# Air Resources Board Mary D. Nichols, Chairman Linda S. Adams 1001 1 Street P.O. Box 2815 Arnold Schwarzenegger

Secretary for Sacramento, California 9581 2 www.arb.ca.gov Governor Environmental Protection

July 7, 2009

Ms. Laura Yoshii Acting Regional Administrator U.S. Environmental Protection Agency Region 9 75 Hawthorne Street San Francisco, California 94105
Dear Ms. Yoshii: 

### Iam pleased to provide information explaining how California's existing State Implementation Plan (SIP) meets the program infrastructure requirements of the Clean Air Act (Act) Section 11 0(a) for the PM2.5 NationalAmbientAir Quality Standards. California originally subrr~itted a comprehensive §I10(a)(2) Infrastructure SIP in response to the Act of 1970, which was approved bythe U.S. Environmental Protection Agency (U.S. EPA) in 1979. A subsequent Infrastr~~cture SIP revision submitted to the U.S. EPA on November 16, 2007, fulfills the required elements for the PM2.5 annual standard aswell as the 24-hour standards of 65 Clg/m3 and 35 Clg/m3.The only outstanding element that the previous submittals did not address concerns emergency powers and adequate emergency episode plans for the PM2.5 standards.
The requirement for a state to submit an emergency episode plan is based on a priority region classification. The priority classification uses information on the severity of air quality in a region to determine the applicability of an emergency episode plan and the specific plan requirements. While the U.S. EPA hasyet to establish the specific PM2.5 levels for the priority classi'fications,it did issue interim guidance which required only States with 24-hour PM2.5 concentrations over 140.5 Clg/m3, inthe most recentthree years of data, to develop an emergency episode plan for PM2.5. States which did not meetthat threshold would be classified Priority I I I regions and emergency episode plans would not be required. Based on guidance from their U.S. EPA regional office, the New England states were considered Priority Ill based on no recorded PM2.5 concentrations over 140.5 vg/m3. California used this same guidance in developing our priority classification.

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption For a list ofsimple waysyou can reduce demand and cut your energy costs, see our website: http://www.arb.ca.qov. California Environmental Protection Agency
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### ..-".Ms. Laura Yoshii July 7, 2009 Page 2

As demonstrated in the Attachment, our review of the most recentthree years of data indicates that California should be considered a Priority III region. Therefore, an emergency episode plan is not required. If we can be of assistance as you review this matter, please have your staff contact Ms. Karen Magliano, Chief, Air Quality Data Branch, at (916) 322-7137 or via email at kmaqlian@arb.ca.gov.
Sincerely,

James



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Attachment

cc: Lisa Hanf 

### U.S. Environmental Protection Agency Region 9 75 Hawthorne Street San Francisco, California 94105
Debbie Jordan 

### U.S. Environmental Protection Agency Region 9 75 Hawthorne Street San Francisco, California 94105 Karen Magliano Chief,Air Quality Data Branch Planning and Technical Support DivisionAttachment Analysis of 2006 to 2008 California PM2.5 Data for Prioritv Classification
Inthe last 'threeyears, PM2.5 FRM concentrations in California have remained below 140.5 pg/m3, with the exception of one wildfire and one windblown dust event. Since the authority specified in Section 11 0(a)(2)(G) was not intendedto control emissions from these type of events and there were no other concentrations over 140.5 pg/m3,California should be considered a Priority Ill region and therefore emergency episode plans are not required. Wildfire: During the 2008 Northern California summer wildfires, a PM2.5 concentration of 142.2 pg/m3was recorded at Quincy on June 23, 2008. During this same event, a concentration of 200.2 pg/m3was recorded at Redding on July 23, 2008. California is in the process of preparing an exceptional event request for both of these days, which documents that anthropogenic sources had little impact on the PM2.5 concentrations. In response to high concentrations during wildfire events, the Air Resources Board and the local districts have an existing notification program to communicate health risks and precautions to the public. These communication methods include websites, hotlines, and press releases, as well as email, faxes, and phone text messaging to interested parties (such as sports team coaches and daycare providers). In some rural areas, door-to-door notifications have been used. Additional efforts to reduce PM2.5 contributions are taken during smoke impact periods. For example, no open burning is allowed in areas impacted by a wildfire. These 'no burn' declarations are handled through the State's comprehensive smoke management program. Dust Event: On December 28, 2006, a PM2.5 concentration of 193 pg/m3was recorded at Keeler in the Owens Lake area due to a windblown dust event. Dust storm events, like the one that occurred at Keeler on December 28, 2006, are caused by wind blown dust from the dry lake bed and are unique to the Owens Lake area. Best available control measures are already in place to control the fugitive dust events. In addition, the Great Basin Valley Air Pollution Control District has an existing health advisory program to notify residents of the appropriate actions to reduce the adverse health effects of these high concentrations.