situation. 

Comment #2: I understand the concept of the urban forest control measure, but there 

might be another aspect where the emphasis on other types of trees (low 

emitters) may have negative impacts. Has anyone taken a look at this 

aspect? I am concerned about the removal and planting of different tree 

species and their effects on the environment regarding types of insects, 

animals, disease, pollination, shallow or deep root systems that could 

cause damage, and other things. (Urban Forest control measure)

Response: Gordon Mann, Sacramento Tree Foundation 

 When we did the study we looked at a diversity of species and identified 

the trees that are best suited for the local environment as well as for air 

quality. We have a technical advisory committee to look into these issues, 

but we are looking at a wide variety of trees, not just two or three types. 

We will capture the right trees for the right areas and look at additional 

impacts. The tree lists change by area and the lists are not just emissions 

related. 
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Comment #3: Would places be eligible for emissions credits if they complied before the 

regulation is put into affect? Say if the regulation requires 9 ppm and we 

go down to 5 ppm. (Local control measures) 

Response: Matt Jones, Yolo-Solano AQMD

 The YSAQMD’s Emission Reduction Credit (ERC) rule is the 

administrative mechanism that allows us to certify surplus emission 

reductions. Section 201.2 of the rule states that once emission reductions 

are proposed as a part of measures to be adopted in a District Air Quality 

Attainment Plan, they can’t be considered surplus. So a source couldn’t 

receive ERC’s for replacing or retrofitting equipment to meet a certain 

limit as proposed in this plan in one of our control measures. However, if 

for example our proposed boiler rule specifies a NOx limit of 9 ppm and a 

source replaces or retrofits equipment that will bring their emissions down 

to 5 ppm, they could receive ERC’s for the incremental reduction (4 ppm). 

Comment #4: Are there any state or local funding mechanisms to help achieve the retrofitting of 

boilers to come into compliance? (Local control measures)

Response: Matt Jones, Yolo-Solano AQMD 

I don’t know. I know locally we don’t have any incentive programs at this 

point. If I hear of any state incentive programs in the course of this plan, I 

will be happy to let you know. 

Comment #5: Are you making contacts with the cities and counties, so they know what’s 

going on and how they will be impacted? (Local control measures)

Response: Matt Jones, Yolo-Solano AQMD 

They would be impacted by the plan in the sense that businesses and 

residences in their respective cities and counties would be impacted as a 

result of the rule changes we are proposing in the plan. Each air district 

has a Board of Directors that oversee the operations of the air district. 

The people that make up the Board are representatives from the 

respective cities and counties in that air district. For instance, in the YoloSolano air district, we have a 14 member Board. We have a 

representative from each city in our district and also supervisors from 

Yolo and Solano Counties as well. So in that respect, we've been keeping 

our Board informed of our proposed plan commitments. The in turn take 

this information back to their respective cities and counties.
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Comment #6: What is the process after you get comments on the plan? Is the plan 

going to change? (Local control measures)

Response: Matt Jones, Yolo-Solano AQMD 

All the commitments that are listed in the plan right now are the result of a 

detailed analysis we performed to determine which local measures could 

be feasibly implemented in our district to help get us to attainment of the 

ozone standard. We don't expect that we would add any regulations that 

aren't in this draft. If we get public comments that raise flags for one or 

more of our commitments, it would be helpful if the commenter could 

suggest an alternate way to achieve the equivalent emission reductions. 

This is because we have to show in this plan that we will get the 

reductions we need to achieve the standard by 2018. 

Comment #7: How has the transportation industry interacted with the plan about 

measures affecting locomotives and airports? (Local control measures) 

Response: Laura Lawrence, California Air Resource Board 

We have discussed the measures during a series of workshops 

throughout the state with transportation representatives as well as 

keeping in contact with officials to discuss their needs and requirements. 

 Matt Jones, Yolo-Solano AQMD 

 Also, I’d like to point out that as ARB just mentioned they have lots of 

workshops for their regulations. The local air districts have a workshop 

process for each rule they want to adopt. So it’s not like just by virtue of 

publishing this plan, that’s it. For each individual rule, there will be a 

workshop and rule adoption process as well. 
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Public Workshop Comments (Marysville, September 24, 2008) 

Participants: Brenna Christiano 

 Dan Tarailo 

 Camille Kustin 

 Nathan Ladd 

 Vaugh Minnix 

 Stephen Scheer 

 Ronald W. Garner 

 Philip Ireanor 

Comment #1: Why would the Air Resources Board rather continue to pollute instead of 

having sources install equipment that use manure methane in combustion 

engines to produce electricity? (Regional Measures, regarding dairy 

emissions) 

Response: Tim Taylor, Sacramento Metropolitan AQMD 

 There are benefits to doing this because it helps reduce some emissions. 

However, it would substitute these emissions (ROG and other green 

house gases) for of pollutants, including NOx. NOx emissions are more 

important to ozone formation in our region than the hydrocarbon 

emissions (ROG) from uncontrolled methane. It is not desirable to trade 

ROG for NOx. 

Comment #2: I just want to confirm that you can only take credit for up to 0.48 tons per 

day even though reductions are about 0.84 tons per day? (Urban Forest 

control measure) 

Response: Janice Lam, Sacramento Metropolitan AQMD 

 Yes, due to the EPA cap on emissions reductions from emerging and 

voluntary measures, only 6% of the emissions shortfall for attainment can 

be claimed. 

Comment #3: Do these (truck) regulations (referring to the light/medium category under 

the mobile emission inventory pie chart) include pick up trucks? (State 

control measures) 

Response: Charles Anderson, Sacramento Metropolitan AQMD 

 Pie chart under light/medium duty category does include pickup trucks. 

These regulations include pick up trucks running on gas and diesel fuel. 
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Public Workshop Comments (Sacramento, September 25, 2008) 

Participants: Jon Ellison 

 Christine Cahill 

 Paul Buttner 

 Susan Wilson 

 Chelsea Sand 

 John Motsinger 

 Marco Lemes 

 Anne Marie Vineent 

 Anissa Routon 

 Brandon Rose 

 Bree Tayler 

 Joe Crummett 

 B. Wood 

 Dan Tarailo 

 Camille Kustin 

Comment #1: First of all, I want to say this is a really great approach, another 

component to air quality. I have two questions. First, do you have 

somewhere available to look at the list of trees in the different categories? 

(Urban Forest control measure) 

Response: Janice Lam, Sacramento Metropolitan AQMD 

 We have a preliminary list now. If you leave your contact information I can 

send you the list.

