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HomeMy WebLinkAboutNB 3 AIR QUALITY RPT 03-20-89~ ~ ~ ! ~ ~ NEW BUSINESS ~ NO. 3 _ DATE: MARClt 20, 1989 ~,~'~'~J TO: WILLIAN HUSTON, CITY MANAGER FROM: CHRISTINE SHINGLETON, DIRECTOR OF COMMUNITY DEVELOPMENT SUBJECT: AIR QUALITY MANAGEMENT REPORT RECOMMENDATION Pleasure of the Council. BACKGROUND Attached for the City Council's information is previous information submitted to the Council on the Air Quality Management Plan. The Orange Division of the League at their meeting on March 9th also voted to instruct their designated representative on the Air Quality Management Board to vote "No" on the Plan. Christine Shingleton m/ Director of Community Development CAS-per TO: FROM: SUBJECT: URSULA E. KENNEDY, MAYOR COI~iqlJNZTY DEYELOPHEI~ DEPARTMENT AZR QUAL]~TY IqANAGEHENT PLAN ~[n response to your request, we have reviewed the Ctty of Fullerton's request of Tustln to support the adoptton of a resolution to be conslderd by the Orange County League of Callfornta Clttes on the proposed Att Qualtty ~lanagement Plan (AQ~IP). Th~s posttlon would recommend that the League's appointee on the Orange County Board of the South Coast Alt Qualtty r4anagement Dtstrlct vote agatnst the AQI~P. Staff have reviewed the original AC)r4P, the environmental Impact report and thetr revisions and has presented comments to the Dtstrtct whtch express'Tusttn's concerns regarding the AQr4P's Implications. These comments are also attached for reference. Based upon the Information provided, the Ctty 1s htghly concerned over the technical, financial, and social lmpacts of the AQ~IP. Staff suggests that further study and consideration be provided prtor to the A0r4P's adoptton and has requested that some form of Implementation program be provtded so that the AQr4P can be appropriately evaluated. Alternative measures should also be considered and evaluated. The Clty of Tusttn as well as planntng staff's throughout Orange County have not been satisfied that SCAi; or the SCAQr4D have adequately addressed our significant concerns. Ctty staff recommends that Tusttn support the Ctty.of Fullerton In requesting the Orange County League of Clttes to adopt the proposed resolution. In dolng so, Tustln can joln forces wtth the many other communities In Orange County and help to suspend adoptton of the AOMP until an Implementation plan and additional alternatives can be considered. Should you have any questions, please do not hesttate to call Laura Kuhn at extension 256 or myself. ChriStine A. Shlng~)ton '" Director of Con;nuntty Development Attachments CAS:LK:ts ' - cc: Clty Council t~1111am Huston Christine A. Shtngleton -..'.. x/":': · ?:,".'-., -:' .--~- :,,:' ...... · ". - '- - · - January 26':-1989 - · . .. .... ~.. .: ~ -: .? :' ,-.:.- ..... ~ . .-., · , , ,: · .: .'?!~ ~'!Z'': ~i!·~,~i::l ]-'~'-~!ii:' :,·. i:, '/.'~ ....... --. i,... .... ?,......: .... Mr.'- Brian,'W.' ~Farri s ...... --.south~ COast "Air Qual ii ty 'Manage~nt Di s~i ct ' '-I ?!;.-[:9.150 Flair Drive :,~.!',.~.~t.J;£.m.i/Monte;"- ' CA':." 91731 i. ... Community Development Department . . ,. .- m -- ' 'SUBJECT:':"'* cOIIMEliTS ON AIR QUALITY MANAGEMENT PLAN £IR ~ ' '......;.'..~.:.','.:,. ~.i~ ..' - ::-"· :' 'o:e'~: Mr',?rarris: - .; * .~.~? ,:.. :&.~,~.:,,.', -~ J -. ..... .. , "· ":-'..~,:~.?" -C' .~ ,I , :'- .- AttaChed to"thls letter is a copy of prevtous correspondence filed with your' office · : .... regarding:, the subject project. Since the"-tlme line for receiving-comments was ,' .... ~'e~tended,:'.no new comenr~ have been prepared by t~e City of 'l'u~tln. However, our "'..:.previous..'cOml~ents still apply, ":' ':' .' ':.- .: -:? 7'-[ ;,i'"!?'i ? :' ':':'," '~" · : ' ";' ' '-' ' ' ' .-. ·" · , ,--. P.lease-address.a11 .comments and concerns as detailed in the attached letter · ~'.':."~r, . .. , . _ · -. Pl'ease:call'-if.y0u' have any questions... '" .-.?,.~;. ':'.',._,. ;_ ~- ; .... . . .J.l~t .. - .... Sl ncerel y ;" .:}!i/-' '"~, . .... ~'.' Chr:l s.tl ne-. Shlngleton ..... .:-':' Director 'of Comluoityl~'eVelopment .. -.. Laura C;-::Kuhn --. .... . Senl or P1 anner- -:. CAS:LCK:jk ... · '. -. "i ..... ,': :.. , -. . . i .... Attachment .'"":.'-:-~ : :. . - .... . :. ':'.:' · ., .:, o,. ,.o ,-.. . . .!, ~ .. · _ ~: ..-.:.. :-, ',:. ': · ,., '. . ~£,.. , ,?,, . ,: ." I .... , -.... , ,.:. ~ ',:.. - :,... .... · .... ', ; . ,' . . . ,. . , . · ,'. '...."-":":, .: .-~. ,, ': ". .. . I .'..: -~?,'. ~ .. ~. ,..:, :.:.-.......:.,-::., :.,'.: ',.. - ......... -.~: .: ~,,. . - . -. , - '.. .- ~ ':? {' ::-i :' ,.~.' ',':: ' ....... ',':. :',.;... :..:::::?:?~300 Centennial Way · Tustln, California 92680 · (714) 544.8890 · ;-~ - . o · ' .... '~..