carb staff report - 2016 air quality management plan for ...mar 07, 2017 · this report presents...
TRANSCRIPT
Staff Report
ARB Review of the 2016 Air Quality Management Plan
for the South Coast Air Basin and
Coachella Valley
Release Date: March 7, 2017 Hearing Date: March 23, 2017
This document has been reviewed by the staff of the California Air Resources Board and approved for publication. Approval does not signify that the contents necessarily reflect the views and policies of the Air Resources Board, nor does the mention of trade names or commercial products constitute endorsement or recommendation for use.
Electronic copies from this document are available for download from the Air Resources Board’s Internet site at: http://www.arb.ca.gov/planning/sip/sip.htm. In addition, written copies may be obtained from the Public Information Office, Air Resources Board, 1001 I Street, 1st Floor, Visitors and Environmental Services Center, Sacramento, California 95814, (916) 322-2990.
For individuals with sensory disabilities, this document is available in Braille, large print, audiocassette or computer disk. Please contact ARB's Disability Coordinator at (916) 323-4916 by voice or through the California Relay Services at 711, to place your request for disability services. If you are a person with limited English and would like to request interpreter services, please contact ARB's Bilingual Manager at (916) 323-7053.
For general questions, contact:
Scott King, Air Pollution Specialist South Coast Air Quality Planning Section Air Resources Board P.O. Box 2815 Sacramento, California 95812
Phone: (916) 322-2832 Email: [email protected]
OR
Carol Sutkus, Manager South Coast Air Quality Planning Section Air Resources Board P.O. Box 2815 Sacramento, California 95812
Phone: (916) 322-1229 Email: [email protected]
Table of Contents
I. EXECUTIVE SUMMARY ......................................................................................... 1 II. BACKGROUND ....................................................................................................... 1 III. NATURE OF OZONE AND PM2.5 IN THE SOUTH COAST REGION.................. 4 IV. ATTAINMENT DEMONSTRATION ....................................................................... 8 V. ATTAINMENT CONTROL STRATEGY ................................................................. 11
A. South Coast Commitment ................................................................................ 12 B. State SIP Strategy Commitment ...................................................................... 15 C. Implementing the Strategy ............................................................................... 20
VI. ADDITIONAL CLEAN AIR ACT REQUIREMENTS ............................................. 24 A. Emission Inventory........................................................................................... 24 B. Emission Statement Certification ..................................................................... 25 C. Reasonably Available Control Measures Demonstration (RACM) ................... 25 D. Best Available Control Measures Demonstration (BACM) ............................... 25 E. Reasonable Further Progress (RFP) for Ozone............................................... 26 F. Reasonable Further Progress for PM2.5.......................................................... 26 G. Quantitative Milestones for PM2.5 ................................................................... 27 H. Contingency Measures .................................................................................... 27
1. RFP Contingency Measure for Ozone in the South Coast............................ 27 2. Attainment Contingency Measures for Ozone in South Coast ...................... 28 3. Attainment Contingency Measures for Ozone in Coachella Valley ............... 28 4. Contingency Measures for PM2.5 in South Coast ........................................ 29
I. Weight of Evidence ............................................................................................. 29 J. Transportation Conformity Budgets..................................................................... 29 K. Vehicle Miles Traveled (VMT) Offset Demonstration ....................................... 30 L. New Source Review......................................................................................... 30
VII. Environmental Impacts ........................................................................................ 31 VIII. STAFF RECOMMENDATION ............................................................................. 32
APPENDIX A: ARB Staff’s Assessment of the South Coast Air Quality Management District’s 2015 and 2016 RECLAIM Amendments
APPENDIX B: South Coast Air Basin Ozone Weight of Evidence Analysis APPENDIX C: Coachella Valley Ozone Weight of Evidence Analysis APPENDIX D: South Coast Air Basin PM2.5 Weight of Evidence Analysis
I. EXECUTIVE SUMMARY
This report presents the Air Resources Board (ARB or Board) staff’s assessment of the South Coast Air Quality Management District (District) 2016 Air Quality Management Plan (2016 AQMP) that was adopted by the District Board on March 3, 2017. The AQMP is a comprehensive roadmap for meeting federal air quality standards (standards) for ozone and fine particulate matter (PM2.5) in the South Coast and Coachella Valley over the next fifteen years. Attaining these standards will provide essential public health protection for the 17 million residents living in the region by reducing hospitalizations for heart and lung related causes, decreasing emergency room visits and incidences of asthma, and preventing premature mortality. The 2016 AQMP builds upon the success of previous planning efforts and defines actions to deploy the next generation of technologies and fuels, in coordination with efforts to enhance the efficiency of moving people and freight, and the design of more sustainable communities.
ARB staff has reviewed the 2016 AQMP released in December 2016 to determine its compliance with the requirements of the Clean Air Act (Act). ARB’s staff review also includes the changes to the proposed AQMP made by the District Board at the March 3 District Board meeting. These amendments further strengthen the 2016 AQMP by accelerating 5 tons per day (tpd) of oxides of nitrogen (NOx) reductions:
• Directing staff to prepare an indirect source rule for airports (excluding aircraft) for Board consideration by February 1, 2019;
• Directing staff to propose a feasible path for sun setting the District’s Regional Clean Air Incentives Market (RECLAIM) program for large industrial sources, and accelerating further reductions from 2031 to 2025;
• Requesting legislative authority to allow the District to require public fleets to replace older heavy-duty on-road vehicles with zero emissions vehicles; and,
• Placing a priority on incentive programs for near-zero technologies for heavy-duty trucks to achieve near-term reductions.
Section VI provides a list of the Act requirements and an overview of how these requirements are met in the 2016 AQMP. As described below, ARB staff recommends that the Board approve the 2016 AQMP, along with the amendments adopted by the District Board, and direct staff to submit the approved AQMP to the United States Environmental Protection Agency (U.S. EPA) as a revision to California’s State Implementation Plan (SIP).
Building on Current Air Quality Progress
Based on research demonstrating adverse health effects at lower exposure levels, the U.S. EPA has set a series of increasingly health protective air quality standards for ozone and PM2.5. The 2016 AQMP addresses current planning requirements for the 8-hour ozone standard of 75 parts per billion (ppb) with an attainment date of 2031, and the annual PM2.5 standard of 12 micrograms per cubic meter (ug/m3), with an
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attainment date of 2025. The AQMP also addresses progress towards attainment of earlier standards that have not yet been achieved, including the 1-hour ozone standard of 120 ppb (with an attainment date of 2022), the 8-hour ozone standard of 80 ppb (with an attainment date of 2023), and the 24-hour PM2.5 standard of 35 µg/m3 (with an attainment date of 2019).
As a result of current control programs, ozone and PM2.5 levels in the South Coast and Coachella Valley have shown significant improvement, with continued progress towards meeting each of these standards. The South Coast, one of only two Extreme nonattainment areas in the nation, once measured ozone values above the 1-hour ozone standard on over 200 days per year. Today it has dropped to 17. Similarly, the number of days over the 8-hour standards has been cut in half since 1990. As illustrated in Figure ES-1, in 1990 the entire South Coast Air Basin recorded values over the 75 ppb 8-hour ozone standard. Today, peak concentrations have declined approximately 45 percent, and about 40 percent of the population now lives in communities that meet this standard. The South Coast also continues to see steady progress towards meeting the federal annual average PM2.5 standard of 12 ug/m3, with concentrations declining over 50 percent since 2000, and the region met the prior 15 µg/m3 annual standard in 2013. Yet significant challenges remain, and new strategies will be necessary to build on this progress and ensure the region meets all air quality standards as required under the Act.
Figure ES-1: South Coast Ozone Progress
Defining Attainment Needs
ARB and the South Coast collaborated on air quality modeling to estimate the reductions needed to attain the ozone and PM2.5 standards. Continued implementation of current control programs will further reduce emissions of smog- and particulate-forming NOx over 50 percent from today’s levels by 2031. These programs will also result in significant reductions in PM2.5 emissions. Ongoing mobile source
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reductions to reduce regional PM2.5 concentrations, coupled with targeted stationary source controls are expected to bring the entire South Coast region into attainment of the PM2.5 standards by 2025.
Meeting ozone standards therefore is the primary driver for overall attainment needs, and reductions beyond those being achieved with current control programs will be needed to meet the standards in 2023 and 2031. Reductions of reactive organic gases (ROG) provide near-term benefits in some portions of the South Coast, and are important for ensuring progress towards the 1-hour ozone standard; however the ozone standards can only be met through significant NOx reductions. The air quality modeling indicates this will require an approximate 70 percent reduction in NOx emissions from today’s levels by 2023, and an overall 80 percent reduction by 2031.
Strategy for Achieving Healthful Air
As shown in Figure ES-2, ongoing implementation of current control programs will provide substantial NOx reductions through 2031. These reductions are a result of the success of ARB’s comprehensive mobile source control program and District stationary source control regulations. Nonetheless, significant further reductions will be required to ultimately reach an 80 percent reduction by 2031 (blue line). Achieving these reductions is a joint responsibility of ARB and the District, along with actions at the federal level. ARB staff worked closely with South Coast staff in developing the attainment strategy, and the 2016 AQMP includes a suite of actions for both stationary and mobile sources to meet both ozone and PM2.5 standards and bring healthful air to the region.
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Figure ES-2: NOx Benefits of Adopted and Proposed Regulations
At the State level, the Proposed 2016 State SIP Strategy for the State Implementation Plan (State SIP Strategy) provides ARB’s commitment for the emission reductions needed from the mobile sector and consumer products. The proposed measures in the State SIP Strategy identify the regulatory and programmatic approaches necessary to deploy cleaner technologies and fuels, and ensure sufficient penetration to meet air quality standards by deadlines established in the Act. These measures include a portfolio approach of technology forcing engine standards, cleaner burning fuels, durability requirements and inspection programs to ensure clean in-use performance, sales requirements for advanced technologies, pilot programs to identify and advance new technologies, and incentive programs to accelerate technology deployment.