Comment #2: Secondly, with new development, especially with DOT wanting to create 

more walkable streets and have separated sidewalks, how do the trees in 

the low emitting category intersect [match up] with shade trees versus 

other types of trees? So if you want to put in a lot of low emitting trees 

along the street where you want pedestrians to walk, do some of those 

trees include shade trees? (Urban Forest control measure) 

Response: Gordon Mann, Sacramento Tree Foundation 

 The way we are developing the lists for the trees is we are evaluating the 

trees first for their suitability to the urban area. So each region will 

probably have its own list that is suitable for that urban area. Then we will 

take that suitability list and rate it for the air quality. So we will try our best 

to match trees best suited for the area with the best air quality trees and 

meet the ratio that we are targeting. 

Comment #3: Do most of the reductions take into account urban growth and sprawl 

which is cutting down oak tree forests or oaks in the foothills and 

replacing it with new types of trees? (Urban Forest control measure) 

Response: Gordon Mann, Sacramento Tree Foundation 

 The current proposal accounts for trees that come down just under 

normal removal and replacement trees to keep our existing canopy. We 

are working with agencies to enhance the urban forest with their 

development as part of the Greenprint which coincides with Blueprint 

growth areas. 
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Comment #4: I would encourage more precaution as I see the expansion south of 

highway 50 covered in oak trees. So I think that is definitely an area that 

should be further examined, and I don’t know if you are taking that into 

account what I just mentioned. (Urban Forest control measure) 

Response: Larry Greene, APCO 

 This control measure does not direct the removal of native trees in the 

area due to development. The control measure focuses on replacing 

trees that naturally die or are removed based on other issues such as 

safety or natural disasters. The Sacramento Tree Foundation will ensure 

the right kind of trees that benefit air quality, emit lower BVOC, and that 

are good for the environment are planted. The Greenprint Initiative, which 

is lead by the Sacramento Tree Foundation, is a multi-decade regional 

framework by expanding urban forests and optimizing the benefits of tree 

canopies. Under Greenprint, trees will be added to newly developed 

areas and will expand the urban forest and increase the tree canopy 

cover in the area. The air district understands that cutting down trees is a 

very difficult and sensitive issue people are concerned about. Our Plan’s 

Environmental Impact Report will address this issue. 

 Gordon Mann, Sacramento Tree Foundation 

 For the aspect of the control measure, it’s just looking at reducing the 

BVOC and the removal of trees actually helps that. But it doesn’t help the 

other benefits that we get from trees that we are all concerned about. So 

from this aspect the removal of trees doesn’t affect the control measure, 

but there are other affects that we would want to deal with. 

 Environmental Audit, Inc. 

 The impact of the Urban Forest Control Measure was evaluated in the 

Notice of Preparation/Initial Study (NOP/IS) under Biological Resources 

(see EIR, Appendix A, pages 2-10 and 2-11) and summarized in the EIR 

on page 3-54. The NOP/IS evaluated the potential biological impacts of the 

Urban Tree Forest Expansion measure. The NOP/IS concluded that the 

measure would encourage additional tree planting. The trees were expected 

to be planted in urban areas as part of landscaped vegetation and were not 

expected to displace any native habitat. It was also expected that guidance 

to implement this control measure would be developed that would also 

consider that certain trees are protected species and should be preserved. 

Since the preparation of the NOP/IS, the Urban Tree Forest control 

measure has been modified. The measure is now aimed at replacing 

existing trees that die off with lower VOC generating trees rather than 

planting additional new lower VOC trees. Therefore, fewer low VOC 

emission trees are expected to be planted under this control measure but 

the conclusions of the NOP/IS remain the same, i.e., the biological impacts 

of this control measure are expected to be less than significant. 
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Comment #5: Regarding the IC engine NOx control measures, this is just to pull in 

minor sources and will there be any changes for major sources? (Local 

Control Measures) 

Response: Aleta Kennard, Sacramento Metropolitan AQMD 

 At this point in time, basically we are not looking at revising those limits 

[for major sources] at least as far as this control measure. As we go 

through the workshop process if anything is identified that could be further 

evaluated, then we will evaluate that in the rule development. But right 

now its mostly bringing in the minor sources or smaller sources. 

Comment #6: It says on the diesel truck flyer that there’s a December 2008 board 

hearing? Do you know when that is exactly? (State Control Measures, 

proposed state regulations) 

Response: Laura Lawrence, California Air Resources Board 

 Yes, that is right. I think it is December 11-12. The Board dates are on our 

Web site. If you can leave me your comments, I can get back to you. 

Comment #7: How does gardening equipment fit into all of this? Leaf blowers and lawn 

mowers? (State Control Measures) 

Response: Laura Lawrence, California Air Resources Board 

 Gardening equipment items that are smaller than 25 horsepower would 

fall under a smaller engine rule. They are governed by an existing CARB 

small off road engine regulation. No new CARB regulation changes are 

proposed in this plan. EPA has just recently adopted a new standard. In 

addition, there are district incentive component for lawn mower. I would 

be happy to provide you with a contact and more information on it. 

Comment #8: You had rules adopted this morning for fuel tanks for marine vessels. Is 

that a part of the previous SIP and not this SIP? Is that why you’re not 

showing any additional reductions? (State Control Measures) 

Response: Laura Lawrence, California Air Resources Board 

 No, it’s a part if this SIP but the reduction for the marine rules is very 

small for the Sacramento area. Those reductions are bigger in the coastal 

regions. 
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Page 33 of 56 January 8, 2009

Letter from Blain Stumpf, BST Service Inc. (September 4, 2008) 

Comment #1: If the Federal Regulations set in 1997 have been since reviewed? 

 Did California ever contested the standard? 

Response: The United States Environmental Protection Agency (USEPA) released the 

1997 8-Hour Ozone Standards on September 16, 1997. The 1997 standard 

has gone through public reviews and comment processes that required by the 

Federal Clean Air Act (CAA). The 1997 ozone standards were upheld by the 

U.S. Supreme Court in Whitman vs. American Trucking Association. 