-.,. :.. ,,-., ~ .... k'.. ~ - ,. , . - ~. . ..... · .,. . City of Tustin RONALD B. HOESTEREY, Mayor QRSLILA F_ KE. NNEDY, Mayor Pm Tem RICHARD B. EDGAR, Council Member JOHN KELLY, Council Member EARL. J. PRESCOTt, Council Member · WILLIAh~ A. HUSTON, City Manager December 15, 1988 ... t4s. Sharon Reed Special Projects Coordinator South Coast Att Quality Hanagement Dl.strlct 9150 Flair Ortve E1 Honte, California 91731 SUB~]ECT: C0MHENTS ON DRAFT AIR QUALITY HANAG~E~ PLAN Dear ~ls. Reed: · 'Thts letter ts tn response to reviewing the 1988 Draft Air .Qualtty t4anagement Plan, 1ts accompanying EIR and the proposed revisions to each of these documents. ~fhlle It ts quite clear that the Governing Board of the South Coast Att QualJty ~lanagement Dlstrtct tntends to adopt the Plan and EIR desptte all of the local and coun~cy agency opposition, the City of Tus:tn wJshes to request an extended review perJod and that additional Information be provided to address the tssues discussed heretn. In 11ght of the recent legal Issues brought to the media from your counsel, when can we expect :o hear word on the revised action plan? · In reytew of the response to comments on the EIR tt was evident that many of the Issues related to ftscal tmpact, socto-economlc tmpacts and lmplementatlon measures are being deferred to a later ttme when rule adoptlon occurs. ~/htle thts · may be easter to do, dt makes for a Plan whtch Is poorly defended. Additionally, without thoughtful consideration of the tmpacts related to each measure, It wtll be extremely difficult to gain support for the Plan and could lead to failure to meet the attainment strategies. This ts reminiscent of prevtous attempts to clean up the Basln's air. It Is Important to note that everyone agrees that the lntent of the Plan ts good, but It must be prepared tn a fashion whtch cleqrly spells out 1ts ftscal and socto-economtc Impacts as well as "-provide an Implementation and monitoring program, l~l:thout these elements, It wtll be extremely, difficult to gatn local agency support for the Plan. 300 Centennial Way · Tustin, California 92680 · (714) 544-8890 ' '..'*'i i.I*: ~' :; ~ ''''* '~ December-15, 1988 Mrs. Sharon Reed Comments on Draft AQMP Page two -'-Attached to this letter are two 1rems, Exhtblt 'A Is a 11sting of Tustln's spectftc comments and concerns on the.revised Plan and Exhtbtt B is a copy of our previously ftled comments which were not adequately addressed tn the response to comments in the E:[R. Prtor to any action by the Dtstrtct or SCAG on this tssue, the City of Tusttn wtshes to recelve and revlew your response.to our continuing concerns. Sincerely, Ursula Kennedy Mayor UK:LCK:pef:ts · Attacihments cc: SCAG Chatrman .,Comaents on Revisions to ~988 X~RP le The .response to comments do not address our previous- request for an implementation plan for each of the Plan,s measures. A · detailed 'analysis of how each of the implementation measures - listed in Tier One and Tier Two should be provided. · In response to AB3180-Cortese, the EIR should also include a monitoring device to assure compliance with each of the mitigation measures. A monitoring program for 'the Plan,s success in pollution reduction should also be provided or discussed in the Plan. · The fisCal and socio-economic impacts of each of the measures in all three tiers is not provided, just generally discussed. ACcording to the' City,s understanding of CEQ& and ~ther state laws, these issues have yet to be adequately addressed to meet legal requirements. Since the Plan will become legally enforcable, it is important to provide this discussion so that each of the measures costs and benefits are appropriately considered. · After thoughtful consideration and review of the Plan and EIR it is .quite evident in the proposed revisions that the Draft EIR did not contain some of the Plan alternatives and economic information such as the Small Business Owners alternative and the economic information from USC. Under CEQA law, it is the City,s understanding that additional review time is needed to consider this informatio~. PLaN ME2~UP. E8: 1. Tier One-ControI Measures:. a. The adoption of strict restrictions on the use of solvents, coatings and adhesives is provided as an important attainment measure~-'Are there adequate substitutes for household and page 2 ",omments on Revised AQMP · industri~l products that can b~ used to. replace:the 'restricted 'itemS?: The Pia~ only eludes tO their existe~ce and does · not proVSde any documentation or listing of these replacements. b. In. addition to the comment above, are there replacement Products which can be used in dry cleaning operations, underarm products, "domestic products- and other items which .are proposed to be restricted? 2. Tier Two-Control Targets: a. The goals for attaining the use of alternative fuels by certain percentages for each t~pe of vehicle is certainly well intended. However, no specific measures on how to achieve these goals are provided. Are there guaranteed committments from the automotive industry to meet these goals? If not how can we expect to meet them? b. As with the Tier One comments listed above, are there existing technology and/or products available to adequately replace the solvents, coatings and adhesives which .emit Reactive Organic Gases? ¸0 Tier Three-Technological Breakthroughs: a. All of the strategies discussed in this tier are difficult to comprehend, much less implement. Without the security of knowing whether or not these goals can be attained, how can we consider submitting them to the Environmental Protection Agency as measures for..meeting the state and federal air quality requirements? Has there been a precedent set by another Air Quality Management DiStrict which uses the same strateg~? b. The use of clean fuel Vehicles for all of the Basin is certaiUly a good idea, the question here is whether we can restrict regionalized travel. Since the use of such vehicles would be ma,,dated in this area, how will interstate- and interregional travel and commerce be affected? This seems more like a federal implementation measure rather than a regional one and would be very difficult to control. page 3 comments on Revised AQHP . . . The'review periods used for this pro~eot (Plan and EIR) meet the State,s -requirements; however, considering the scale, regional ~npact and technical information and measures proposed in the Plan, it is not feasible for local agencies to respond adequately in the allowed time periods, especially for the revisions to the EIR and Plan. An additional 90 day should be provided for.review and consideration of the Plan, EIR and there corresponding revisions. . Many of the measures require implementation of new technolog~ and/or restrictions on activities or uses which are currently in effect. Will the restrictions and tecB~ological changes be applied retroactively, or will existing uses and facilities be grandfathered? For examp1e,..