Approximately 70 percent of the mobile source reductions needed to meet the 75 ppb 8-hour ozone standard in the South Coast comes from existing or proposed regulatory actions. This percentage is even higher for passenger cars and trucks, where regulatory measures comprise 93 percent and 88 percent respectively of the needed reductions. These regulatory actions form the core of the strategy, and are critical to drive technology development and deployment of the cleanest near-zero and zero-emission technologies into the fleet.
The remaining 30 percent of reductions come from additional efforts to enhance the deployment of these cleaner technologies through new incentive or regulatory actions to meet the South Coast’s Extreme ozone nonattainment area needs. Other ongoing efforts may also provide pathways for emission reductions, including non-monetary incentives to reward use of cleaner technologies, actions to promote efficiency improvements in moving people and freight, and support for the use of advanced
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transportation technologies, such as intelligent transportation systems and autonomous vehicles. Implementing the State SIP Strategy will require early and sustained action, and include efforts not only by ARB, U.S. EPA, and other federal and international agencies. Action by U.S. EPA and other federal and international agencies will be especially critical for sources that are under their primary regulatory authority, including interstate trucks, locomotives, and ocean going vessels. In aggregate, implementation of the State SIP Strategy will reduce mobile source NOx emissions over 260 tpd by 2023, increasing to almost 300 tpd by 2031 (Table ES-1).
Table ES-1: Mobile Emission Reductions Needed for Attainment* (tpd)
Existing Mobile Programs
2023 153
2031 184
New Proposed Measures 113 111
Total Reductions 266 295 *from 2015 levels
At the local level, the District has outlined a series of proposed measures to achieve further reductions from a variety of sources under its jurisdiction. These measures address natural gas combustion equipment, non-refinery flares, commercial cooking, and residential and commercial appliances. The AQMP also includes a measure to achieve additional reductions for facilities that are covered under the District’s RECLAIM program. Similar to the State SIP Strategy, the District measures achieve reductions through a combination of technology forcing regulations coupled with incentives to accelerate deployment and enhance public acceptance of new technologies. The District has also identified mechanisms under its local authority to achieve emission reductions from mobile sources within the region, including facility based measures and public fleet rules. These efforts complement ARB’s statewide actions and are an important part of the implementation of the mobile source reductions included in the State’s commitment. As shown in Table ES-2, implementation of current and proposed District measures will achieve 38 tpd of NOx by 2023, reaching 47 tpd by 2031.
Table ES-2: District NOx Reductions in 2023 and 2031 (tpd)
Existing District Programs
2023
15
2031
16
New Proposed Measures 23 31
Total Reductions 38 47
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Together, ARB and District actions provide all of the reductions necessary to meet both ozone and PM2.5 standards over the next fifteen years. Meeting the standards will provide significant public health protection, which the District has estimated represents $173 billion in cumulative health benefits between 2017 and 2031. This includes approximately 2500 fewer annual asthma related emergency room visits, over 200,000 fewer lost work days and school absences, and 1600 premature deaths avoided.
Investments in bringing clean air to the region will deliver broad environmental emission reduction benefits as well as provide significant greenhouse gas and toxic diesel PM emission reduction benefits.
Securing Incentive Funding to Support Technology Transformation
Funding to support incentive-based programs and other innovative mechanisms will be an essential element of the attainment strategy in the South Coast. This will be especially important for achieving significant penetration of the cleanest technologies over the next five to ten years. ARB has worked with the South Coast on defining funding needs and mechanisms for implementing the State SIP Strategy. ARB and South Coast staff has estimated that sustained funding levels of approximately $1 billion per year through 2031 will be needed to support the necessary scale of technology transformation. This represents the upper limit on funding needs. Emission reductions achieved through system efficiencies, additional regulatory efforts, and co-benefits from climate program initiatives would reduce the overall funding needed.
The South Coast has recently released a Draft Financial Incentives Funding Action Plan (Funding Action Plan)1 which describes existing sources of funding, new funding opportunities, activities that will be undertaken to pursue each potential funding mechanism, as well as a schedule and reporting process. As part of this effort, the South Coast has identified a broad spectrum of potential funding mechanisms that could meet the region’s funding needs. The scope of funding sources reflects the important role that all levels of government must play in bringing healthy air to the South Coast region. Targeted funding in disadvantaged communities can also provide significant benefits for residents who are disproportionately impacted by multiple emission sources by reducing both criteria pollutants and toxic air contaminants. An enhanced focus on investments in these communities will be an important element of the implementation of the funding plan.
The South Coast is also establishing a stakeholder working group to help further develop and implement the Funding Action Plan. ARB will continue to collaborate with the South Coast on the Funding Action Plan, as well as play a key role in implementing State level efforts that are facilitating the transition to cleaner technologies such as the California Sustainable Freight Action Plan, the ZEV Action Plan and the Transformative Climate Communities program.
1 http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-plans/2016-air-quality-management-plan/draftfinancialincentivefunddec2016.pdf?sfvrsn=6
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Next Steps
The District Board initially considered the 2016 AQMP on February 3, 2017. Based on Board member discussion regarding potential amendments to further strengthen the plan, the Board postponed action on the AQMP until their March 3, 2017 meeting.
At the March 3 Board meeting the Board adopted the plan along with several additional amendments. As noted above, these amendments commit to prepare for Board consideration an indirect source rule for commercial airports, sunset the RECLAIM program, request legislative authority to allow the District to require public fleets to replace older heavy-duty on-road vehicles with zero emissions vehicles, and prioritize incentive funding for near-zero heavy-duty truck technologies. In addition, the District will begin a collaborative process for achieving further reductions from ports, rail yards, and warehouse facilities. District staff will report back to the Board within one year, and if progress is not made in identifying actions for specific reductions, will initiate a rulemaking process should it be necessary to ensure sufficient reductions to meet the region’s attainment needs. The ARB will consider adoption of the 2016 AQMP at the March 23-24, 2017 Board Meeting. ARB staff recommends that the Board approve the 2016 AQMP, along with the amendments adopted by the District Board, and direct staff to submit the approved AQMP as a SIP revision to U.S. EPA.
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II. BACKGROUND
Exposure to ozone and PM2.5 can cause severe harm to human health, especially in sensitive populations such as young children, older adults and those with diseases that already compromise their respiratory or cardiovascular systems. Ozone is a highly reactive gas that can damage the tissues of the respiratory tract, causing inflammation and irritation, and resulting in symptoms such as coughing, chest tightness and the exacerbation of asthma symptoms. Ozone exposure can also lead to decreased lung function. With respect to PM2.5, studies have linked daily exposure with hospitalization for heart and lung related causes, as well as an increase in emergency room visits, exacerbation of asthma, and other respiratory diseases, such as chronic obstructive pulmonary disease, increased respiratory symptoms, and increased asthma medication use. Older adults and other individuals with pre-existing chronic heart or lung disease are at greatest risk of experiencing the most serious of the adverse effects related to PM2.5 exposure. Most critically, exposure to PM2.5 and ozone has been estimated to contribute to approximately 7,500 premature deaths in California and millions globally each year.
The Clean Air Act requires U.S. EPA to set health-based air quality standards and periodically review the latest health research to ensure that standards remain protective of public health. Based on research demonstrating adverse health effects at lower exposure levels, U.S. EPA has set a series of increasingly health-protective standards. For ozone, U.S. EPA initially set a 1-hour ozone standard of 120 ppb in 1979. Subsequent health studies have demonstrated the greater effects of exposure to ozone over longer time periods, resulting in U.S. EPA establishing an 8-hour ozone standard of 80 ppb in 1997, and the 75 ppb standard in 20082. U.S. EPA first established a PM2.5 standard in 1997, consisting of a 24-hour PM2.5 standard of 65 µg/m3 and an annual standard of 15 µg/m3. Based on an extensive assessment and scientific review of the health impacts of PM2.5 pollution, U.S. EPA strengthened the 24-hour PM2.5 standard to 35 µg/m3 in 20063, and the annual standard to 12 µg/m3 in 20124.
In May 2012, U.S. EPA designated nonattainment areas for the 75 ppb ozone standard, effective July 20, 2012.5 Ozone nonattainment areas are classified according to the severity of their air pollution problem. Areas with higher pollution levels are given more time to meet the standard (attainment date), but are also subject to more stringent control requirements. The 2016 AQMP addresses planning requirements for both the South Coast Air Basin and the Coachella Valley nonattainment areas. The South Coast and the San Joaquin Valley are the only two areas with an Extreme classification in the nation. The Coachella Valley is classified as a serious nonattainment area. The Coachella Valley already meets the 1-hour ozone standard, and U.S. EPA recently proposed approval of the region’s plan demonstrating attainment of the 80 ppb 8-hour ozone standard by its 2018 attainment date. The ozone standards and respective
2 73 FR 16436 https://www.gpo.gov/fdsys/pkg/FR-2008-03-27/pdf/E8-5645.pdf 3 71 FR 61144 https://www3.epa.gov/ttnamti1/files/ambient/pm25/pt5006.pdf 4 81 FR 61136 https://www.gpo.gov/fdsys/pkg/FR-2016-09-06/pdf/2016-21338.pdf 5 77 FR 30088 http://www.gpo.gov/fdsys/pkg/FR-2012-05-21/pdf/2012-11618.pdf
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attainment dates for both Serious and Extreme nonattainment areas are summarized in Table 1.