 The Federal CAA Section 109(d)(1) requires that the USEPA review the criteria 

pollutant standards on a regular time interval. The USEPA Administrator will 

consider the recommendation from the Clean Air Scientific Advisory Committee 

(CASAC) and some other factors (technology availability and costeffectiveness evaluation) to determine the National Ambient Air Quality 

Standards (NAAQS). The CARB submitted comments during the development 

of the new NAAQS on June 21, 2006. CARB had concerns regarding the role 

of CASAC in the reviewing process of the NAAQS. The letter can be found 

under http://www.epa.gov/ttn/naaqs/carb.pdf. In March 2008, the USEPA 

released a new standard which lowers the ozone standard from 0.08 ppm to 

0.075 ppm. The 1997 standard and the implementation rules for that standard 

will remain in place for implementation purposes as USEPA undertakes 

rulemaking to address the transition from the 1997 ozone standard to the 2008 

ozone standard. 
Public Comments and Responses on the Draft 

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Page 34 of 56 January 8, 2009

Letter from Scotty DuPriest, Otto Construction (September 4, 2008) 

Comment #1: My only comment is that at a time when the economy is not doing so well, 

when budgets are lean, and costs are high, this new industry that is being 

created by your organization on the backs of the Contractors is not a very well 

thought out concept. We all know that the main polluter of our waterways is the 

storm drains that are continuing to receive the run-off from people like you and 

me and our homes and city streets. New construction only disturbs only 

6/10ths of 1% of the entire states exposed soil areas and with the construction 

downturn will be much less for 2009 and on. You essentially left the lion’s 

share of the contamination source alone and it will increase as long as people 

continue to water lawns and wash and drive cars. The plan you are proposing 

has no endgame or goals that are realistic or will show up in any significant 

way scientifically as working to solve the problem. Apparently from what I read 

and the backers of the plan (lawyers) who’s only affect is a litigious feeding 

frenzy for noncompliance and the complexity of the plan in general seems very 

short sighted and difficult. You’ve all bought into this plan and your jobs will be 

secure as long as there continues to be contractors who can remain afloat 

during these tough economic times and are willing to shell out large sums of 

money to test the clarity of construction activity water while the average home 

owner will fertilize, water and wash all the driveways down without even a 

thought of the pollution created by the masses. 

Response: The Sacramento Metropolitan Air Quality Management District and other 

agencies prepared this plan do not have authority over water quality issues. 

The Air District encourages you to contact California Water Resources Control 

Board or U.S. Environmental Protection Agency to express your comments. 

The objective of this Sacramento Regional 8-Hour Ozone Attainment and 

Reasonable Further Progress Plan and Draft Environmental Impact Report is 

to address the air quality issues in the Sacramento Area. High concentrations 

of ground-level ozone are harmful to human health. It can aggravate 

respiratory diseases, increase cardiovascular problems, cause premature 

death, and cause damage to crops and natural vegetation. This plan includes 

technologically and economically feasible control strategies to lower the 

harmful air pollutants by the federal mandated attainment date.
Public Comments and Responses on the Draft 

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Page 35 of 56 January 8, 2009

Letter from Mr. Ed Welch, Save the Air in Nevada County (September 25, 2008)

Comment #1: I would love to hear your opinion about whether it is good for Nevada County to 

be outside the Attainment Area. I have read a report concerning the issue, but 

it still seems questionable. In the report, it says that Nevada County will 

essentially maintain stronger autonomy to be outside the area. If we were in 

the area, our county would be subject to Sacramento AQMD oversight and 

regulations, and our county would likely be subject to Federal sanctions placed 

on the Sacramento area, loss of highway money, etc. I understand that, but 

Western Nevada County is not in attainment either and will likely stay out of 

attainment as long as the Sacramento area. So by being out of the attainment 

area, we lose our voice in the Ozone Plan, we still are susceptible to Federal 

sanctions, and we are not included in any number of programs within the 

attainment area. What gives? NSAQMD has more autonomy, but they only 

have three air pollution employees in Grass Valley and very tiny programs 

anyway. 

Response: The boundaries for federal nonattainment areas are determined by the U.S. 

Environmental Protection Agency (EPA). Area designations for the 1997 

federal 8-hour ozone standard were made in 2004 (69 FR 23858, April 30, 

2004). The California Air Resources Board (CARB) first recommended 

boundaries to EPA. Along with information and recommendations provided by 

the State, EPA boundary guidance for 8-hour ozone nonattainment areas 

suggests the consideration of various air quality related factors. These factors 

include: emissions (sources, location, and control), air quality and monitoring 

data, population density and urbanization, traffic and commuting patterns, 

expected growth, meteorology, geography, and jurisdictional boundaries. 

Additional information can be found on EPA’s designation Web site at: 

http:/www.epa.gov/ozonedesignations/ 

 During the development and review process for the Draft Ozone Plan, the 

Northern Sierra AQMD and interested Nevada County residents were 

contacted and encouraged to provide their input. Sacramento Metropolitan 

AQMD staff participated in various public meetings in Nevada County 

regarding air quality and the ozone planning process. Comments from Nevada 

County are taken into consideration along with comments from the Sacramento 

nonattainment region. 

 The Sacramento Metropolitan Air Quality Management District (SMAQMD) 

does not have oversight authority over the other air districts in the Sacramento 

Federal Nonattainment Area (SFNA). Oversight authority rests with ARB and 

EPA.
Public Comments and Responses on the Draft 

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Page 36 of 56 January 8, 2009

Letter from Mr. Ed Welch, Save the Air in Nevada County (October 9, 2008) 

Comment #1: Does the photochemical modeling account for the increased temperatures that 

are predicted for the region? If not, it is not factoring in increased ozone 

production from higher temperatures, as well as potentially increased biogenic 

VOCs from the higher temperatures. 

Response: The impact of future climate change is not included in the photochemical 

modeling assumptions. In the view of CARB modeling experts, the temperature 

changes during the timeframe of this SIP will likely be small enough to have 

very little impact on the model results. Effects of climate change would be 

speculative in the short term, and impacts on the region’s ability to attain will be 

tracked through the reasonable further progress (RFP) process. 

Comment #2: The plan focuses on reductions to 84 ppb instead of the new 75 ppb standard. 

By 2017, when Western Nevada County is expected to be in compliance, the 

75 ppb standard will have been in existence for 9 years. Why is this plan not 

accounting for reductions to the lower standard? (See p. 1-3 and 2-4) 

Response: The Clean Air Act requires for the new 8-hour ozone NAAQS (73 FR 16503, 

March 27, 2008) that EPA make final designations by March 2010. The 

deadlines for submitting nonattainment area State Implementation Plans (SIPs) 

will be 3 years after final designations (2013). This plan to attain the 1997 8-

hour ozone NAAQS will provide reductions essential to meet the 2008 NAAQS, 

but additional controls may be needed. The current plan includes all 

reasonably available control measures (RACM). The plan for the new 2008 

ozone NAAQS will re-evaluate RACM based on technological advancements 

between now and 2013. 
Public Comments and Responses on the Draft 

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Page 37 of 56 January 8, 2009

Comment #3: Attainment in Sacramento (and therefore Nevada County) is predicated on 

attainment in the Bay Area and the San Joaquin Valley. (See p. 1-10 and 9-2) 

Are their State Implementation Plans (SIPs) showing sufficient reductions for 

Nevada County to achieve attainment by 2017? 