-wi11 all new and existing drive-thru restaurants be banned, or only new ones? If these requirements are not applied retroactively,, is it economically and legally equitable to restrict tho rights of businesses and residents who are new to the- area? While this grandfathering is common, the measures in the Plan are.quite severe and impact a wide range of activities and uses. Some consideration of this issue should be 'provided. of Tustin II I . R~ B. flOF-,RTF:RgY, ,'~yor '"; ' ' . ~ F. ~Y. ~ayer ~ Tern . · · . ~ KELLY. Counci/~ EARL ~ .PRESCOTT, CouncU ~ · ~ A. HUSl'OI'"L City October 27, 1988 gs. Sharon ~ed Spectal Projects Coordinator South Coast Att Quallty Planagement Dtstrlct 9150 F1 at r Drlve E1 Honte, California 91731 SUS~£CT: COHIdEHTS 011 DRAFT AZR QUALZTY HAgAGEI~ttT PLA}I -. 0ear Ids. Reed: The City of Tusttn has taken the 'opportunity to review the Draft Air Quality Management Plan (AQIdP). On behalf of.the City of Tustln and it's staff, ! would like to thank the Dlstrtct for this opportunity t~ comment and would appreciate your-consideration and resp.onse to the .comments contained in Exhlbit A at:ached to this ietter. · ~ · Zt is quite obvious that the Plan requtred serious thought and careful analysis and proposes leplementatlon measures with far reaching impacts. Additionally, the Plan is hlghly technical and ~equlres detatled and specialized analysts by City staff in order to fully understand the Implications of the Plan proposals. · As of this date, the City of Tusttn has yet to receive all of the related Plan documents such as the proposed Moblllty and Growth 14anagement Plans being prepared by,.the. Southern California Association of Governaents. These Plans are referred to as an appendices and reference documents In the 0raft AQIqP. For this reason, and tl~e need for specialized review of the Plan as mentioned previously, the City of Tustln arde'ntly requests an. extension of the revle~ perlod so that more detatled revtew and comment on the Plan and a1~1 of its appendices can be made, · . · . I am confident that we can all agree that the provision of clean att lsa goal shared*by all persons'l, lvtng in thts regton. However, the path taken to reach this goal rust be' clear of obstruction. Specifically, the Plan must contaln Implementation ~easures, goals and objectives that both regtonal and local governments alike can understand and pr.operly carry out. · 300, Centennial Way · Tustin, California 92680 · (714) 544-8890 · · ·,., ., ; · .'.,,. ,~'.?- '_::~L' :.. · ' : "." :;i':.i/:'!':'_ . ':':~.. 'Oc~ber 27,' 1988 Hs. Sharon Reed' · Sout-h coast Air Ouallt:~ Hanagement District Page ~o o Once"agaln,: thank you. for the opportunity to comment on the Draft AQIqP and appreciate you? consideration and response to the comments attached hereto £xhtbt~c A. :"': ~' ~,,~;,- ,j¢~"~-e~- · Ronald 'B. H~esterey Hayor RBH:LCP:pef · enclosure: £xhtbtt A cc: Tustln Ctty Counct1 .Plannl.n.g Co, ri sston ~/1111am A. Huston, C'l"l:y Hanager Orange County Board of Supervisors Dr. James Lents, PhD. Hark Plzano, SCAG POLICY ISSUES i i · EXHIBIT X CITY OF TUSTIN COMMENTS ON DRAFT AIRL. QUALI.TY..MANAG£MENT PLAN The Proposed Plan is based upon development of technology which, at this time, may be technologtcall, y feasible but economically impractical. How can we rely on technological' changes which may not be implemented if they aren't cost "effective? '2. ':l:.Al~Jlough we can all agree on the issue of clean air~ how can local Jurisdictions attempt to implement policies which will ha~e an adverse impact on the local, not to mention regional, economic development? The Plan proposes to limit such development which is in direct conflict with the goals and objectives for the mission and.?x.istence of may local agencies. 3. :'~':.The."laborlous. task of formulating the proposals and policies of the AQMP is obvious. However, the result of these efforts has resulted in a Plan that is poltttca!ly and economically unpalatable for the local agencies. Tustin has .reviewed the comments submitted by. the other local agencies in the region and -'agrees that- the AQMP- proposals are such that coordination wi th all -implementing agencies should have been started earlier. Now, the local 'Jurlsdl¢.tlons are reacting in an unfavorable manner and we are at the mercy of the District to consider our comments and request to extend the review period · in orde.r .to allow adequate consideration of a highly 'technical and powerful plan. : PRO~l£~r TIMING i GROWTH MANAG£M£NT The CitY of Tusttn realizes the sensitive, nature of the project and the implications of non-attainment. We all stand to lose if the region's air quality is not improved to meet state and federal requirements. However, in order to meet these requirements, the District has adopted an accelerated processing schedule. The amount of time allowed'to local' jurisdictions to review the Plan is grossly