BAY AREA

AIR QUALITY

M A N A G E M F N T

DISTRICT

ALAMEDA COUNTY

Tom Bates

Scott Haggerty

Nate Miley

(Vice-Chair)

Tim Sbranti

CONTRA COSTA COUNTY

John Gioia

David Hudson

Mary Piepho

Mark Ross

MARIN COUNTY

Susan Adams

NAPA COUNTY

Brad Wagenknecht

SAN FRANCISCO COUNTY

John Avalos

Edwin M. Lee

Eric Mar

SAN MATEO COUNTY

Carole Groom

(Secretary)

Carol Klatt

SANTA CLARA COUNTY

Cindy Chavez

Ash Kalra

(Chair)

Liz Kniss

Jan Pepper

SOLANO COUNTY

James Spering

SONOMA COUNTY

Teresa Barrett

Shirlee Zane

Jack P Broadbent

EXECUTIVE OFFICER!APCO

December 1 7, 2013

Amy Zimpfer

Associate Director

USEPA, Region 9, Air Division

75 Hawthorne Street

San Francisco, CA 94105

RE: Response to the 11/26/13 request for information regarding Section 111(d):

Carbon Pollution Standards for Existing Power Plants

Dear Ms. Zimpfer:

It was a pleasure participating in the November 15th meeting to discuss EPA’s efforts to

develop carbon pollution standards for existing power plants under 111(d) of the Clean Air

Act. Section 111(d) encourages each state to create a plan that establishes a standard of

performance and provides for implementation and enforcement of that standard. Many

states and regions have already created programs and laws designed to reduce greenhouse

gas (GHG) pollution. Some have embraced variants on cap-and-trade schemes, enacted

renewable portfolio standards, or developed demand reduction strategies focused on

targeted sectors. California already has launched state-wide efforts to reduce GHG

pollution including: Assembly Bill 32 programs, the Cap-and-Trade Regulation, the

California Environmental Quality Act, energy efficiency standards, and renewable

portfolio standards.

Efforts to develop carbon pollution standards for power plants should be based on the

proven State Implementation Plan (SIP) model. State and local air quality districts have

demonstrated expertise in reducing criteria pollutant emissions through the SIP process.

SIPs are a compilation of new and previously submitted plans, programs (such as

monitoring, modeling, permitting, etc.), district rules, state regulations and federal controls.

Local air districts and other agencies prepare SIP elements and submit them to the

California Air Resources Board and EPA for review and approval. SIP documents contain

a wide variety of information including air quality goals, measurements of air quality,

emission inventories, modeling demonstrations, control strategies, and evidence of public

participation.

The elements of an effective program to achieve GHG reductions from power production

through a SIP-like” program would include:

• Establishment of stringent emissions standards, control measures, and air quality

goals.

939 ELLiS STREET • SAN FRANCISCO CALIFORNIA 94109 . 415.771.6000 . www.haacjtnd.gov
Amy Zimpfer December 17, 2013

Page 2

• Plans to achieve GHG reductions:

o EPA should allow flexibility for States to include energy efficiency, capand-trade schemes, renewable portfolio standards, demand reduction

strategies, etc.

o The Plan should achieve the GHG reduction goals in a given timeframe, or

take all feasible measures to achieve the GHG emission reductions (similar

to the California Clean Air Act).

• Programs for enforcement of emissions standards and control measures.

• Programs for air quality monitoring and source testing.

• Adequate authority aiid resources to implement the plan.

The District periodically prepares and updates plans in order to attain State and National air

quality standards and comply with air quality planning requirements. These plans report on

progress in improving air quality and provide a road map to guide the District’s future

activities. The latest District plan is the Bay Area 2010 Clean Air Plan (2010 CAP). The

2010 CAP provides an integrated, multi-pollutant control strategy to reduce ozone,

particulate matter, air toxics, and GHGs in a single, integrated plan.

The Bay Area 2010 CAP and associated documentation may be found at:

http://www.baagmd.govIDivisions/Planning-and-Research/Plans/C1ean-Air-P1ans.apx.

A useful document on Section 111(d) is the January 2013 report titled ‘Regulating Carbon

Dioxide under Section 111(d) of the Clean Air Act: Options, Limits, and Impacts”. The

report by the Duke University, Nicholas Institute for Environmental Policy Solutions,

memorializes an October 2012 workshop ofstakeholders on EPA’s proposed 2012 C02

emissions standards for new fossil-fueled power plants. Here is the link to the report:

http://nicholasinstitute.duke.edu/climç/ppjiçesign/regulating-carbon-cjjoxide-under

section-I I Id. We support using it to assist in develpping your program.

Please feel free to contact Barry G. Young, Senior Advanced Projects Advisor, Engineering

Division, at byoung@baaqmd.gov or (415) 749-4721 with any questions regarding this

matter.

Sincerely,

Jeff McKay

Deputy Air Pollution Control Officer

CC: Jack P. Broadbent, Executive Officer/APCO

Jim Karas, Director of Engineering

Henry Hilken, Director of Planning