Response: CARB modeling for the attainment demonstration for the Sacramento 

nonattainment area used domain-wide emission reductions to characterize 

future ozone reductions at peak ozone monitoring stations. Therefore, for our 

area to attain, the reductions in forecasted emissions necessary and committed 

to in Sacramento must also be achieved in the areas that significantly impact 

the region. In other words, the attainment demonstration for the Sacramento 

nonattainment area is predicated on the San Francisco Bay Area and the San 

Joaquin Valley also achieving an equivalent additional percent reduction of 

NOx emissions in their forecasted 2018 inventory. 

 The reductions could come from either state or upwind regions’ local 

measures, but we understand that CARB has committed to address the 

reduction requirement by implementing the new state measures statewide. The 

CARB attainment demonstration for Sacramento has not quantified state 

measure benefits in the Bay Area or the impact of Bay Area transport. 

However, it is likely that the state measures will achieve the percent reductions 

in the Bay Area and San Joaquin Valley similar to the percent reductions from 

the 2018 emission inventory forecasts for the Sacramento region. 

Comment #4: What is the 2007 VOC emissions data for on-road vehicles? The drop from 

2002 to 2011 in Table 5-2 seems precipitous. (See p. 5-6) Where does it stand 

now? 

Response: The VOC emissions for on-road vehicles in 2007 are estimated at about 47 

tons per day for the Sacramento nonattainment area. The significant drop in 

VOC emissions between 2002 and 2011 (64 to 38 tons per day in Table 5-2) is 

mainly due to the fleet turnover of older on-road light duty gasoline motor 

vehicles to cleaner newer vehicles assumed in the California Air Resources 

Board EMFAC2007 on-road vehicle emissions model. Additional information on 

the on-road vehicle emissions inventory can be found on the CARB website: 

http://www.arb.ca.gov/msei/onroad/on-road.htm 
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Page 38 of 56 January 8, 2009

Comment #5: Recreational boats are the highest single source of VOCs in the nonattainment 

area from 2011-2018 (See Table 5-2 on p. 5-6). What is being done in the plan 

to address this emissions source? 

Response: The California Air Resources Board (CARB) is responsible for controlling 

emissions from recreational boats in the state. CARB has proposed a new 

state measure for establishing lower emission standards for recreational boats. 

(See Table 7-1 in Draft Ozone Plan.) They plan to adopt catalyst-based 

exhaust standards for new outboard and personal water craft (jet ski) engines 

and evaporative emission standards to address all sources of recreational boat 

evaporative emissions. Implementation of the new exhaust standard is 

expected to be phased in by 2013, and the evaporative standard by 2012. 

CARB anticipates this measure could achieve VOC emission reductions of 

about 3 tons per day for 2018 in the Sacramento nonattainment area. 

Additional information on the recreational boats control measure can be found 

on the CARB website: 

 http://www.arb.ca.gov /planning/sip/2007sip/2007sip.htm 

Comment #6: On-road motor vehicle emission reductions are significant from 2002-2018, but 

the population over that same time frame increases by about a million people. 

(See table 5-9, p. 5-14) How is this possible? 

Response: Population and vehicle miles traveled (VMT) are forecasted to increase by 

about one third from 2002-2018 for the Sacramento nonattainment area. The 

forecasted decline in on-road motor vehicle emissions of about 60% during this 

period is mainly due to the fleet turnover of higher polluting older cars and 

trucks to cleaner newer vehicles assumed in the California Air Resources 

Board EMFAC2007 on-road vehicle emissions model. Existing CARB control 

strategies include requiring more stringent exhaust and evaporative emission 

standards and incentive programs to accelerate the retirement of older 

vehicles. Additional local control measures include incentive programs to 

promote the use of vehicle technology improvements. These state and local 

control strategies are expected to continue to be very effective in reducing 

future on-road vehicle emissions, despite the growth in population and VMT. 

Additional information on the on-road vehicle emissions inventory can be found 

on the CARB website: http://www.arb.ca.gov/msei/onroad/on-road.htm
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 39 of 56 January 8, 2009

Comment #7: Has the "modeled attainment test" (See p. 6-2) been conducted for the Grass 

Valley monitor? The text reads that "...the State is responsible for other nearby 

counties or areas outside the nonattainment area to address downwind 

influence." If this test has not been conducted for Grass Valley, is the Air 

Resources Board responsible for ensuring that testing is conducted? 

Response: The attainment demonstration for each region relies on photochemical 

modeling of future ozone concentrations in a given year. The photochemical 

modeling is done over the entire domain of the Central California Ozone Study, 

which includes Nevada County. The California Air Resources Board (CARB) 

has completed modeling to support a Sacramento Nonattainment Area 

attainment demonstration for 2012 (for a 2013 attainment date under the 

“serious” classification) and 2018 (for a 2019 attainment date under the 

“severe-15” classification). 

 Nevada County was designated nonattainment by U.S. EPA under subpart one 

of the Clean Air Act, which was later vacated by the courts. As a result of this 

court decision, EPA must redesignate all former subpart one areas. At the time 

of the redesignation, EPA will establish an attainment deadline for Nevada 

County. If either a 2013 or a 2019 deadline is assigned, then appropriate 

modeling has been completed for Nevada County’s attainment test. If another 

year is assigned, new modeling may need to be completed. CARB is 

responsible for conducting the modeling. 

 This is a rather unusual situation. Generally, EPA would designate all areas at 

the same time, and local plan elements for all nonattainment areas in the state 

would be developed more or less simultaneously. 

Comment #8: What are the funding mechanisms for the Further Study Measures outlined in 

Section 7.20 (p. 7-28)? The emissions reduction benefits from these measures, 

particularly Urban Heat Island and Energy Efficiency, could be substantial. 

Does the study of these measures have a dedicated funding source, and if so, 

what level of funding is being provided? 