inadequate. Additional review time is an absolute · necessity tn light of the fact that the supporting documentation (Mobility and Growth Management Plans) have yet to be .provided to us. Once all supporting, documentation is available, the City of Tustln would ki'ndly request a 90 day review period. This will allow for thorough analysis and informed consideration of the Plan. The current expectations are' both unfair and legally questionable. · one of .the key elements to the 'Plan is to ensure a job to housing'balance. This goal is also supported by the StAG Housing Allocation Plan. Tustin has filed a formal appeal of the requirements in the Plan. and the status of this appeal has yet to be determined: Ensuring compliance with' this policy is difficult at best, when considering the cost of housing and high interest 'rates of the region. In most cases, residents will continue to commute because ':iliey. cch' t affort to move. Ct~y of' Tusttn Comments on Draft. Att O.ua, l~ty Hana~e.ment,,Plan (AOt4P) Page ~o -. · . . . .: .., ..-:~ .;.:: Additionally, the' $CAG' growth forecasts for the regton show tremendous .~. growth, 'l~tth a continued lnflux of new residents to the area, only more :: ~::' pollution wtll follo~. - : ]~PL~E ~AT]Og ~EASURES .... . .. . i ., , -. 1, '..~ The Plan Identifies tony goals ~tthout provision of Implementation measures. For Instance, ~h~t assurance ts there that vehicles capable of being powered '- :..by ;:~etther ~thanol or electricity .~tll be produced by the mrket of ---'"'satisfactory quality and quantity to ~et thts goal? If thts Is possible, ....-~tll the vehicles be used outstde the ~tr basin? If not, h~ can they be 'used .~:-for long dtstance travel by vehtcles In Interstate co~erce? And finally, ho~ -:can ~e control non-clean fuel cars (1.e. tourism, tnters~te coerce) from entering the basin? . . 2. "The.:.Plan ~ns far short from providing the ~ecessar~ l~lementatlon '~lthout adequate consideration of possible, lmpacts. A ftscal tmpact report shOuld a:~company ~he AQHP ~n order.-to address the fiscal tssues and determine .. fundlng sources for l~le~ntatlon of the ~Q~P strategies. . :, Use of relatively st~le tacttcs such as bannlAg use of blowers and requiring .~rpaullns on gr~vel and dtrt hauling trucks could be added to the AQ~P and help ~ Increase co~11ance. . . ;CONO~ZC D;V;LOP~E~ ]HPACTS 1. The Plan does not provlde an Economic :Zmpact Analysts of the attainment measures. However, the measures are estimated to cost $8.0 m111~on per day for the "Tier 1" measures only. One can only assume that this burden will .be · .. · .' 'absorbed by- consumers and bustnesses fn' the reglon. The Impacts of these Increased costs could stunt the reglons economlc growth. 2. ~/tthout adequate consideration of the economtc lmpacts of the Implementation -measures, tt Is only hopeful that they wtll ever be Implemented. As mentioned · previously ..In our. comments, the economtc lmpac;s should be revlewed via a ftscal, lmpact report, Thts report could provide fundtng sources and economtc .. development strategies for post AQI~P Implementation, TO: ~Ro~: SUBJECT: I/IIJ. IN~ HUSTOII~ CITY RANAGER DEVELOPMENT DEPAETHEIIT CI::t',HENTS ON DRAFT AIR QUALTTY RAHAGE]qENT PLAN RECe~IqEHDATXON iii Instruct staff to complete formal comments on the Air Quality Management Plan and authorize t4ayor to transmit the City's comments prior to close of the review period. BACKGROUNO _ ii ii i .._The Federal Environmental Protection Agency (EPA) has ordered, through the ~urts, the South Coast Air Quallty Management Olstrtct (SCAQMD) to devise a ,an wh*ich a'ttalns the Federal Air Quality requirements .by the year. 2007. In response to these requirements the SCAQMD has prepared the Draft Air Quality Management Plan. This draft document has been circulated for comments from local jurl sdtcttons by October 28, 1988. ANALYSTS The, Community Development Department staff have reviewed the Plan and prepared preliminary comments for subnrlttal to SCAOt~O. These comments are on the formal draft Plan, a summary of which Is attached for review. The major issues Identified by staff are summarized as follows: · ,1. Policy._ Development: The Plan contains many poll cy statements which have far reachlng lmpacts. One example is the goal of reducing use of petroleum burning vehtcle engines by 405 by the year 2007. This reduction ts to be achieved by use of clean-burning fuel cars (electric and methanol). The business community and consumers will bear this burden and the provls~on of the required vehtcles ts uncertain. i,, J · Ctty Count11 Report ' ~- Comments on Draft Att Quallty Managment P.lan October 17, 1988 Page Staf~ Is concerned wtth thts poltcy and many of the other pollcJes contained tn the document. These ktnds of poltcles should have been formulated as a consensus, not as a top-down pressure approach. In order to reach attainment of these goals, all affected jurtsdlctlons must agree to implement them. 2, Zmplementatton Measures: The Plan Identifies many goals without provision of Implementation mea. sures. For Instance,. uslng the previously stated example, what assurance ts there that vehtcles capable of being powered by etther methanol or electricity wtll be produced by the market of satisfactory qualtty and quanttty to meet this goal? If this is possible, will the vehicles be used outside the air basin? If not, how can they be used for long distance travel by vehtcles in interstate commerce? And finally, how can we control non-clean fuel cars (i.e. tourism, interstate commerce) from entering the basin? · · The Plan runs far short from providing the necessary Implementation measures without adequate consideration of posstble impacts. 