Table 1: Federal Ozone Standards in the 2016 AQMP and Attainment Dates
Federal Standard Attainment Year South Coast Air Basin
120 ppb 1-hour Ozone 2022 80 ppb 8-hour Ozone 2023 75 ppb 8-hour Ozone 2031
Coachella Valley 75 ppb 8-hour Ozone 2026
On July 20, 2012, U.S. EPA designated nonattainment areas for the most recent annual PM2.5 standard of 12 ug/m3. While U.S. EPA has determined that the South Coast now meets the prior 15 ug/m3 annual standard, the South Coast remains above the 12 ug/m3 annual standard, as well as the 35 ug/m3 24-hour standard. Unlike ozone, the Act establishes a step-wide process for PM2.5 classifications. The South Coast is currently classified as Serious for the 35 µg/m3 24-hour PM2.5 standard with an attainment date of 2019. For the 12 µg/m3 annual PM2.5 standard, the South Coast is classified as Moderate, with an initial attainment date of 2021. Under the Act’s step-wise process, areas can make a demonstration that a longer-term horizon is needed to implement the types of technologies needed for attainment. These areas can then request a classification of Serious, with an attainment deadline of 2025. The 2016 AQMP includes this reclassification request for the 12 ug/m3 annual PM2.5 standard. Table 2 summarizes the PM2.5 standards and respective attainment dates.
Table 2: Federal PM2.5 Standards in the 2016 AQMP and Attainment Dates
Federal Standard Attainment Year South Coast Air Basin
35 ug/m 3 24-hour PM2.5 2019 12 ug/m 3 Annual PM2.5 2025
All together, the 2016 AQMP addresses a combination of five pertinent ozone and PM2.5 standards for the South Coast and Coachella Valley. Current ozone and PM2.5 levels in the South Coast and Coachella Valley are shown in Table 3. Addressing multiple pollutants within an integrated planning framework provides a more efficient and effective planning process to maximize air quality benefits of control programs. The District Governing Board adopted the 2016 AQMP to address both ozone and PM2.5 planning requirements for the South Coast and the Coachella Valley on March 3, 2017.
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Table 3: 2015 Design Values and Percentage above Federal Standards
Federal Standard 2015 Level 2015 Percent Above Standard
South Coast Air Basin 120 ppb 1-hour Ozone 130 ppb 5 percent 80 ppb 8-hour Ozone 102 ppb 21 percent 75 ppb 8-hour Ozone 102 ppb 36 percent 35 ug/m3 24-hour PM2.5 40 ug/m3 14 percent 12 ug/m3 Annual PM2.5 14 ug/m3 17 percent
Coachella Valley 75 ppb 8-hour Ozone 88 ppb 17 percent
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III. NATURE OF OZONE AND PM2.5 IN THE SOUTH COAST REGION
A. SOUTH COAST AIR BASIN
The South Coast Air Basin includes the southern two-thirds of Los Angeles County, all of Orange County, and the western, urbanized portions of Riverside and San Bernardino counties. The area generally forms a lowland plain, bounded by the Pacific Ocean on the west and by mountains on the other three sides (Figure 1).
Figure 1: Map of the South Coast Air Basin and Coachella Valley Areas
The South Coast Air Basin is the nation’s second largest urban area and California’s largest metropolitan region. It is home to well over 16 million people, over 40 percent of the State’s population. The South Coast is also home to over 10.5 million passenger and commercial vehicles that travel over 130 billion miles per year. Emissions from these vehicles along with those from ships, ports, rail yards, and airports, combined with stationary sources such as refineries and power plants, all contribute to ozone and PM2.5 air pollution in the South Coast.
The dry Mediterranean climate of the region, complex terrain, and surrounding mountains, coupled with general west to east air flow driven by ocean breezes, leads to ozone concentrations that are highest in the spring through early fall in the central and eastern portions of the South Coast. Due to these factors, the South Coast has the highest ozone concentrations in the nation. In 2015, peak 8-hour ozone levels were 127 ppb, almost 70 percent above the 75 ppb ozone standard, and over the last three years the standard was exceeded somewhere in the region an average of almost 90 days each summer.
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However, the South Coast has made dramatic progress in reducing both 1-hour and 8-hour ozone concentrations over the last 40 years as a result of comprehensive control programs that have reduced ozone precursor emissions. Figure 2 illustrates progress in reducing 8-hour ozone design values. Design values are based on monitored air quality data to measure compliance with air quality standards. The 8-hour ozone design value is the fourth highest ozone measurement each year, averaged over three consecutive years. Today, the 8-hour ozone design value in the South Coast is more than 60 percent lower than it was in the 1970s. The 1-hour ozone design value has similarly decreased over 70 percent over this same time period. This progress in reducing pollution has occurred even as population grew by about a third, and the number of vehicles on the road increased by more than 50 percent since 1990.
Figure 2: 8-hour Ozone Trends in the South Coast Air Basin
While the ozone design values have decreased at most monitoring sites in the South Coast in the last 15 years, the rate of progress has been changing in recent years, with more modest declines in ozone levels. This has been most pronounced at monitoring sites in the San Gabriel Valley such as Fontana, Upland, and Pomona. This slowing of progress is indicative of changes in ozone chemistry, as the region transitions from being responsive to both ROG and NOx emission reductions, to one where NOx
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reductions will be essential for meeting the standards. The transition to a NOx sensitive regime has already occurred at some monitoring locations that are the furthest downwind, such as Perris. Over time, with continuing NOx reductions, the entire region will also undergo a similar transition. This complex chemistry indicates that past rates of progress cannot be used to project future rates, and underscores the need for photochemical modeling to assess the region’s emission reduction needs.
PM2.5 pollution in the South Coast has also steadily declined since U.S. EPA first promulgated standards in 1997. Figure 3 illustrates progress in reducing both annual average and 24-hour average PM2.5 levels since 2001. Similar to ozone, PM2.5 design values represent an average of measurements over consecutive three year periods. Annual levels have dropped 50 percent, while peak 24-hour concentrations have decreased 45 percent. Today, the annual average design value is 14 ug/m3. The 24-hour design value has increased in recent years in response to drier conditions associated with the drought. While elevated concentrations can occur throughout the year, the highest PM2.5 levels in the South Coast tend to occur during the late fall and early winter, when colder, more stagnant conditions lead to the formation and accumulation of PM2.5. Significant periods without rainfall in 2013 through 2015 allowed PM2.5 to accumulate over extended periods, resulting in higher peak concentrations.
Figure 3: Annual and 24-hour PM2.5 Trends in the South Coast Air Basin
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B. COACHELLA VALLEY
The Coachella Valley 8-hour ozone nonattainment area is the portion of Riverside County that lies in the Salton Sea Air Basin (Figure 1). The Coachella Valley is surrounded by large mountain ranges and has average daytime temperatures in the summer months of over 100 degrees. These conditions, coupled with transport of ozone and ozone precursors from the South Coast , along with local emissions result in levels of ozone that exceed the 8-hour ozone standard. In 2015, 8-hour ozone levels in the Coachella Valley were 88 ppb, 17 percent over the 75 ppb 8-hour ozone standard.
However, as emissions have been reduced in both the South Coast and Coachella Valley from implementation of State and District programs, ozone levels have decreased significantly. Today, the 8-hour ozone design value in the Coachella Valley is 30 percent below what it was in 1990 (Figure 4).
Figure 4: 8-hour Ozone Trends in Coachella Valley
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IV. ATTAINMENT DEMONSTRATION
The 2016 AQMP identifies both the magnitude of reductions needed to attain ozone and PM2.5 standards in the region, and the actions necessary to achieve those reductions. Given current progress in reducing PM2.5 levels, meeting ozone standards is the primary driver for the region’s attainment needs, and substantial reductions beyond those being achieved with the current control program are needed to meet the 8-hour ozone standards in 2023 and 2031.
Effective control strategies to reduce ozone have been informed by substantial research investments that have provided an improved understanding of the nature and sources of pollution in the South Coast, including comprehensive field studies, data analyses, and air quality modeling. These studies provide the foundation for the attainment demonstration contained in the 2016 AQMP. District staff, in collaboration with ARB, conducted air quality modeling for the 2016 AQMP following U.S. EPA modeling guidance6. Air quality modeling considers emission inventories along with measurements of meteorology and air quality to establish the relationship between emissions and air quality and to predict the level of man-made emissions limits in line with bringing the area into attainment with health-based air quality standards. The modeling also identifies the benefits of controlling different ozone and PM2.5 precursors.
The District’s modeling platform integrates meteorological modeling, emissions inventories and atmospheric chemistry simulations into a physically and chemically consistent framework. For the 2016 AQMP, the modeling platform was updated with satellite-based input data, improved chemical gaseous and particulate mechanisms, improved computational resources and post-processing utilities, enhanced spatial and temporal allocations of the emissions inventory, and a revised attainment demonstration methodology. This modeling was conducted using the U.S. EPA recommended Community Multi-scale Air Quality (CMAQ) modeling platform7 with Statewide Air Pollution Research Center SAPRC07 chemistry8, and the Weather Research and Forecasting Model (WRF) meteorological fields9. The modeling underwent extensive performance evaluation and effectively simulates the response of ozone concentrations in the region to changes in emissions over time.