Response: Additional funding may not be needed to complete the Further Study Measures 

outlined in Section 7.20. The Sacramento region is currently working with 

several other districts that have also committed to similar Further Study 

Measures to determine if our needs can be partially or fully met with studies 

that are already planned and funded elsewhere. These Further Study 

Measures may benefit from efforts undertaken by industries affected by the 

greenhouse gas (GHG) strategies included in by the California Air Resources 

Board’s (CARB) AB32 Scoping Plan. This potential overlap may result in 

additional partners seeking the same analytical answers. 
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 40 of 56 January 8, 2009

Comment #9: On page 9-3, the document states that "Ultimately, CARB is responsible for 

ensuring that Nevada County meets its federal attainment requirements." 

Please explain that statement more fully. Does it mean that the Sacramento 

Metropolitan AQMD has no legal or regulatory responsibility and/or authority for 

Nevada County's ozone attainment? 

Response: Section 110(a) of the Clean Air Act requires each state to submit a State 

Implementation Plan (SIP) that provides for attainment of the NAAQS in each 

air quality control region (or portion thereof) within the state. Also, in the “Final 

Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard – 

Phase 2” (70 FR 71612, November 29, 2005), U.S. EPA indicated that the 

Clean Air Act requires individual states to deal with intrastate transport. The 

CARB has adopted specific responsibilities and requirements for upwind air 

districts as part of state plan obligations.
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 41 of 56 January 8, 2009

Letter from Greg Rowe, Sacramento County Airport System, (10/24/2008) 

Bump-up and General Conformity

Comment #1: The new threshold increases the burden for the SCAS to limit emissions, while 

developing projects to meet public transportation needs and demands. The 

new threshold also lowers the level at which future emission increases would 

have to be fully offset. ..., the SCAS is incorporating air quality improvements 

into development plans and projects it manages. Although the estimates in the 

Sacramento International Airport (SMF) Master Plan Final EIR indicate that 

short-term potential growth will be below the lowered de minimis threshold, the 

emission growth at all regional airports needs to be carefully considered, so 

that near-term and long-term budget will accommodate required future growth. 

Response: The Air District appreciated that the SCAS took considerations of the bump-up 

for ozone precursor pollutants when preparing the Sacramento International 

Airport Master Plan Final EIR. The Air District staff will work closely with SCAS 

staff to ensure future development and growth meets the general conformity 

requirement and accommodates required future growth. 
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 42 of 56 January 8, 2009

Aircraft Emission Budget

Comment #2 It is unclear if and how the growth of aircraft operations within other counties in 

the Area Basin was included. Thus, the SCAS remains concerned that growth 

at airports in other counties might be inadvertently under-forecasted and that 

future air services at Sacramento County airports, especially SMF may be 

constrained. 

Response: Growth of aircraft operations for other airports in the Sacramento Federal 

Nonattainment Area (SFNA) counties is based on California Air Resources 

(CARB) growth profiles for aircrafts developed specifically for each county. The 

growth profiles are based on California State University, Fullerton (CSUF) 

scenario of flight operations, and were updated to California Emissions 

Forecasting System (CEFS) on December 19, 1997. Thus, the aircraft 

emission forecast is growing independently for each county based on its 

aircraft activity growth profile. 

 The FAA Airport Data (5010) as of September 2008 shows that aircraft activity 

at Sacramento Federal Nonattainment Area (SFNA) is mostly general aviation 

operation (98%). Sacramento County is the only county in SFNA has 

commercial aircraft operations. Aircraft inventory and forecast will be updated 

as better activity data and estimation method become available. 

 The table below shows the 2002 inventory for SNA aircraft operations. 

 2002 Aircraft Emissions, Ton/Day

Area ROG %ROG NOX %NOx

Sac County 0.45 81.82% 1.6100 98.05% 

Yolo 0.03 5.45% 0.0185 1.13% 

Solano(SV) 0.01 1.82% 0.0096 0.58% 

Placer(MC+SV) 0.02 3.64% 0.0003 0.02% 

South Sutter 0.03 5.45% 0.0032 0.19% 

El Dorado(MC) 0.01 1.82% 0.0005 0.03% 

Total SNA 0.55 100.00% 1.6421 100.00%
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 43 of 56 January 8, 2009

Ground Service Equipment (GSE) Emissions Budget

Comment #3: The SCAS concerned that the SIP emissions budgets shown in Table 12-1 for 

regional GSE may be incomplete. These budgets are expected to decline in 

the future, even as more GSE services will be required for additional future 

aircraft operations. Review of the Off-Road Appendices to the Draft SIP shows 

only 217 GSE items were included in the 2002 regional emission estimates. 

The number of GSE items in the entire air basin is expected to increase to 326 

by 2018. ..., all the GSE are shown to be located in Sacramento County, and 

no GSE emissions are estimated out of Sacramento County. The current and 

projected GSE emissions may be underestimated, because the equipment 

needed to provide aircraft ground services at non-Sacramento County airports 

has not been included. Small Airports such as Woodland and Yolo County do 

deploy GSE for aircraft towing. 

Response: GSE emissions are determined through CARB’s OFFROAD model and are 

calculated for the state and allocated to each county based on commercial 

aircraft activities. Thus, the GSE for Sacramento/Sacramento Nonattainment 

Area (SNA) is based on number of the commercial aircraft operations in 

Sacramento/SNA relative to that of other areas in California. Since other SNA 

districts do not have commercial aircraft operations, there is no GSE emissions 

allocated to these districts. Though GSE is only allocated to Sacramento, it 

should represent GSE for the nonattainment area. 

 Emission inventory is undergoing improvement continuously. As better data 

and methodology become available, the inventory is updated. CARB 

OFFROAD model accounts for the anticipated reductions from offroad 

equipment regulations. Airport budget, like the transportation budget, reflects 

anticipated future year emission reductions from adopted regulations. District 

will work with CARB to improve the inventory. 

Comment #4: Future Estimates for VOC and NOx emissions from GSE activities at all 

airports in the entire Air Basin may not be sufficient unless aggressive 

assumptions about equipment replacement and regulatory enforcement are 

made. New regulations have been adopted by the CARB for off-road 

equipment, including airport GSE. The requirement to rapidly phase-in low 

emission off-road engines is an important goal of these regulations. The 

airlines and their contractors own and operate a variety of specialized GSE to 

service particular types of aircraft. Airport operators do not regulate or in any 

way otherwise dictate the types of equipment to be used. The local air districts 

and CARB will be responsible for enforcing the off-road regulations with the 

individual tenants at each of the regional airports. 

