APOSTOLIC FAITH CENTER CALIFORNIA COMMUNITIES AGAINST TOXICS CALIFORNIA KIDS IAQ CALIFORNIA NURSES ASSOCIATION COALITION FOR A SAFE ENVIRONMENT COALITION FOR CLEAN AIR COMMUNITIES FOR A BETTER ENVIRONMENT COMMUNITY DREAMS EARTHJUSTICE EAST YARD COMMUNITIES FO R ENVIRONMENTAL JUSTICE END OIL/COMMUNITIES FOR CLEAN PORTS NATURAL RESOURCES DEFENSE COUNCIL PHYSICIANS FOR SOCIAL RE SPONSIBILITY-LOS ANGELES SIERRA CLUB

February 5, 2015

Chairman Burke & Members of the Board 21865 Copley Dr. Diamond Bar, CA 91765 cob@aqmd.gov

Re: Agenda Item No. 22—Oppose Staff Recommendation

Dear Chairman Burke and Members of the Board:

On behalf of Apostolic Faith Center, Calif ornia Communities Against Toxics, California Kids IAQ, California Nurses Association, Coaliti on for a Safe Environment, Coalition for Clean Air Communities for a Better Environment, Co mmunity Dreams, Earthjustice, East Yard Communities for Environmental Justice, EndO il/Communities for Clean Ports, Natural Resources Defense Council, Physicians for Social Responsibility-Los Angeles, and Sierra Club, we write regarding the attainment plan for the 2006 24-hour fine Particulate Matter (“PM2.5”)

standard that is before the G overning Board at the February m eeting. In particular, we find the attainment demonstration completely inadequate. We also find the failure to include any additional measures problematic given the troubl ing information in the draft plan regarding

continued violations of the standard.

We are disappointed that the South Coast Air Quality Manage ment District (“District”) acknowledges that attainment of the 2006 24-hour PM2.5 standard is unlikely to happen on time. The federal Clean Air Act (“CAA”) delegates re gulatory responsibility for reducing particulate pollution to states and local air districts. Purs uant to CAA sections 110( a) and 172(c), the State Implementation Plans (“SIPs”) must demonstrate attainment of clean ai r standards and include all feasible measures. Importan tly, the District proposes no reme dy to the continued violations.

Indirect source rules and back stop rules to control freight po llution are some examples ofAgenda Item No. 22—Oppos e Staff Recommendation February 5, 2015 Page 2

feasible measures. Instead, the plan before th e Board takes a wait and see attitude where the District hopes for favorable weather. The Distri ct should use this opportunity to develop control strategies to ensure the PM2.5 sta ndard is actually met on time.

We appreciate your considerati on of our comments. This issue is especially important as exceptionally high levels of particulate pollution have hit many parts of the basin over the last couple of days making the air unhea lthy to breathe. Please do not hesitate to contact us if you have questions about these comments.

Sincerely,

Pastor Alfred Carrillo Apostolic Faith Center Jane Williams California Communities Against Toxics

Drew Wood California Kids IAQ Fernando Losada California Nurses Association

Jesse N. Marquez Coalition For A Safe Environment Maya Golden Krasner Communities for a Better Environment

Ricardo Pulido Community Dreams Adrian Martinez Earthjustice

Mark Lopez East Yard Communities for Environmental Justice Giselle Fong EndOil/Communities for Clean Ports

Melissa Lin Perrella Natural Resources Defense Council Angela Johnson Meszaros Physicians for Social Responsibility-Los Angeles

Evan Gillespie Sierra Club Fabiola Lao Coalition for Clean Air