This modeling demonstrates that meeting the 8-hour ozone standards will require an approximate 70 percent reduction in NOx emissions from today’s levels by 2023, and an overall 80 percent reduction by 2031. Table 4 identifies the NOx emission levels that must be reached to provide for attainment of the 1-hour ozone standard in 2022, the 80 ppb 8-hour ozone standard in 2023, and the 75 ppb 8-hour ozone standard in 2031. The 2016 AQMP modeling also demonstrates that while ROG reductions provide near-term benefits in some portions of the South Coast and is important in meeting the
6 https://www.epa.gov/ttn/scram/guidance/guide/Draft_O3-PM-RH_Modeling_Guidance-2014.pdf 7 http://www.epa.gov/scram001/8 http://www.engr.ucr.edu/~carter/SAPRC/ 9 http://www.wrf-model.org/
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1-hour ozone standard, these studies demonstrate that meeting the 8-hour ozone standards will require significant NOx reductions. Continued NOx reductions are also important for meeting PM2.5 standards in the region.
Table 4: South Coast Air Basin 8-hour Ozone NOx Attainment Levels (tpd)
NOx 2022 2023 2031
Attainment Level Emissions 245* 141 96
Percent Reduction from 2015 Emission Levels 44% 70% 80%
*Concurrent VOC reduction will assist in meeting the carrying capacity
With these reductions, the 2016 AQMP demonstrates the South Coast will attain each of the federal ozone standards by the requisite attainment deadlines, as well as provide for attainment of the 75 ppb 8-hour ozone standard in the Coachella Valley by 2026. Ongoing reductions from the current control strategy also provide for attainment of the 24-hour PM2.5 standard by the Serious area deadline of 2019. For the 12 μg/m3 annual PM2.5 standard, the 2016 AQMP follows the Act’s step-wise planning process for setting an appropriate classification and attainment timeframe. The 2016 AQMP includes this analysis and reclassification request, and demonstrates attainment of the 12 μg/m3 annual PM2.5 standard by the 2025 Serious area deadline. Table 5 summarizes the predicted ozone and PM2.5 concentrations in the respective attainment years. Figure 5 further illustrates the significant progress that will occur in reducing ozone levels throughout the South Coast on the path towards attainment. In addition, in 2015, U.S. EPA further strengthened the 8-hour ozone standard to 70 ppb. The control strategy included in the 2016 AQMP will provide the foundation for the reductions needed to meet the 70 ppb standard by the District’s attainment deadline of 2037.
Table 5: Predicted Attainment Concentrations in the Relevant Attainment Year
Modeled Design Value of Pollutant with Controls
Standard 1-hour Ozone
80 ppb10
8-hour Ozone 75 ppb
8-hour Ozone 24-hour PM2/5
Annual PM2.5
Attainment Year 2022 2023 2031 2019 2025
Design Value 122 ppb 84 ppb 75 ppb 31 ug/m3 11.8
ug/m3
10 Due to rounding conventions, compliance with the 80 ppb 8-hour ozone standard is achieved when ozone levels equal 84 ppb.
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Figure 5: Predicted Ozone Concentrations in the Attainment Years
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V. ATTAINMENT CONTROL STRATEGY
Achieving an 80 percent reduction in NOx emissions by 2031 will require comprehensive efforts to address emissions from both stationary and mobile sources through ongoing implementation of already adopted measures, as well as new actions to deploy the next generation of cleaner near-zero and zero emission technologies. Actions at the federal, State, and local levels have resulted in a decrease of over 75 percent in both mobile and stationary source NOx emissions between 1990 and today. These efforts have been the driver for the substantial air quality progress that has occurred to date in the South Coast region. Looking forward, continued implementation of current control efforts will reduce mobile source NOx emissions a further 50 percent by 2031. Achieving the benefits of the current control program will continue to require significant efforts for implementation and enforcement. Recognizing these benefits and ensuring effective implementation represents a key element of the overall attainment strategy.
However, significant further reductions are necessary to reach an 80 percent reduction by 2031. Achieving these reductions is a joint responsibility of ARB and the District, along with actions at the federal level. ARB staff worked closely with South Coast staff in developing the attainment strategy, and the 2016 AQMP includes a suite of actions for both stationary and mobile sources to meet both ozone and PM2.5 standards and bring healthful air to the region. Figure 6 illustrates the combination of current and new actions that provide the total reductions (blue arrows) needed for attainment.
Figure 6: NOx Emission Reductions are met by Existing and New Measures (tpd)
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A. South Coast Commitment
Measures adopted by the District as part of prior AQMPs provide significant emission reductions that also contribute to attainment of the ozone and PM2.5 standards addressed in the 2016 AQMP. The District is proposing 16 new measures to further reduce emissions from stationary sources (Table 6). These measures will reduce emissions from traditional combustion sources by replacing older, high-emitting equipment with new, lower or zero-emitting equipment. The AQMP also include a measure to achieve additional reductions for facilities that are covered under the District’s RECLAIM program. This measure was amended at the March 3 District Board to accelerate the 5 tpd in NOx reductions specified in the control measure from 2031 to 2025, and direct District staff to develop and present to the District Board a feasible path to transition the market-based program to a command-and-control based regulation as soon as practicable. ARB staff encourages the District to consider transitioning the refinery sector out of the program first as a means to maximize near-term direct reductions, especially in disadvantaged communities. Other District measures will secure emission reductions through education, co-benefits from other programs such as greenhouse gas efficiency measures and incentive programs.
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Table 6: District Measures for Stationary Sources
NUMBER TITLE Implementation Period Target
Reductions (tpd)
(2023/2031)
CMB-01 Transition to Zero and Near-Zero Emission Technologies for Stationary Sources Ongoing
NOx 2.5 / 6 VOC 1.2 / 2.8
CMB-02 Emission Reductions from Replacement with Zero or Near-Zero NOx Appliances in Commercial and Residential Applications
2020–2031 NOx 1.1 / 2.8
CMB-03 Emission Reductions from Non-Refinery Flares 2020 NOx 1.4 / 1.5
VOC 0.4 / 0.4
CMB-04 Emission Reductions from Restaurant Burners and Residential Cooking 2022 NOx 0.8 / 1.6
CMB-05 Further NOx Reductions from RECLAIM Assessment 2031 NOx 0 / 5
ECC-01 Co-Benefit Emission Reductions from GHG Programs, Policies, and Incentives Ongoing All TBDa
ECC-02 Co-Benefits from Existing Residential and Commercial Building Energy Efficiency Measures
Ongoing NOx 0.3 / 1.1
VOC 0.07 / 0.29
ECC-03 Additional Enhancements in Reducing Existing Residential Building Energy Use Ongoing NOx 1.2 / 2.1
VOC 0.2 / 0.3
ECC-04 Reduced Ozone Formation and Emission Reductions from Cool Roof Technology Ongoing All TBDa
FLX-01 Improved Education and Public Outreach Ongoing NOx N/Ab
MCS-01 Improved Breakdown Procedures and Process Re-Design All N/Ab
MCS-02 Application of All Feasible Measures All TBDa
BCM-10 Emission Reductions from Greenwaste Composting 2020 VOC 1.5 / 1.8c
FUG-01 Improved Leak Detection and Repair 2022 VOC 2 / 2
CTS-01 Further Emission Reductions from Coatings, Solvents, Adhesives, and Sealants 202-2031 VOC 1 / 2
FLX-02 Stationary Source VOC Incentives Ongoing VOC TBDb
areductions to be determined once the measure is further evaluated breductions that cannot be quantified ccorresponding VOC reductions from other measures
The District has also identified 15 complementary measures for mobile sources to help implement the reductions identified in the State SIP Strategy (Table 7). District measure reductions that are identified as TBD reflect emission reductions that are already included in the State’s commitment. These measures play an important role at the local level and include facility oriented measures, as well as incentive based programs for both on-road and off-road sources. At the District’s March 3 Board meeting, the Board adopted several amendments to further strengthen these measures. The first amendment commits to prepare for Board consideration an indirect source rules for commercial airports (excluding aircraft) by February 1, 2019. Other amendments will request legislative authority to allow the District to require public fleets to replace older heavy-duty on-road vehicles with zero emissions vehicles, and prioritize
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incentive funding for near-zero technologies for heavy-duty trucks to achieve near-term reductions. In addition, the District will begin a collaborative process for achieving commitments for further reductions from ports, rail yards, and warehouse facilities. District staff will report back to the Board within one year, and if progress is not made in identifying actions for specific reductions will initiate a rulemaking process should it be necessary to ensure sufficient reductions to meet the region’s attainment needs.
Table 7: District Measures for Mobile Sources
NUMBER TARGET TITLE IMPLEMENTATION PERIOD
REDUCTIONS (TPD)
(2023/2031)
EGM-01 all Emission Reductions from New
Development and Redevelopment Projects
2019-2031 TBDa
MOB-01 NOx, SOx, PM
Emission Reductions at Commercial Marine Ports Ongoing TBDb
MOB-02 NOx, PM Emission Reductions at Rail Yards and Intermodal Facilities Ongoing TBDa
MOB-03 All Emission Reductions at Warehouse Distribution Centers 2019-2031 TBD
MOB-04 All Emission Reductions at Commercial Airports 2019-2031 TBDb
MOB-05 VOC, NOx, CO
Accelerated Penetration of Partial Zero-Emission and Zero-Emission
Vehicles Ongoing TBDa
MOB-06 VOC, NOx, CO
Accelerated Retirement of Older Light-Duty and Medium-Duty Vehicles Ongoing TBDa
MOB-07 NOx, PM
Accelerated Penetration of Partial Zero-Emission and Zero-Emission
Light-Heavy- and Medium-Heavy-Duty Vehicles
Ongoing TBDa
MOB-08 NOx, PM Accelerated Retirement of Older On-Road Heavy-Duty Vehicles 2019-2031 TBDa
MOB-09 NOx, PM On-Road Mobile Source Emission Reduction Credit Generation Program 2019-2027 TBDa
MOB-10 NOx Extension of the SOON Provision for Construction/Industrial Equipment Ongoing 2.0 / 2.0
MOB-11 VOC, NOx, CO Extended Exchange Program Ongoing 2.9 / 1.0 [NOx]
MOB-12 NOx, PM Further Emission Reductions from Passenger Locomotives 2017-2023 TBDb
MOB-13 NOx, SOx, PM
Off-Road Mobile Source Emission Reduction Credit Generation Program 2019–2027 TBDa
MOB-14 NOx, PM Emission Reductions from Incentive Programs 2016–2024 11 / 7.8 [NOx]
a
emission reductions will be determined after projects are identified bsubmitted into the SIP as part of Rate-of-Progress reporting or future baseline inventories
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Finally, to address PM2.5 standards, the District has included 10 control measures that provide for emission reductions in 2025 to lower direct PM2.5 or PM2.5 precursor emissions. The PM2.5 control measures include episodic controls and technology assessments as shown in Table 8.