Response: Comment noted. 
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 44 of 56 January 8, 2009

Closing

Comment #5: The SCAS provided infrastructure to encourage the use of alternative fuels or 

electricity by their tenants. However, the SCAS cannot dictate the types of 

aircraft or other equipment that their tenants may choose to operate. The 

decisions of the tenants are based upon financial considerations, which 

become even more critically important during these difficult economic times. 

Response: We applaud the airport’s decision to provide infrastructure to encourage 

airlines to use less-polluting energy sources. 

 Airport GSE projects may be funded by the Carl Moyer Program or the 

Department of Motor Vehicles (DMV) surcharge on registration fees. The 

region has provided limited funding for alternative fuel infrastructure to those 

fleets that have made a significant commitment to alternative fuel use within 

their fleets and to the community. We encourage the SCAS and their tenants to 

replace their existing compression ignition or spark ignited equipment with new 

zero emission technologies, and work with the airlines to commit, via airline 

contracts, to the use of zero emission GSE fleets operating at the SCAS 

airports. 

Comment #6: The SCAS wishes to clarify a statement in Section 12.5 of the Draft SIP, which 

was repeated in the Draft EIR. The first paragraph in the Section 12.5 states as 

follows: Sacramento County airports include: SMF, Mather, Executive, 

McClellan, Franklin, Rancho Murieta, Sunset, Natomas, and Rio Linda.” 

Readers could infer from this sentence that the SCAS operates a total of nine 

airports, which is not the case. For clarity, the SCAS suggest the paragraph be 

revised as follows. 

 The Sacramento County Airport System is comprised of four airports: 

Sacramento International (SMF), Mather (MHR), Executive (SAC), and Franklin 

(F32). In addition, the County Airport System manages the aviation activities at 

McClellan Airport on behalf of another County agency. Four private airports 

also operate in Sacramento County: Natomas, Rancho Murieta, Rio Linda, and 

Sunset. 

Response: Thank you for your updated information for the airports description in the 

Sacramento County. We will incorporate your suggested paragraph in both of 

the Plan and the EIR. 

Comment #7: Natomas Airport was closed in 2000, is no longer, and should not be included 

in the SMAQMD inventory of county airports. 

Response: Comment noted. The Air District will update the text in the plan. However, it is 

not possible for the SMAQMD to update the emissions inventory at this stage 

of the plan. When SMAQMD staff prepared the airport emissions inventory, it 

was based on the 1999 airport survey results and projected to 2002 emissions. 

Information available at the time when SMAQMD prepared the inventory did 

not indicate that the airport was closed in 2000. The NOx and VOC emissions 

from the Natomas Airport are very small compared to the overall airport 

emissions inventory. It should not have a significant impact on the general 

conformity budget. 
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 45 of 56 January 8, 2009

Letter from Camile Kustin, Environmental Defense et al (October 20, 2008) 

Comment #1: Achieve additional emissions reductions

 The Plan estimates that both the construction and operational ISRs will each 

contribute reductions of less than 0.1 tons per day of NOx and VOCs by 2018. 

These reductions are modest and we believe that the ISR has the potential of 

achieving greater reductions. As modeling technologies improve and the region 

continues to grow, the ISR will prove itself to be a critical element of the ozone 

plan. URBEMIS is the popular modeling tool for estimating development project 

emissions, but it does not adequately reflect the costs and benefits of project 

location within a specific region, which may result in an increased number of 

vehicle trips and longer travel distances. As the AQMD looks to other models, 

including the parameters listed above will more accurately represent the 

environmental impacts of site selection and land use patterns that directly 

affect air quality across the region. This will allow the air district to more 

accurately predict the emissions impacts and reduction needs. 

Response: In order to estimate potential reductions from the Construction ISR rule, Staff 

used the California storm water permit database to estimate the number of 

projects occurring in the area and URBEMIS to estimate the emissions 

generated from these projects during construction. For the Operational ISR 

rule, Staff used the percent reduction commitments made by the SJVUAPCD 

and the SCAQMD in their ozone attainment plans, applied to the SMAQMD 

inventory. 

 For operation emissions, SACOG is currently working on a new tool called 

iPLACES, which addresses the issues identified by the commenter and 

estimate region-wide emissions impacts from individual projects. When this tool 

is in place, Staff expects to be able to quantify the impacts of a projects 

location within a specific region. 

 Staff believes these emission benefit estimates are conservative and as the 

modeling tools improve the actual emission reduction achieved may be larger 

than our initial projections. 
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 46 of 56 January 8, 2009

Comment #2: Follow the San Joaquin Valley’s ISR Framework

 While we recognize that details of the rule will be addressed during the 

rulemaking process, as AQMD staff begins to consider rule design, we 

recommend they follow the general framework used in the San Joaquin Valley. 

This will help provide uniformity throughout the state and ease implementation 

and compliance. The San Joaquin Valley rule has also proven to be effective. 

 In just two years, ISR implementation in the San Joaquin Valley has reduced 

and prevented more than 6000 tons of NOx and particulate matter emissions. 

Developers who have embraced the rule have come up with innovative 

compliance solutions: construction equipment retrofits, sitting close to public 

transportation and existing job centers, signing contracts to maintain cleaner 

vehicle fleets, and increasing building energy efficiency. 

 Specifically, we support a framework that quantifies emissions, before and after 

mitigation measures have been included, sets emissions tonnage thresholds, 

project size thresholds, and emission reduction requirements, and includes a 

fee option to achieve offsite emissions reductions when onsite reduction 

strategies are unavailable. We also recognize that a one-size-fits-all approach 

may not work, and that specific requirements may have to be tailored to meet 

certain needs throughout the Sacramento region. Even though some specifics 

may need adjusting, the framework used in the San Joaquin Valley rule can be 

similarly applied in Sacramento to allow projects to move forward while 

improving air quality. 

Response: These control measures are modeled after our existing CEQA mitigation 

program and rules in place in other districts, especially the San Joaquin Valley. 

The proposed control measure commits to a framework that includes 

quantification of emissions before and after mitigation measures are applied, 

sets appropriate applicability limits and emission reduction requirements. The 

emission reduction requirements are proposed to include a fee option to 

achieve offsite reductions when onsite reductions are unavailable. 

Comment #3: Design an ISR that is complementary to existing policies and legislation

 As the AQMD moves forward with ISR rule development, the District should 

attempt to integrate its air quality regulations with evolving land use policies. 