3. Growth Mana~eme.n..t: One of the key elements to the Plan tS to ensure a job to i~ouslng balance. This goal ts also supported by the $CAG Housing Allocation Plan. However, ensuring compliance with this policy is difficult at best, when considering the cost of housing and high interest rates of the region. In most cases, residents wi1.1 conttnue to 'commute because they can't afford to move. Additionally, the SCAG. growth forecasts for the region show tremendous growth. With a continued influx of new residents to the area, only more alt pollution will follow. Economic Zmpacts: The Plan does not provtde an Economic Zmpact Analysis of the attainment measures. However, the measures are estimated to cost.S8.0 mtllton per day for the 'Tter l" measures only (see summary). One can only assume that this. burden will be absorbed by consumers and businesses in the region. The impacts of these increased costs could stunt the regions economic growth. Without adequate consideration of the economic impacts of the implementation measures, it is only hopeful that they will ever be implemented. jONCLUSIO# · Staff is htghly concerned, with the adoption of a Plan which calls the local jurisdictions to enforce unreasonable or poor measures which will not ensure Corn reunify, Development Departrnen~ Clf, y Counc11 Report Comment, s on Draft Att quallty Hanagment Plan October 17, 1988 Page three attainment of clean air. Our recommendation is to prepare a response to SCAQMD and $CAG which requests both revision of the Plan and adequate consideration of the issues highlighted in this report. LCP: CAS: ts -tttachment:" Summary Director of Community Development · ,, Corn rnuniry Development Depar~men~ DRAFT 19 8 8 AIR QUALITY MANAGEM PLAN NT SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT SOUTHERN CALIF<3RNIA A$~:X:IAT1ON OF G EXECUTIVE SUMMARY BACKGROUND The South Coast Air Basin~ which cob:prises all 'of Orange County and the non-desert portions of Los Angeles, Riverside and San Bemardino Counties, has thc .worst air quality problem in the nation. Despite having put into place many strict controls, the Basin still fails to meet the federal air quality standards for four of the six criteria pollutants. The Basin is in compliance with federal standards for sulf~ dioxide and lead. But the maximum ozone concentrations here reach about three times the federal health standard. Carbon monoxide and fLUe particulate matter (PM10) reach maximum levels of twice the federal standard. And the Basin is the only area in the country that still faili to meet the nitrogen dioxide standard. The Basin's first Air Quality Management Plan (AQMP) was adopted in 1979. It contained an early action plan that emphasized ~ontrol measures which had been targeted by the federal Environmental Protection Agency (EPA) and the state Air Resources Board (ARB) as having high priority for implementation. The Plan also requested an extension until 1982 for subfiaittal of a revision that would address attainment of the carbon monoxide and ozone standards. .. With the better data and modeling methods available for the 1982 Revision of the AQMP, it became apparent that the Plan could not demonstrate a~_~i-~ent by the 1987 deadline required by the federal Clean Air Act. Tlierefore, the 1982 AQMP Revision proposed a long range strategy that could result in attainment in 20 years. In 1987, a federal court ordered the EPA to disapprove the 1982 AQMP Revision because it did not demonstrate anainment by the 1987 deadline. i September. 1988 \ PURPOSE OF THE 1988 REVISION OF THE AIR QUALI'I'~ MANAGEMENT PLAN (AQMP) · .The purpos~ of the 1988 R~'ision of the AQMP is' to set for~. a c0mprehemzv.e control program that will lead the South Coast Air Basin rote compliance with all federal and state air quality standards. This goal has been set by the Board of Directors of the South. Coast Air Quality. Management District (the District) and the Executive Committee of the Southern Calffo~a Association of Governments (SC, AG). ' In 1988, the District Board adopted a policy calling for attainment of all the federal and state health standards at the earliest practicable date, but no later them December 31, 1996 for nitrogen dioxide, December 31, 1997 for carbon monoxide, December 31, 2007 for ozone and PM10. The .AQMP. includes interim go-Is for ozone and PM10 to be met. by the year 2000. For ozone, the interim goal is to reduce maximum concentrations to no higher than the Stage I emergency episode level (0.20 ppm), and to reduce the average per capita exposure to ozone levels above the federal standakd by 70 percent compared to 1985. For PM10, the interim goal is to attain the federal standards. The District is responsible for completing the overall AQMP, with major elements contributed by SC. AG and the Ca~omia Air Resources Board. SCAG is responsible for developing regional plans for tramportation management, growth and land use. These plans each include strategies that ' contri, bute to air quality improvement, and are included in the AQMP. The Cali/ornia Air Resources Board is responsible for developing mobile source control measures, such as vehicle emission standards and fuel specifications. Once the 1988 AQMP Revision is adopted locally, and approved by the California Air Resources Board, it will be included in the