Table 8: District Stationary Source PM2.5 Control Measures
NUMBER TARGET TITLE IMPLEMENTATION PERIOD
REDUCTIONS (TPD)
(2021/2025)
BCM-01 PM Further Emission Reductions from Commercial Cooking 2018–2025 3.3/3.3*
BCM-02 PM Emission Reductions from Cooling Towers 2022 & beyond TBDa
BCM-03 PM Further Emission Reductions from Paved Road Dust Sources TBD TBDa
BCM-045 NH3] Emission Reductions from Manure Management Strategies TBD TBDa
BCM-05 NH3] Ammonia Emission Reductions from NOx Controls TBD TBDa
BCM-06 PM Emission Reductions from Abrasive Blasting Operations TBD TBDa
BCM-07 PM Emission Reductions from Stone Grinding, Cutting and Polishing Operations
TBD TBDa
BCM-08 PM Further Emission Reductions from Agricultural, Prescribed and Training Burning
TBD TBDa
BCM-09 PM Further Emission Reductions from Wood-Burning Fireplaces and Wood Stoves
TBD TBDa
BCM-10 VOC, NH3
Emission Reductions from Greenwaste Composting TBD 0.1 / 0.1 [NH3]
*contingency measure aemission reductions will be determined after projects are identified
A full description of District control measures can be found in Chapter 4 and Appendix IV-A11 of the 2016 AQMP.
B. State SIP Strategy Commitment
The State SIP Strategy provides ARB’s commitment for the emission reductions needed from the mobile sector and consumer products. ARB staff released an initial version of the State SIP Strategy on May 17, 2016. A revised version of the State SIP Strategy was released on March 6, 2017 reflecting the most recent air quality modeling and inventory data developed as part of the AQMP process, as well as refinements to
11 http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-plans/2016-air-quality-management-plan/draft-final-aqmp/strikeout/appivA2016.pdf?sfvrsn=30
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specific measures in response to stakeholder feedback and continued technology assessments. The proposed measures in the State SIP Strategy identify the regulatory and programmatic approaches necessary to deploy cleaner technologies and fuels, and ensure sufficient penetration to meet air quality standards by deadlines established in the Act. These measures include a portfolio approach of technology forcing engine standards, cleaner burning fuels, durability requirements and inspection programs to ensure clean in-use performance, sales requirements for advanced technologies, pilot programs to identify and advance new technologies, and incentive programs to accelerate technology deployment. The State SIP Strategy will be considered by the ARB Board on March 23-24, 2017, in conjunction with the 2016 AQMP. Adoption of the State SIP Strategy by the Board will create a commitment to bring to the Board or take action on defined new measures and achieve aggregate emission reductions by the specified attainment deadlines. The total emission reductions and the obligation to propose certain actions would become enforceable up on approval by U.S. EPA of the elements of the State SIP Strategy included in the 2016 AQMP.
Most of the reductions needed for attainment will come from the existing control program, which is projected to reduce NOx emissions from all sources by approximately 50 percent by 2031, providing a significant down payment on the emission reductions needed. The new measures contained in the State SIP Strategy commitment are shown in Table 10 and reflect a combination of State actions, petitions for federal action, as well as actions that outline a pathway for achieving further deployment of the cleanest technologies in each sector. Together with the emission reductions associated with ongoing implementation of the existing control program, these measures identify all of the reductions needed to achieve a 70 percent reduction in NOx emissions from mobile sources by 2023, and an 80 percent reduction by 2031 in the South Coast. Table 9 summarizes the combined reductions that will accrue through implementation of the current control program, along with proposed new measures identified in the SIP Strategy. The State SIP Strategy also includes a measure to address ROG emissions from consumer products, the largest source category of ROG emissions in the State.
Table 9: Mobile Source Emission Reduction Commitment (tpd)*
2023 2031
184
111
295
Existing Mobile Programs 153
New Proposed Measures
Total Reductions
113
266 *from 2015 levels
Table 10 lists proposed new SIP Measures in the 2016 AQMP and schedule for action. Table 11 further provides estimates of the emission reductions from each of the
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individual new measures. While Table 11 shows the anticipated emission reductions associated with each measure, the measures as proposed by staff or adopted by the Board may provide more or less reductions than the amount shown. ARB’s aggregate emission reduction commitments may be achieved through a combination of actions including but not limited to: the implementation of control measures; the expenditure of local, State or federal incentive funds; or through the implementation of other enforceable measures. In some cases, actions by federal and international agencies will be needed. In others, programmatic approaches must be developed and funding secured to achieve the reductions outlined in the further deployment of cleaner technologies measure for each sector. The Clean Air Act includes a provision for approval under Section 182(e)(5) advanced technology provisions to allow this future flexibility for Extreme areas such as the South Coast. Measures proposed for approval under Section 182(e)(5) are noted with an asterisk in Tables 10 and 11. Additional information on the control measures in the State SIP Strategy can be found in appendix IV-B in the draft final 2016 AQMP, or in the revised Proposed 2016 State SIP Strategy for the State Implementation Plan12.
12 https://www.arb.ca.gov/planning/sip/2016sip/2016sip.htm
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Table 10: Proposed New SIP Measures and Schedule
Proposed Measure Agency Action Implementation Begins
On-Road Light-Duty
Advanced Clean Cars 2 ARB 2020 – 2021 2026
Lower In-Use Emission Performance Assessment ARB / BAR n/a ongoing
Further Deployment of Cleaner Technologies* ARB / SCAQMD / U.S. EPA ongoing 2016
On-Road Heavy-Duty
Lower In-Use Emission Performance Level ARB 2017 – 2020 2018 +
Low-NOx Engine Standard – California Action ARB 2019 2023
Low-NOx Engine Standard – Federal Action* U.S. EPA 2019 2024
Medium and Heavy-Duty GHG Phase 2 ARB / U.S. EPA 2017 – 2019 2018 +
Innovative Clean Transit ARB 2017 2018
Last Mile Delivery ARB 2018 2020
Innovative Technology Certification Flexibility ARB 2016 2017
Zero-Emission Airport Shuttle Buses ARB 2018 2023 Incentive Funding to Achieve Further Emission Reductions from
On-Road Heavy-Duty Vehicles ARB / SCAQMD ongoing 2016
Further Deployment of Cleaner Technologies* ARB / SCAQMD / U.S. EPA ongoing 2016
Off-Road Federal and International Sources
More Stringent National Locomotive Emission Standards * U.S. EPA 2017 2023
Tier 4 Vessel Standards * ARB / IMO 2016 – 2018 2025
Incentivize Low Emission Efficient Ship Visits ARB 2018 – 2020 2018 +
At-Berth Regulation Amendments ARB 2017 – 2018 2023
Further Deployment of Cleaner Technologies* ARB / SCAQMD / U.S. EPA ongoing 2016
Off-Road Equipment
Zero-Emission Off-Road Forklift Regulation Phase 1 ARB 2020 2023
Zero-Emission Off-Road Emission Reduction Assessment ARB 2025 + --
Zero-Emission Off-Road Worksite Emission Reduction Assessment ARB tbd --
Zero-Emission Airport Ground Support Equipment ARB 2018 2023
Small Off-Road Engines ARB 2018 – 2020 2022
Transport Refrigeration Units Used for Cold Storage ARB 2018 – 2019 2020 +
Low-Emission Diesel Requirement ARB by 2020 2023
Further Deployment of Cleaner Technologies* ARB / SCAQMD / U.S. EPA ongoing 2016
Consumer Products
Consumer Products Program ARB 2019 – 2021 2020 + * Request U.S. EPA approval under the provisions of Section 182(e)(5) of the Clean Air Act allowing for reliance on anticipated development of new
control techniques or improvement of existing control technologies. Also includes identification of needed funding, infrastructure development, and actions/resources required from other agencies
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2023 2031 Proposed Measure NOx ROG NOx ROG
On-Road Light-Duty Advanced Clean Cars 2 -- -- 0.6 0.4 Lower In-Use Emission Performance Assessment NYQ NYQ NYQ NYQ Further Deployment of Cleaner Technologies* 7 16 5 16 Total Category Reductions 7 16 6 16
On-Road Heavy-Duty Lower In-Use Emission Performance Level NYQ <0.1 NYQ <0.1 Low-NOx Engine Standard – California Action -- -- 5 -- Low-NOx Engine Standard – Federal Action* -- -- 7 -- Medium and Heavy-Duty GHG Phase 2 NYQ NYQ NYQ NYQ Innovative Clean Transit <0.1 <0.1 0.1 <0.1 Last Mile Delivery <0.1 <0.1 0.4 <0.1 Innovative Technology Certification Flexibility NYQ NYQ NYQ NYQ Zero-Emission Airport Shuttle Buses NYQ NYQ NYQ NYQ Incentive Funding to Achieve Further Emission Reductions from 3 0.4 3 0.4 On-Road Heavy-Duty Vehicles Further Deployment of Cleaner Technologies* 34 4 11 1 Total Category Reductions 37 4 27 2 Off-Road Federal and International Sources*
Aircraft Further Deployment of Cleaner Technologies* 9 NYQ 13 NYQ Locomotives
More Stringent National Locomotive Emission Standards* <0.1 <0.1 2 <0.1 Further Deployment of Cleaner Technologies* 7 0.3 3 0.3 Ocean-Going Vessels Tier 4 Vessel Standards* -- -- NYQ NYQ Incentivize Low Emission Efficient Ship Visits NYQ NYQ NYQ NYQ At-Berth Regulation Amendments 0.3 <0.1 1 <0.1 Further Deployment of Cleaner Technologies* 30 NYQ 38 NYQ Total Off-Road Federal and International Reductions 46 0.3 57 0.3 Off-Road Equipment Zero-Emission Off-Road Forklift Regulation Phase 1 -- -- 1 0.1 Zero-Emission Off-Road Emission Reduction Assessment NYQ NYQ NYQ NYQ Zero-Emission Off-Road Worksite Emission Reduction Assessment NYQ NYQ NYQ NYQ Zero-Emission Airport Ground Support Equipment <0.1 <0.1 <0.1 <0.1 Small Off-Road Engines 0.7 7 2 16 Transport Refrigeration Units Used for Cold Storage NYQ NYQ NYQ NYQ Low-Emission Diesel Requirement 0.3 NYQ 1 NYQ Further Deployment of Cleaner Technologies* 21 21 18 20 Total Off-Road Equipment Reductions 22 28 22 36 Consumer Products Consumer Products Program -- 1 – 2 -- 4 – 5 Total Consumer Products Reductions -- 1 – 2 -- 4 – 5 Aggregate Emission Reductions 113 50 - 51 111 59 - 60
* Request U.S. EPA approval under the provisions of Section 182(e)(5) of the Clean Air Act; “NYQ” denotes emission reductions are Not Yet Quantified; “—“ denotes no anticipated reductions
Table 11: South Coast Expected Emission Reductions from State SIP Measures (tpd)
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C. Implementing the Strategy
Implementation of current control programs and new regulatory actions to establish requirements for cleaner technologies comprise the core of the overall strategy. The relative proportion of regulatory and incentive reductions varies by the sector, reflecting differences in the maturity of the current control program, authority, and technology development. For example, existing regulations and new proposed regulations for passenger cars provide 93 percent of the overall reductions for the light-duty sector in the SIP Strategy. For trucks, current and proposed regulations provide 88 percent of the overall reductions in the strategy. Overall, approximately 70 percent of the total mobile source reductions come from regulations. Similarly, almost 60 percent of the District’s 2031 NOx reductions come from regulatory actions.