SACOG’s regional Blueprint, California’s Global Warming Solutions Act (AB 

32), and now the Sustainable Communities Act (SB 375) can work together to 

encourage development that meets 21st Century demands. 

Response: Comment noted. The proposed control measure has been revised to 

specifically call out the integration issues identified. 
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 47 of 56 January 8, 2009

Comment #4: Evaluate the real costs of action versus inaction

 Experience with the ISR in the San Joaquin Valley has indicated that additional 

development costs of mitigation are minimal. A 2007 survey of 9 housing 

developments estimated a per-unit cost increase of just $420. In return, 

prospective homeowners and tenants get improved air quality and safer, more 

walkable communities to live and work. 

 Many Sacramento area developers who build “smart” projects that also take 

into account ways to reduce indirect source pollution, e.g. locating near transit, 

jobs and services and in walkable communities are still selling houses and 

commercial space. Developments located far outside the urban core, and that 

produce a heavier burden in indirect source pollution, face unprecedented 

foreclosures and even bankruptcy. 

Response: Commented noted. The potential cost estimates only include costs of 

complying with the ISR rules using information available at this time. Cost 

associated with not implementing an ISR rule is not available. We will be 

revising the cost effectiveness calculations when the rules are developed for 

adoption by the governing boards.
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 48 of 56 January 8, 2009

Letter from Samuel F. Longmire, Northern Sierra Air Quality Management District (October 24, 

2008) 

Comment #1: While the Plan does say that reductions in the SFNA will benefit WNC’s 

(Western Nevada County) efforts to reach attainment, there is no discussion of 

the fact that WNC’s 8-hour ozone values are not following the downward trend 

observed in the SFNA. The NSAQMD recommends that the Plan include a 

discussion of this apparent anomaly. Rapid growth in the northeastern part of 

the SFNA (particularly in Placer County) has been implicated in public forums 

as a factor. Placer is the fastest-growing county in the State (according to 

Department of Finance data), experiencing a population growth rate between 

April 1, 2000 and January 1, 2006 of 27.4% (compared to 8.8% for Nevada 

County). The City of Lincoln grew by 200% during the same period and has 

many residents who commute to Sacramento to work. There is a large swath of 

land north of I-80 and west of Auburn with no ozone monitor, so there is no 

data for tracking ozone development and transport to WNC through this rapidly 

growing area. 

Response: The Sacramento Regional 8-Hour Ozone Attainment Plan is a federal plan 

prepared to comply with the federal Clean Air Act requirements to submit a 

State Implementation Plan. California’s full SIP includes the state strategy for 

attainment, local element plans specific to each nonattainment area, and other 

documents. Because the Sacramento plan is specific to the Sacramento 

attainment area, it discusses ozone trends for the Sacramento Region, and not 

for other regions. Upon formal designation and assignment of an attainment 

date by U.S. EPA, Nevada County will begin preparation of its own attainment 

plan. A discussion of ozone trends in Nevada County will be an important 

component of this plan. 

 Under the California Clean Air Act, upwind areas affecting air quality in 

downwind regions are responsible for incorporating specific mitigating 

requirements in their state plans. As the Sacramento Regional 8-Hour Ozone 

Attainment Plan is a federal plan, this discussion is not required. Each district 

in the Sacramento Nonattainment Area intends to update their state plans 

during 2009. 
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 49 of 56 January 8, 2009

Comment #2: The NSAQMD recommends consideration of the following reasonably available 

measures, or similar measures, relating to ERC redemption. This would involve 

discussion with EPA and with CARB, and presumably include considerations 

relating to California’s “All Feasible Measures” requirement. It may be possible 

to fold one or more of the following recommendations into the ERC rule that is 

under development. The primary focus should be on NOX credits, since 

modeling indicates that ozone concentrations in the SFNA and, especially, in 

downwind rural areas including WNC, are more responsive to NOx reductions 

than VOC reductions. 

1) Commit all or some of the ERCs to non-summer activities (such as 

controlled burning for fire safety or agricultural purposes) or restrict their 

actual use by purchasers during ozone season via operating permit 

conditions. 

2) Stipulate that ERCs cannot be redeemed until transport-impacted areas 

reach attainment (except for the possible exception of necessary power 

generation projects). 

3) Buy up the ERCs from the credit holders (using mitigation funds or 

other funding sources) and retire them permanently. 

4) Designate the ERCs (or a portion thereof) for use in the downwind 

mountain counties rather than inside the SFNA, in accordance with the 

offset ratio requirements of the Clean Air Act. 

 As an explanation of the logic behind the last recommendation above, the 

mountain county nonattainment areas are facing an unusual situation in which 

they are likely to become Serious or Severe nonattainment areas within a year 

(with major source thresholds of 50 and 25 tons respectively), but they have 

minimal opportunities for generating ERCs to offset the establishment or 

modification of major sources under NSR. Thus, downwind rural areas are 

suffering in more than one way from ozone generated in the SFNA – not just 

from the high ozone itself but also from regulatory constraints that apply simply 

due to the presence of the transported ozone. The Clean Air Act’s ERC 

requirements indirectly limit economic development in transport-impacted rural 

areas by limiting the potential for industrial growth and power generation. The 

point of including offset requirements in the Clean Air Act was to place 

emission constraints on an area that fails to attain the NAAQS in order to force 

the area toward attainment. However, since the 8-hour average captures 

transport-impacted areas more than the 1-hour standard did but the Clean Air 

Act has not changed, the development constraints end up affecting rural areas 

that have never even had the opportunity to develop a large emissions base 

from which ERCs could flow. Earmarking the ERCs for use in the transportimpacted mountain counties would both assist the SFNA in their precursor 

reduction efforts (thereby reducing ozone concentrations and assisting with 

future Reasonable Further Progress demonstrations) and increase economic 

opportunities in areas that are affected by SFNA’s transported ozone. 

Response: The federal Clean Air Act requires the use of offsets at specified facilities 

during the required preconstruction permit programs in nonattainment areas, 

and as such, the Act anticipates the need for offsets in nonattainment areas. 

EPA requires in order to show compliance with Section 173(a)(1)(A) of the 

federal Clean Air Act that the pre-2002 emission reduction credits be 

incorporated in to the plan and that attainment with the federal ambient air 
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 50 of 56 January 8, 2009

quality standards for ozone be demonstrated by the applicable statutory date. 

The pre-2002 emission reduction credits, including the rice burning credits, 

have been included in the draft plan and attainment has been demonstrated by 

2018. 