State Implementation Plan (SIP). It will then serve as the' framework for all future air pollution control efforts in the South Coast Air Basin. ii September, 1988 EZE-GU l-lYE ;::i U I,~,,;ARY ~ · . . SOURCES AND QUANTITIES OF EMISSIONS Figure 1 shows the' relative conu'ibufion of certain emissions from each of ~c .major'categories of sources during 1985, thc baseline year used ~o represem · the correm 'situation. For som.e polluum~s, such as carbon monoxide, the emissions are overwhelmingly due ~o mobile sources - primarily cars, t/'ucks and buses. For other pollutan~ such as reactive organ/c gases and oxides of nin'ogen (the precursors of ozone), the sources of emissions are more diverse. Figure I Relative Conm'bufioa By $~afionary And Mobile Sources ~o 1985 Emi-~sions NO= r'i'om: I04o Te~/Day) September, 1988 DRAFT 1988 AQIV,~,, The Basin's air quality proMem caunot be solved by' contro]iing any one category of sources.. For example, Table ! shows the 1985-.emissions of . ozoue precursors (ROO aud NOx) for each of the caiegories. Eveu if the em/~_~ions from any 'two of these .categories were totally eliminated, substantially more controls for the remaining two .would b.e required .to achieve thc reductions necessary to attain the ozone standard. · · TABLE 1 'Emissions of Ozone Precursors in 1985 (tons/day) Residential/Commercial/Services Indusu'ial/Manufacmring on-Road Mobile Sources Other Mobile Sources · ** To.t~l emissions in 1985 ROG NOx 280 142 310 144. 578 619 78 135 1,2.44 1,040 September, 1988 FUTi.~RE AIR QUALITY WITH NO ADDITIONAL CONTROLS · The yeaz~ 2000 and 2010 were selected to be the baselines for emissions forecasts. These forecasts were derived using the 1985 emissions data, adjns~ing d~em for the projected growr~ and a.~tming full implementation of all roles of the Disu'ict and the ARB that were adopted prior to December 31, 1987. ' The forecasts show a reduction in emi~ions of most pollutants by the year 2000. Bu~, by 2010, emissions are predicted to rise nearly as high or hi~,her than thc 198~ levels. Figure 2 show~ ~ pa~ern for reactive or§anic §ascs and oxides of niu'ogen. This resurgence in emissions is due entirely to the im.r, ac~ of growth, with two-thirds of this growth due to natural increases (b/nhs over deaths) rather than people moving in from other areas. Almost all the emission reductions expected over thc next few years as a result of thc rules currently in effect will be lost to the impact of the projected 37 percent increase in population and the related increases in jobs, housing and u'nf6c shown in Table 2. FIGURE 2 Emissions Wkh And Without Growth' lC~C W/la ?84 2OOO 2010 ROG 904 OTHER IM~etLA W/G W/O {3 NOx W/O (3 2010 September, 1988 u TAB~ 2 Socio-Economic Growth Forecasts for the South Coast Air. Basin · Compar/son of the year 2010 ~o the year 1985. Population Ho s units Total Employment Retail Employment Vehicle Miles Traveled Vehicles In Use Vehicle Trips 37% increase 46% increase 47% increase 47% increase 68~ increase 35%'increase 72% increase Controlling growth alone,, however, will not solve .the Basin's air quality problem. Even if no future growth were assumed, the emission reductions expected by the year 2010 as a result of existing rules would not be nearly enough to bring the Basin into compliance with the air quality standards for ozone, PM10 and carbon monoxide. Forecasts for the year 2010 show that the' distribution of emissions throughout the Basin will change over the years, w/th a significant decrease in emissions in the western part and an increase in the eastern part. Computer modeling was used to estimate the effect this distribution would have on air quality. Even though the Basin's total erni~sions of ROG and NOx are nearly the same in the year 2010 as they were in 1985, the resulting ozone distribution is very different. Modeling predi .cra that there would be large scale ( 0.11 ppm ) reduction in the ozone concentrations in Los Angeles and Orange counties, but a corresponding scale of deterioration in the inland areas. The peak ozone concentration would be reduced by 0.06 ppm and the affected area would shift eastward and would be larger. · vi September, 1988 THE ATTAINMENT STRATEGY In developing th~ AQlVIP, all the potential.'co'ntrol measures that could be · available by thc. year 2007 were identified and, to the extcnt 'possibl~, ~hcir' emission re, ductions were quant~e'd. 'These. control measures were categorized into three tiers, baaed upon the. ir readiness for implementation. Tier I. Full Implementation of known control technologies and management practices. Tier I controls are those that can be adopted within the next five years using currently available technological applications and management practices. Tier I control measures, summarized in Table 3, are expected to be implemented by 1993 except for transportation facility constructions which may continue up to 2007. The total estimated cost for the Tier I measures that have cost data i~ about 1;8.0 million per day. This represents an average cost of about 65 cents per day. for each resident of the Basin. Improved technology may reduce thc costs. On the other hand, the estimated air quality benefit is about I;2 per day per capita. Computer modeling has indicated that'Ticr I measures will bring the Basin into compliance with the federal standards for carbon monoxide and nitrogen dioxide. Additional control measures arc needed to' mcct the PM10 and ozone standards. Tier II. Significant advancement of today's