The remaining increment of reductions will be achieved through a suite of actions. These actions reflect the importance of a variety of tools and approaches to achieve emission reductions. Building from the core regulatory efforts, implementing the complementary actions to support this transformation will include: 1) efforts to enhance the penetration of cleaner technologies through incentive programs and other funding mechanisms; 2) advocacy for further federal actions; 3) further regulatory development as new technologies emerge; 4) quantification of the benefits of increased system efficiencies, utilization of intelligent transportation systems and emerging autonomous and connected vehicle technologies; and 5) other innovative efforts to incentivize the demand for cleaner technologies.
Funding to support incentive-based programs and other innovative mechanisms will be an essential element of the attainment strategy in the South Coast. This will be especially important for achieving significant penetration of the cleanest technologies over the next five to ten years. Current incentive programs have been an important part of a portfolio to accelerate the penetration of cleaner technologies. However, funding levels beyond what is available through current programs will be needed. ARB has worked with the South Coast on defining funding needs and mechanisms for implementing the State SIP Strategy. ARB and South Coast staff has estimated that sustained funding levels of approximately $1 billion per year through 2031 will be needed to support the necessary scale of technology transformation. This represents the upper limit on funding needs. Emission reductions achieved through system efficiencies, additional regulatory efforts, and co-benefits from climate program initiatives would reduce the overall funding needed.
The South Coast has recently released a Draft Financial Incentives Funding Action Plan (Funding Action Plan)13 which describes existing sources of funding, new funding opportunities, activities that will be undertaken to pursue each potential funding mechanism, as well as a schedule and reporting process. As part of this effort, the South Coast has identified a broad spectrum of potential funding mechanisms that could meet the region’s funding needs. The scope of funding sources reflects the important
13 http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-plans/2016-air-quality-management-plan/draftfinancialincentivefunddec2016.pdf?sfvrsn=6
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role that all levels of government must play in bringing healthy air to the South Coast region. Targeted funding in disadvantaged communities can also provide significant benefits for residents who are disproportionately impacted by multiple emission sources by reducing both criteria pollutants and toxic air contaminants. An enhanced focus on investments in these communities will be an important element of the implementation of the funding plan.
Given the $100 million per year the South Coast currently receives, an expansion of current programs, coupled with a number of the new initiatives identified above would provide an effective framework for achieving the necessary funding stream. While no single funding source or government entity can fulfill the South Coast region’s funding needs, in combination the broad spectrum of mechanisms and approaches described above have the potential to provide over $2.3 billion per year to the South Coast if currently quantified opportunities are realized, exceeding the $1 billion per year necessary to meet the region’s attainment needs.
Beyond individual funding mechanisms, there are multiple State level programs and legislative mandates that are facilitating the overall transformation to cleaner, more efficient technologies in California. These programs are designed to provide an overall framework to support needed technology development and infrastructure, increase consumer awareness and outreach, and provide for focused investments in individual communities. These efforts also help meet the State’s transportation electrification goals under SB 350 through pursuit of transformational programs that can catalyze widespread transportation electrification.
The South Coast is also establishing a stakeholder working group to help further develop and implement the Funding Action Plan. ARB will continue to collaborate with the South Coast on the Funding Action Plan, as well as play a key role in implementing State level efforts that are facilitating the transition to cleaner technologies such as the California Sustainable Freight Action Plan, the ZEV Action Plan and the Transformative Climate Communities program. ARB, along with other public and private partners, also continue to sponsor research and demonstration programs to further promote advanced technology development. This will occur through ARB’s annual research program, grant programs, and other cooperative agreements. Additional strategies that target mechanisms for increasing consumer demand for cleaner technologies also offer promise.
As part of ongoing implementation of the AQMP, both ARB and the South Coast commit to monitoring progress in obtaining funding and in quantifying the benefits of reductions from mechanisms such as system efficiencies, advanced transportation systems, and other complementary programs including the California Sustainable Freight Action Plan, the 2030 Target Scoping Plan Update, and the SB 375 target setting process. As noted earlier, ARB’s overall commitment is to achieve the aggregate emission reductions necessary to attain the federal air quality standards, reflecting the combined reductions from the existing control strategy and new measures. Based on a continuing assessment of progress, ARB will identify, as necessary, appropriate regulatory
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mechanisms to achieve any shortfall in reductions. These regulatory mechanisms could include fleet rules to require enhanced deployment of cleaner technologies, expanded purchase requirements for zero emission technologies, and establishment of more stringent engine standards for additional vehicle and equipment types.
As part of ARB’s efforts to implement the further deployment measures, ARB commits to report back to the Board within one year of adoption of the State SIP Strategy, and yearly thereafter. This report will include:
1. The status of partnerships with the South Coast, San Joaquin Valley, U.S. EPA, other government agencies, and the private sector to pursue research, demonstration, and pilot projects for further advancement of zero and near-zero emission technologies;
2. The status of the Financial Incentives Funding Action Plan, progress in identifying and implementing funding mechanisms, and status of State level incentive programs and allocation of funding to the South Coast and San Joaquin Valley regions;
3. The status of technology assessments, emerging technologies and emission reduction opportunities. ARB staff will also report on implementation of actions identified by the South Coast and San Joaquin Valley as well as actions contained in the California Sustainable Freight Action Plan, the 2030 Target Scoping Plan Update, SB 375, and other complementary efforts and the criteria pollutant benefits that result from these actions; and,
4. Recommendations on the development of further regulatory measures and schedules for their development for inclusion in the SIP.
ARB staff will also provide periodic reports to U.S. EPA on the progress in developing and implementing the further deployment measures. This process will also include coordination with U.S. EPA to develop the programmatic structure for use of incentive-based measures in the SIP to satisfy Clean Air Act requirements. These include:
• demonstration that the incentive program reductions are quantifiable, enforceable, permanent, and surplus,
• provisions for an enforceable commitment, • technical analyses and supporting documentation, • demonstration of funding and legal authority, • procedures for public disclosure of information, and • provisions to measure and track program results.
At the District level, South Coast staff will assess progress in identifying actions to achieve emission reductions at the local level for ports, rail yards, and warehouses, as well as progress in identifying and obtaining funding and report to the Governing Board on a routine basis. If progress is not made in identifying specific actions within one year
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from adoption of the final 2016 AQMP, South Coast staff will recommend whether the Governing Board should consider proceeding with the development of rules within its existing legal authority or seek additional authority to adopt and implement measures to cost-effectively reduce mobile source emissions. Such authority includes development of new or expanded clean vehicle fleet rules or indirect source regulations.
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VI. ADDITIONAL CLEAN AIR ACT REQUIREMENTS
The 2016 AQMP addresses other Act requirements for ozone and PM2.5 nonattainment areas. These include additional requirements to support attainment demonstrations, verify that transportation and other projects don’t exceed attainment level emissions, and ensure that rules meet required control levels. For ozone, the requirements are published in U.S. EPA’s 2015 Implementation Rule for the 2008 8-hour ozone standard (Ozone Implementation Rule)14, and for PM2.5, U.S. EPA’s 2016 Fine Particulate Matter National Ambient Air Quality Standard State Implementation Plan Requirements Rule (PM2.5 implementation Rule)15. Chapter 6 of the AQMP provides a list of the Act requirements. An overview of how these requirements are met in the 2016 AQMP is provided below.
