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 FOR ENVIRONMENTAL JUSTICE 

END OIL/COMMUNITIES FOR CLEAN PORTS 

NATURAL RESOURCES DEFENSE COUNCIL 

PHYSICIANS FOR SOCIAL RESPONSIBILITY-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, 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 for Environmental Justice, EndOil/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 Governing Board at the February meeting. In particular, we find the 

attainment demonstration completely inadequate. We also find the failure to include any 

additional measures problematic given the troubling information in the draft plan regarding 

continued violations of the standard. 

 We are disappointed that the South Coast Air Quality Management 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 regulatory responsibility for reducing particulate 

pollution to states and local air districts. Pursuant to CAA sections 110(a) and 172(c), the State 

Implementation Plans (“SIPs”) must demonstrate attainment of clean air standards and include 

all feasible measures. Importantly, the District proposes no remedy to the continued violations. 

Indirect source rules and back stop rules to control freight pollution are some examples of 
Agenda Item No. 22—Oppose Staff Recommendation 

February 5, 2015 

Page 2 

feasible measures. Instead, the plan before the Board takes a wait and see attitude where the 

District hopes for favorable weather. The District should use this opportunity to develop control 

strategies to ensure the PM2.5 standard is actually met on time. 

 We appreciate your consideration 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 unhealthy 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