technological applications and vigorous regulatory intervention. Tier II measures include already-demianstratcd control technologies, but require advancements that can reasonably be expected to occur in the near future. When necessary, these advancements are promoted through regulatory action, such as setting standards at levels that force the advancement of existing technology, or establishing a system of emission charges that provide an economic incentive to reduce emissions. vii September, 1988 · Tier'II measures mainly-focus on transportation sources and the use of coatings and solvi~nts.:i. Tier H measures and...goals are summarized in .Table..4. All the Tier H..go. als are. expected to bc. achio'ved by 2000 except for · wansponafion faciliv/conslrucfion which may conl~nue until 2007. Computer modeling indicates that the combination of Tier I and Tier II conttoh will bring the Basin into compliance with the federal, but not the state, standard for PM10. To meet the state standard for PM10, and the state and federal ozone standards, additional controls beyond Tier H will be required. TIER Ill- DEVELOPMENT OF NEW TECHNOLOGY Tier I~ programs are designed to bring about major technological breakthroughs to further reduce emi~ion~ of reactive organic gases. Unlike the first two tiers, which focus on implementing and strengthening known .cont[.o.l measures, Tier IH promotes research, development and widespread commercial application of technologies that may not exist yet,' but may be reasonably expected given thc rapid technological advances experienced over the past 20 years. Although no specific control measures can be summarized for Tier IlL the programs included in this tier are directed primarily at further reducing ROG emissions from solvents and coatings, and from motor vehicles. Possible Tier IH control strategies for solvents and coatings include fur',.her improvement in water-based products, ultraviolet-curable coatings, two- component coatings, and non-reactive solvents. These strategics, along with the prohibition of certain coating processes, offer thc promise of almost complete elimination of ROG from solvents and coatings. With respect to clean-fueled vehicles, recent progress in fuel cells, solar cells, storage batteries, and superconductors offer the promise of eliminating combustion processes from motor vehicles almost entirely. viii September, 1988 If suf~cien~ technologies ~o achieve ~e standards are nbt identifiable by the m~d-nineties, a contingency plan ,will be developed for replacing high- pollutin~ industrics with low-~ollUtin~ indusu'ics havin~ equiv~en~ employment potentiaL " .. Modeling indicates that a fur~er 90 percent reduction of ROG from ~olvents · and~ coatings, and total conversion of the veMcle' fleet to clean' fuels; can bring the Basin very Close to the federal ozone standard with a Basin pcalc of 1.2.6 l~hm_- -' · There is some uncenaimy in the ozone model at low ozone concentrations. This unccrtaint% along with the inab/lity to predict the future for technology that does not yet exisL must be taken into account when trying to determine the possible air quality improvement associated with Tier ITt_ Further study will be required to determ/ne if, or how much, additional control will be necessary to meet the federal and state ozone standards. Modeling indicates that to meet the state standards for PMIO and ozone, we will requite flu'fi=er technology advancement than just solvent substitution and dean fueh. ix Septemloer, 1988 PREDIC'I;ION OF AIR QUALITY IMPROVEMENTS The air quality !m_provements predicted as a result of each Of the three tiers · ' of the anaimnent strategY. are shown in Figm-.e 3. .. Figar~ 3 Projection of Future Air Quality in the South Coast Air Basin in Comparison with the Most Stringent Federal Standards 4OO 350 3OO 250 20O 150 lO0 50 0 NO2 PM'lO - OZONE CC) POLLUTANT ~ 2000 · To estimate the degree of air quality improvement expected before Tier IH measures are put into effect, an evaluation was made for the year 2000, assuming maximum implementation of the control measures in Tiers I and H. The results are; le Compliance with all federal and State standards for carbon monoxide, Co. mpliance with all federal and state standards for nitrogen dioxide, Compliance with the federal annual and 24-hour average PM10 standard, but without any sa/ety margin, · e Basinwide peak 24-hour average PM10 concentrations would be about 2.4 times the state standard, and the annual average PM10 concentration would be about 1.6 times the state standard, x Septemt~er, 1988 .. Peak ozone concentrations will be lowered to me level of the S.tage I Episode ( 0.20 ppm), ':' ' · · The Basinw/de average per capita exposure to oz. one levels 'ibove the- federal standard will be lowered about 90 per.cent from the 1915. average. . . SCHEDULE FOR IMPLEMENTATION OF ATTAINMENT STRATEGIES Thc schedule for implementation of each tier of the attainment strategy is shown in Figure 4. The 'rnile~tone for complete adoption of Tier I control measure~ h 1993. Tier II goah for emission reduction are expected to be achieved by 1998. FIGURE 4 Am/nment Strategy Timetable Z xi September, 1988 Achieving the' Tier IX[ emlx_~ion reduction goals depends largely on research · and technological bre,~~oughs that nmy reasonably be.expected to occur during thc next two decades. But actual implementation Of Tier ~ measures is projected to begin as the T/er H goal~ axe achieved in 1998. The T/ct III measures will then be implemented on an