A. Emission Inventory
An emission inventory consists of a systematic listing of sources of air pollutants with an estimate of the amount of pollutant emissions from each source category over a period of time. District and ARB staff worked jointly to prepare the updated emission inventories for the 2016 AQMP. The inventories include a category-by-category review and update using the most recent information available on emissions-generating activities and anticipated population and economic growth in the region.
California’s updates to support current SIPs use a 2012 baseline inventory; the inventory reflects 2012 emissions and activity levels, and inventories for other years are back-cast or forecast from the base inventory. The inventories reflect District rules submitted through November 2016.
On-road motor vehicle emissions were generated using ARB’s mobile source emissions model. EMFAC2014. Off-road mobile source emissions were generated using ARB’s OFFROAD model. Both models were developed for use in the 2016 SIP revisions, and represent significant improvements over models used in prior SIP updates.
For the 2016 AQMP, two inventories were developed, a summer inventory and an annual average inventory. The summer planning inventory was developed for NOx and ROG sources to capture emission levels during the high ozone season, while the annual average inventory captures emissions that led to high PM2.5 concentrations, directly emitted PM2.5, NOx, SOx, ROG and ammonia.
These inventories were used to perform ozone modeling and analysis, estimate the cost-effectiveness of ozone control measures, and to report emission reduction progress as required by the Act. Detailed information regarding the emissions inventory development and emissions by major source category in the base year and for future year baseline emissions can be found in Chapter 3 and Appendix III of the 2016 AQMP.
14 80 FR 12264 http://www.gpo.gov/fdsys/pkg/FR-2015-03-06/pdf/2015-04012.pdf 15 81 FR 58010 https://www.gpo.gov/fdsys/pkg/FR-2016-08-24/pdf/2016-18768.pdf
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B. Emission Statement Certification
The Act requires ozone nonattainment areas to have an Emission Statement program that mandates stationary sources with emissions over 25 tons per year of NOx or ROG report and certify the accuracy of NOx and ROG emissions annually. District Rule 301 requires emissions reporting from all sources with total emissions greater than or equal to 4 tons per year of ROG, NOx, PM2.5 and other air contaminants. Thus, Rule 301 requires more stringent reporting of ROG and NOx stationary source emissions than is required under the Act in Section 182(a)(3)(B). Further discussion can be found on pages 6-8 of the 2016 AQMP.
C. Reasonably Available Control Measures Demonstration (RACM)
The Act requires that ozone SIPs provide for the implementation of RACM as expeditiously as practicable to provide for attainment of the ozone standard. RACM must also include emission reductions from existing sources that may be obtained through the adoption, at a minimum, of reasonably available control technology (RACT). The U.S. EPA has interpreted RACM as those emission control measures that are technologically and economically feasible and when considered in aggregate, would advance the attainment date by at least one year. The 2016 AQMP contains a RACM analysis that concludes that the District’s rules and regulations were in general equivalent to, or more stringent than other districts’ rules and regulations. For regulations where improvements beyond RACM may be possible, the District commits to evaluate potential amendments. These analyses are further described in Appendix VI-A of the 2016 AQMP.
In November 2016, U.S. EPA proposed to partially disapprove the District’s Reasonably Available Control Technology (RACT) SIP due to concerns that prior amendments to the RECLAIM program adopted in 2005 and 2010 did not meet Act requirements for RACM/RACT. In addition, as required under State law, ARB staff also conducted an assessment of more recent amendments to the District’s RECLAIM program adopted in 2015 and 2016 with respect to meeting a more stringent level of control known as Best Available Retrofit Control Technology (Appendix A). While ARB staff concluded that the 2015/2016 amendments do not meet the BARCT requirements established under State law for criteria pollutant market based trading systems, the District is developing additional documentation that the 2015/2016 amendments achieve NOx reductions equivalent to RACM/RACT, which is a less stringent level of control than BARCT.
D. Best Available Control Measures Demonstration (BACM)
The Act also requires that Serious PM2.5 nonattainment areas demonstrate BACM, including best available control technology (BACT), for the control of direct PM2.5 and PM2.5 precursors. U.S. EPA defines a BACM-level of control as the maximum degree of emissions reductions achievable from a source or source category considering energy, economic and environmental impacts. BACM is more stringent than RACM. The 2016 AQMP contains a BACM/BACT analysis for identifying and selecting the
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control measures for the 2016 AQMP in compliance with the requirements of the Act, as well as the U.S. EPA’s policy and guidelines. These analyses are further described in Appendix VI-A of the 2016 AQMP.
As discussed above, the District is developing documentation demonstrating that the RECLAIM program amendments adopted in 2015 and 2016 meets the RACM/RACT requirements of the Act. However, BACM/BACT is a more stringent level of control. ARB staff believe the amendments to the new RECLAIM measure adopted at the March 3 Board meeting, which commits to a further 5 tpd of NOx reductions by 2025, and provides direction to transition the program to a command-and-control based regulation as soon as practicable, meets requirements for BACM/BACT within the timeframes specified within the Act.
E. Reasonable Further Progress (RFP) for Ozone
The purpose of the RFP demonstration for ozone is to ensure that a nonattainment area makes steady progress towards attainment. Per the Ozone Implementation Rule, the South Coast and Coachella Valley must demonstrate an average 18 percent reduction in ROG or NOx emissions individually or in combination for the first six years of the attainment planning period, and an average three percent per year reduction in emissions every three years thereafter until the attainment date. The RFP demonstration in Appendix VI-C of the 2016 AQMP shows that ROG and NOx emission reductions in the South Coast are more than sufficient to meet the required RFP in every milestone year for the 75 ppb 8-hour ozone standard. The emission reductions exceed those required for RFP, as the incremental reductions needed for attainment in an Extreme ozone nonattainment area are much larger than the minimum requirements for progress required under the Act. Similarly, Chapter 7 in the 2016 AQMP demonstrates that the Coachella Valley meets the RFP requirements for all milestone years for the 75 ppb 8-hour ozone standard.
F. Reasonable Further Progress for PM2.5
The purpose of the RFP demonstration for PM2.5 is also to ensure that a nonattainment area makes steady progress towards attainment. Unlike the ozone RFP rule, progress in reducing PM2.5 and precursor emissions must demonstrate that emission reductions are generally linear through the attainment year. Emission reductions required under an RFP plan for PM2.5 may be from either directly-emitted PM2.5 or an applicable precursor pollutant such as NOx or SOx. Milestones are to be achieved every three years from 2012 until the area demonstrates attainment. Baseline PM2.5 emissions project no shortfall for PM2.5 or precursors for each milestone year through the attainment year. Additional information on the RFP demonstration is provided in Appendix VI-C of the 2016 AQMP.
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G. Quantitative Milestones for PM2.5
As stated in the PM2.5 Implementation Rule, states are required to submit quantitative milestones that must be achieved 4.5 years from the date of designation and then every three years afterward. In the case of the 35 μg/m3 24-hour PM2.5 standard, the milestone years are 2017 and 2020. For the 12 μg/m3 annual PM2.5 standard, the 2016 AQMP must include quantitative milestones to be achieved 4.5 years after the date of designation, or 2019 and then every three years thereafter, in this case 2022 and 2025.
The PM2.5 Implementation Rule also requires that all Serious area attainment plans contain one additional quantitative milestone to be met in the three year period beyond the attainment date. As a result, the year 2022 was added as a milestone year for the 35 μg/m3 24-hour PM2.5 standard and the year 2028 is added as a milestone year for the 12 μg/m3 annual PM2.5 standard.
The 2016 AQMP includes a list of adopted rules and regulations for stationary and mobile sources that are scheduled to be implemented from 2012 and account for the emission reductions in the future milestone/attainment years needed for the PM2.5 standards. The reductions in the quantitative milestone years for the 24-hour standard can be found in Appendix VI, table VI-C-3 of the 2016 AQMP with a list of rules to provide those reductions in table VI-C-4. For the annual PM2.5 standard, Appendix VI, table VI-C-5 demonstrates the emission reductions for the annual PM2.5 milestone years from rules listed in Appendix VI, table VI-C-6. The corresponding information on the mobile source control measures can be found in Appendix VI-C-1.
H. Contingency Measures
The Clean Air Act requires contingency measures to provide additional emission reductions in the event a nonattainment area fails to achieve RFP targets or attain by the deadline (Clean Air Act, sections 172(c)(9), 182(c)(9).) A recent Ninth Circuit decision, Bahr v. U.S. Environmental Protection Agency, (9th Cir. 2016) 836 F.3d 1218, found that U.S. EPA approval of certain types of contingency measures in an Arizona PM10 SIP were not consistent with the Act’s contingency requirements.
ARB staff expects that U.S. EPA will revise its guidance on contingency requirements in light of the Bahr decision. The contingency measures described below meet U.S. EPA’s existing guidance. ARB staff will work with the District and the U.S. EPA to provide any additional documentation or develop any needed SIP revisions to support U.S. EPA approval of the 2016 AQMP.
1. RFP Contingency Measure for Ozone in the South Coast
RFP contingency reductions are in addition to RFP, since they must be beyond those accounted for in the RFP demonstration. RFP contingency requires an extra one year, or three percent in emission reductions to cover any shortfall. The RFP demonstration
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in the 2016 AQMP shows that both the South Coast and Coachella Valley meet the three percent RFP contingency by the first milestone year (2018) and that the three percent is carried through to the attainment year. A demonstration that the District meets the RFP contingency requirement can be found in Appendix VI-C.