 Emission offsets are a necessary part of the preconstruction permitting 

program and to the extent that the credits meet all the applicable federal, state 

and local regulations need to be available for use by facilities going through the 

new source review permitting in the nonattainment area. 

 Since the Sacramento Federal Nonattainment Area is a separate 

nonattainment area and some portion are separate air basin under state 

regulations from the Western Nevada County Federal Nonattainment Area and 

Mountain Counties Air Basin, there are state and federal regulations that apply 

to the use of emissions reduction credits created in one area for use by a 

facility in the other area. If a source in Nevada County needed NOx emission 

offsets and all the requirements in the federal Clean Air Act Part 173(c)(1), 

40CFR51 Appendix S, and California Health and Safety Code Section 40709.6 

are met, then a Nevada County source could negotiate to buy credits. Because 

Nevada County does not have a state ozone classification it is not clear that 

state requirements could be satisfied for Sacramento Valley portions of the 

Sacramento Federal Nonattainment Area. 

Comment #2a: The NSAQMD is concerned that generating ERCs from reductions in rice field 

burning could have the unwanted effect of moving precursor emissions from 

the fall and spring rice-burning seasons into the peak of the ozone season 

(July and August). If ERCs from reductions in the burning of rice fields are used 

by a source that operates throughout the summer, then the net result is an 

increase in ozone precursor emissions during the time of year when it is most 

crucial to reduce emissions. 

Response: ERC’s generated in the winter months could not be used during peak ozone 

season under the current ERC program. When ERCs are banked, they are 

issued only in the calendar quarters in which the emissions originally occurred. 

Consequently, because rice burning has predominantly occurred in the 1st and 

4th calendar quarters, the majority of ERCs will be issued for these quarters as 

well. While there will be some rice credits issued for the 2nd and 3rd quarters, 

the credits will be directly proportional to the amount of rice which was 

historically burned in those quarters. Any ERC’s issued for the 1st and 4th

calendar quarters, however, cannot be shifted to the 2nd or 3rd calendar 

quarters. 

 Because most rice ERC’s were generated during winter months and cannot be 

used during the ozone season, either modifying the manner in which these 

ERC’s are used or prohibiting their use would have little effect on ozone levels 

in the mountain counties.
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 51 of 56 January 8, 2009

Comment #3: Modeling Episodes

 It is not clear why the longer August 8-17, 2002 episode was not chosen for 

Sacramento’s attainment demonstration. It seems that using a larger data set 

would be the conservative approach, leading to more reliable modeling, and 

that a more recent year would have an emission profile more similar to current 

conditions – two factors that favor its use over the use of the shorter 1999 

period (when the wind carried more of the ozone farther south). On August 13, 

15 and 17 of 2002, WNC had higher 8-hour ozone concentrations than any 

other area in the mountain counties or the SFNA. 

Recommendation 3: Episode Selection Discussion

 The NSAQMD recommends that the main body of the Plan include more 

details on the episode selection criteria (perhaps in Section 6.6), on the 

episodes dismissed from consideration, and on the process used to determine 

that the episodes chosen are characteristic of the actual ozone transport 

situation. At least a qualitative summary of the other episodes that were under 

consideration and how they differ from the ones selected would be useful in 

assisting the public in evaluating the appropriateness of the episode selection. 

The NSAQMD further recommends that the Plan include a clear, 

mathematically and scientifically sound discussion of what would be expected if 

the 2002 episode were chosen for the SFNA’s attainment demonstration 

modeling, and an explanation of why the 1999 episode is a superior choice. 

Response: The evaluation of the episode days selected for air quality modeling included 

many local, state and federal governmental agencies, consultants, and 

stakeholder interest groups that participated in the Central California Ozone 

Study (CCOS) and other air quality technical committees formed in support of 

ozone SIP developments for Central California. A large body of work was 

produced by these study groups toward the goal of determining representative 

candidate episode periods for use in 8-hour ozone SIP modeling for the region. 

From this collective body of work, the following four episodes were identified as 

having the greatest potential for accurate SIP modeling in the region: 

• July 7-13, 1999 (captured with routine state and local measurements) 

• July 29-August 2, 2000 (CCOS-studied episode) 

• September 17-21, 2000 (CCOS-studied episode) 

• August 8-17, 2002 (captured with routine state and local 

measurements) 

Due to time constraints and based on model performance issues expressed by 

study efforts for the two later episodes, the first two episodes (July 7-13, 1999 

and July 29-August 2, 2000) were determined to be the most adequate for the 

initial round of 8-hour ozone SIP attainment planning. Brief summaries of the 

two episodes selected for SIP modeling are contained in the Plan’s Appendix B 

– Photochemical Modeling, along with a list of available California Air 

Resources Board (CARB) modeling reference documents for the Sacramento 

SIP modeling. 

With regard to the two potential episodes that were dropped from 

consideration, CCOS sponsored a project that was focused on developing the 

third episode (September 17-21, 2000) while the Sacramento Metropolitan Air 
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 52 of 56 January 8, 2009

Quality Management District sponsored a project to develop the fourth episode 

(August 8-17, 2002). As indicated above, achieving adequate model 

performance for both of these periods was problematic. 

The August 8-17, 2002 episode was pursued by the Sacramento Air District 

under independent contract with the Desert Research Institute (DRI). DRI was 

not able to achieve adequate model performance with the episode, rendering it 

unusable for SIP attainment demonstration modeling. With regard to Nevada 

County, the modeling of the August 2002 episode failed to reproduce the 

observed range in 8-hour ozone concentrations at Grass Valley. 

The August 2002 episode was found not to be representative due to the large 

number of wildfires within the domain and an especially large wildfire in 

southern Oregon. The smoke and presumably ozone precursors flowed along 

the coast and some of the smoke plume penetrated into central California near 

the San Francisco Bay Area. Undoubtedly, emissions from the wildfire 

influenced ozone levels at many monitors, meaning that these days were not 

reflective of typical summertime high-ozone days, when precursor emissions 

are dominated by anthropogenic emissions. 

More details and discussion of episode selection will be added to the Plan’s 

Appendix B – Photochemical Modeling. Additional references pertaining to the 

evaluation of potential ozone modeling episodes will also be included.
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 53 of 56 January 8, 2009

Attachment b 

Public Comments Received after deadline 

Note: No new issues raised. No responses prepared. 
Public Comments and Responses on the Draft 

Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan and Environmental Impact Report 

Page 54 of 56 January 8, 2009
Public Comments and Responses on the Draft 

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Public Comments and Responses on the Draft 

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