accelerated schedule intended to achieve attainment by the year 2007. Progress toward attainment will be tracked in annual 'status rep°ns to ~e Distric~ Board. Additional control measures will be proposed, or others advanced, as necessary or appropriate. · RESPONSIBIUTYFOR IMPLEMENTATION OF ATTAINMENT STRATEGIES Tier I control measures can be implemented by exis~g agencies using their exis~g authority. The priority fbr each measure's implcmenta~on is based on the following criteria: · , Potential for reducing em/ssions · T~me required for implementation Technical and legal readiness for implementation Cost effectiveness of control Availability of financing Short term benefit in relation to long term goah Number of years benefit would accrue Based upon thc above criteria, the responsible implementing agencies, the adoption dates, and the associated activities have been identified. Tier H control measures are primarily extensions of Tier I mealures, but with more stringent requ/rements. T/er II goals are heavily dependent' on research and development to facilitate their commercial application and widespr~.a~d u.se.. The technology advancement and-demonstration, projects xii September, 1988 needed to ensure meeting the Tier II goals are provided along with the · responsible agencies and thc time frames for ~ach measure's implementafiom The District will be responsible for implementing all measures related to stationary .sources. 'Growth management measures will be the primary responsibility of local governments, but there may be some involvement with. such regional organ/zafions as SC, AG and the District.. Local transportation commissions, along with Caltram, will be responsible for improvements ~o uansp°nafion infrastructure. Further controh on motor vehicles, including alternative fuels, are the responsibil/ty of the ARB with the assistance of the District. In some cases, regulatory actions such as technology-forcing standards, emission charges, and growth-management measures will be needed to bring about thc technology necessary to achicve Tier II goals. 'The regulatory actions that require legislation along with the responsible agencies have been provided. The strategies necessary to achieve Tier 1II goals are thc responsibility of thc District, in conjunction with thc state Air Resources Board, md local and regional transportation and.planning agendes. A task force should be formed to coordinate necessary regulatory actions and to morfitor progress toward meeting the Tier II and Tier HI goals. xiii September, 1988 · SU1VIMARY OF TIER I CONTROL M .:F_~ASURES · Controls'on the use' of''~-oatinp and solvents · ?~rw~ control measures such as using low VOC paints ~nd solvent, s, higher transfer efficiency for applyin~ coatings and controlling run'cs ~rom coating opcrations. Also. rcdudng. emissions-fi.om consumer products such as aerosol sprays and underarm dcodoran~ Controls on the production, retinal and dlstributrion of' petroleum and gas F'~tcen control measures to control cmissiom from roguery heaters and boilers, oll field generators, valves, pumps and compressors, and improve vapor recovery systems. Controls on industr~ and commerciei proeesses Ten control measures such as reducing emissions from small sources which arc exempt from existing rules, controlling cmi~_,ions from boilers and internal combustion engines. Controls on residential equipment and public servicu N'u~ control measures such as rcducin~ nitrogen oxid~ cmis.sions from water heaters and furnaces, col:ltrollln~a fugitiv~ ClVlis~OaS fi.om publicly*ownod wastcwa~cr treatment plants, controlling dust .from roads and parking lots, and transporting~oiid wastes out of thc Basin for disposal Controls on agricultural sources · Thrc~ control measures to roduce rcaaivc cmlte_!om fi.om pesticide applications, ammonia from livestock was~c~ and fugitive dus~ from farming operations. · Controls on other stationary sources Ten control mcasure such as requiring us~ of Best Available Retro~ Control Technology for ail cxisti~ sources, tightening rcquircmenu for New Source R ow, requiring low-emission materials for building consuuction, and phasing out usc of fucl oil and coal by stationary sources. Controls on motor vehicles N'u'~ctcen control measures such as requiring stricter emission control standards for new vehicles, clean fuels for flcct vchiclc~ improved inspection and maintenance programs and controls on diesel pow~rcd buses and trucks. Controls on tr~_n~portatioa systems and land use Twenty-two control measures to reduce vehicle ~ improve traffic flow, improve public trnn.~it, and manage growth. Control on other mobile sources Thirteen control measures such as reducing emissions from aircrnft, ships, locomotives, construction cquipment~ pleasure boats and off-road motor,.-yclcs. xiv September, 1988 .. · SUMMARY OF TIER II CONTROL MEASURES AND GoaLs. Converting 40 percent of the passenger vehicles and ?0 percent of the vehicl clean ~els (e.g., methanol; fuel cells, or freight es to operate on e. lectric power). All diesel-powered tranm buses switched to clean fuels (e.g., methanol'or liquid propane gas). ' Reducing the remaining emissions ~om other mobile sources (aircraft, ships, locomotives, construction eqmpment) by 50 percent. ReduX:lng the remaining ROG emissions from solvents and coating by $0 percent. Reducing the remaining ROG em/ssions from i:onsumer products by $0 percent Minimizing potential increases in emissions from existing stationary sources xv September. 1988