2. Attainment Contingency Measures for Ozone in South Coast
Contingency measures must be included in the 2016 AQMP to provide additional emission reductions in the event a nonattainment area fails to attain the ozone standard by its attainment date. These reductions must be beyond those accounted in attainment demonstrations.
While attainment contingency measures are appropriate for areas that can develop measures that will produce additional reductions beyond those needed to show attainment in the SIP, Extreme areas such as the South Coast, by law, are not able to hold back any possible measures to be used for contingency. In the Ozone Implementation Rule, U.S. EPA provides that “Extreme” areas with approved section 182(e)(5) commitments only need to submit contingency measures three years before the attainment date or 2028, and not the general Act contingency measures.
3. Attainment Contingency Measures for Ozone in Coachella Valley
In the Coachella Valley, reductions needed for attainment contingency is met by additional baseline reductions occurring between 2026 and 2027 from continued implementation of the mobile source control program. Under existing guidance, U.S. EPA has allowed states to use excess reductions from already adopted measures to meet the attainment contingency requirement.16 Since existing mobile source control measures are projected to continue providing significant emission reductions for many years beyond the 2026 attainment year as newer vehicles enter the fleet due to continued implementation of the mobile source programs, continuing emission reductions from those existing mobile source control measures fulfill the attainment contingency measures requirement. These measures will continue to be implemented. Table 12 demonstrates that NOx reductions between 2026 and 2027 will be more than the three percent needed to demonstrate attainment contingency. Attainment contingency reductions were not included in the 2016 AQMP. ARB will be releasing a separate notice for these reductions, which will be considered at the April ARB Board meeting.
Table 12: Attainment Contingency in the Coachella Valley (tpd)
2026 3 Percent Target 2027 2026 to 2027
reductions Is Attainment
Contingency Met? NOx inventory (tpd) 9.13 0.27 8.84 0.29 Yes
16 https://www.regulations.gov/document?D=EPA-R09-OAR-2014-0178-0185
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4. Contingency Measures for PM2.5 in South Coast
The Act requires that PM2.5 SIPs contain contingency measures for both RFP and attainment. For areas that demonstrate impracticability to attain the standard by the Moderate area attainment deadline, contingency measures are only required in the event a nonattainment area fails to achieve RFP targets. Contingency measures must represent additional reductions not accounted for in setting RFP levels. U.S. EPA has interpreted the contingency requirement to represent one year’s worth of emission reductions needed toward attainment. These measures must already be in place and take effect without further rulemaking action prior to the RFP milestone or attainment deadline. The District identified control measures that will be in place and serve as contingency for PM2.5.
I. Weight of Evidence
U.S. EPA modeling guidance requires that the modeled attainment demonstration be accompanied by a weight of evidence analysis (WOE) to provide a set of complementary analyses. Examining an air quality problem in a variety of ways provides a more informed basis for the attainment strategy as well as a better understanding of the overall problem and the level and mix of emissions controls needed for attainment. ARB staff prepared a WOE for both the South Coast (Appendix B) and Coachella Valley (Appendix C) to support the modeled ozone attainment demonstrations. In addition, a WOE is included to support the modeled PM2.5 attainment demonstrations for the South Coast (Appendix D).
The ozone WOE analysis includes an assessment of trends in ozone air quality, ozone precursor concentrations, and ozone precursor emissions; meteorology impacts on ozone air quality trends; and a summary of corroborating analyses. Similarly, the PM2.5 WOE includes supportive analysis showing attainment of these standards by their attainment date. The WOE analysis draws on the wealth of data collected in the South Coast and Coachella Valley from both routine air quality, metrology and emission networks and special region specific studies.
J. Transportation Conformity Budgets
Under Section 176(c) of the Act, transportation plans, programs, and projects that receive federal funding or approval must be fully consistent with the SIP before being approved by a Metropolitan Planning Organization (MPO), the Southern California Association of Governments in the case of the AQMP. U.S. EPA’s transportation conformity rule17 details requirements for establishing motor vehicle emission budgets (budgets) in SIPs for the purpose of ensuring the conformity of transportation plans and programs with the SIP.
17 Federal transportation conformity regulations, 40 CFR Part 51, subpart T. Funded or Approved Under Title 23 U.S.C. of the Federal Transit Laws, Part 93, subpart A, August 15, 1997.
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The 2016 AQMP establishes on-road motor vehicle emission budgets in the South Coast and Coachella Valley for each ozone RFP milestone year, as well as for the attainment years. The AQMP also establishes conformity budgets and emissions trading mechanisms for both the annual and 24 hour PM2.5 nonattainment areas in the South Coast. Altogether, the years that require transportation budgets in the South Coast are 2019, 2022, 2025 and 2028 for the PM2.5 standards, and 2018, 2021, 2024, 2027, 2030 and 2031 for the ozone standards. In the Coachella Valley, transportation budgets are needed for 2018, 2021, 2024 and 2026.
Emission budgets for the ozone years were calculated using EMFAC2014 for NOx and ROG summer average emissions. For PM2.5, emission budgets were calculated for NOx, ROG, and direct PM2.5 annual average emissions. The emission budgets established in the 2016 AQMP fulfill the requirements of the Act and U.S. EPA regulations to ensure that transportation projects will not interfere with progress and attainment of the annual PM2.5 standard. Additional detail on the on-road motor vehicle emission budgets can be found in Appendix VI-D of the 2016 AQMP.
K. Vehicle Miles Traveled (VMT) Offset Demonstration
Section 182(d)(1)(A) of the Act requires that SIPs for Severe and Extreme ozone nonattainment areas include a demonstration that identifies specific enforceable transportation control strategies and transportation control measures to offset any growth in vehicle miles travelled or number of vehicle trips.
The 2016 AQMP includes a VMT offset demonstration and analysis prepared pursuant to the requirements of the Act and is consistent with August 2012 U.S. EPA guidance entitled “Implementing Act section 182(d)(1)(A): Transportation Control Measures and Transportation Control Strategies to Offset Growth in Emissions Due to Growth in Vehicle Miles Traveled.” The 2016 AQMP demonstrates that the VMT offset demonstration is satisfied for the South Coast and Coachella Valley is described further in Appendix VI-E of the 2016 AQMP.
L. New Source Review The District’s Regulation XII-New Source Review, complies with ozone non-attainment requirements. With the amendment of District Rule 1325 on November 4, 2016, the Regulation also meets PM2.5 nonattainment requirements as it includes ROG and ammonia as PM2.5 precursors and incorporates changes to the major source threshold for Serious nonattainment areas. Further details are provided in Appendix VI-G of the 2016 AQMP.
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VII. Environmental Impacts
The District found that the 2016 AQMP will result in potentially significant adverse effects on the environment and therefore prepared an Environmental Impact Report (EIR) in accordance with the California Environmental Quality Act (CEQA). The EIR found no significant impacts to agriculture and forestry resources, biological resources, cultural resources, geology and soils, land use and planning, mineral resources, population and housing, public services and recreation. The EIR determined that the 2016 AQMP will result in potentially significant and unavoidable impacts to aesthetics, air quality and greenhouse gas emissions, energy, hazards and hazardous materials, hydrology and water quality, noise, solid and hazardous waste, and transportation and traffic. For more detailed information regarding this analysis please refer to the South Coast Air Quality Management District Draft Program Environmental Impact Report for the 2016 Air Quality Management Plan 18.
ARB has determined that its review and approval of the 2016 AQMP does not alter the District’s determinations in its EIR. Generally, ARB considers its review and approval of district plans for inclusion in the California SIP as a ministerial activity by ARB for purposes of CEQA.19 A “ministerial” decision is one that involves fixed standards or objective measurements where the agency has no discretion to shape the activity in response to environmental concerns.20 ARB’s review is limited to determining if the AQMP meets the requirements of the Act, and is prohibited from approving it or changing it unless ARB finds that it does not comply with the Act.21 ARB lacks authority to modify or not approve the AQMP in response to environmental concerns. Since ARB lacks authority to not approve the plan, or modify it, in response to environmental concerns raised through the CEQA process, ARB’s action on the plan is ministerial for purposes of CEQA.
18 http://www.aqmd.gov/docs/default-source/ceqa/documents/aqmd-projects/2016/2016-aqmp-draft-program-eir-combined.pdf?sfvrsn=219 Cal. Code Regs., tit. 14, § 15268. 20 Cal. Code Regs., tit. 14, § 15369; San Diego Navy Broadway Complex Coalition v. City of San Diego (2010) 185 Cal.App.4th 924, 934.21 Health and Safety Code, §§ 41650 and 41652.
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VIII. STAFF RECOMMENDATION
ARB staff recommends that the Board:
1. Adopt the portions of the South Coast Air District 2016 AQMP that address the ozone and PM2.5 requirements in the Clean Air Act, including the emission inventories, attainment demonstrations, reclassification to Serious for the 12 µg/m3 annual PM2.5 standard, proposed measures, RACM demonstration, BACM demonstration, RFP demonstration, Quantitative Milestone requirements, Impracticability demonstration, PM2.5 precursor requirement, contingency measures, transportation conformity budgets, and VMT offset demonstration, as a revision to the California SIP.
2. Direct the Executive Officer to submit the South Coast Air District 2016 AQMP and ARB staff report, in conjunction with the ARB 2016 State SIP Strategy to U.S. EPA for approval.
3. Direct ARB staff to work with the District and U.S. EPA to provide any additional information needed for U.S. EPA to approve the South Coast Air District 2016 AQMP as an amendment to the SIP.
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