BOARD MEETING DATE: July 11, 2003
AGENDA NO. 26

Mobile Source Committee

SYNOPSIS:

The Mobile Source Committee met Friday, June 27, 2003. Following is a summary of that meeting.

RECOMMENDED ACTION:

Receive and file.

S. Roy Wilson, Ed.D., Chair
Mobile Source Committee

Attendance

The meeting started at 9:05 a.m. Present: Committee Chair Roy Wilson, Committee Vice Chair Jane Carney, and Committee Members Fred Aguiar, William Craycraft, and Jim Silva. Absent: Committee Member Ron Loveridge.

INFORMATION ITEMS

1)	Recommendation to Implement FY 2002-03 Environmental Justice Enhancement I-4 – Continue to Develop Localized Significance Thresholds for Subregions of Air District as Another Indicator of CEQA Significance Dr. Steve Smith, Program Supervisor of the AQMD’s CEQA section, gave the presentation on the staff proposal. Dr. Smith discussed the background regarding development of the Localized Significance Thresholds (LSTs); the concept was originally developed as part of a previous stakeholder working group created to advise the AQMD on revisions to the AQMD’s CEQA Air Quality Handbook (Handbook). The LSTs, provide an additional indicator of air quality significance for a CEQA analysis, are an alternative to project-specific micro scale modeling, and require fewer resources to use. Dr. Smith briefly summarized the methodology used to develop the LSTs and the positive and negative aspects of using LSTs compared to performing project-specific micro scale modeling. The presentation concluded with identifying stakeholder comments/issues and staff’s responses to these issues. Public comments were received on this item. Jeb Stuart, representing the Construction Industry Air Quality Coalition (CIAQC), presented CIAQC’s comments via the telephone. He commented that AQMD staff is rushing the LST Methodology to the Board, and that implementation of the LSTs should be delayed until updated mitigation measures are available. Staff responded that the Handbook contains mitigation measures with quantifiable control values that can be applied to projects. Lead agencies have the authority to develop their own mitigation measures and quantifiable control values. The LST Methodology will not impinge on this authority. In addition, AQMD staff will continue to assist lead agencies to find and quantify mitigation measures on a project by project basis. Jeb Stuart also indicated that the LSTs may not be applicable to linear projects such as pipeline projects. Staff responded that linear projects such as pipelines generally consist of project areas that exceed five acres so the LST lookup tables would not be applicable. Staff suggests that large projects complete air dispersion modeling to estimate localized impacts. If pipeline projects are constructed in phases, the LST lookup tables may be applicable to these smaller phased projects. Staff is available to assist linear projects with estimating localized significant analysis and mitigation, if needed. Todd Campbell of Coalition for Clean Air, commented that the LST Methodology provides guidance. Whether or not lead agencies use this guidance or develop their own, the LST Methodology provides the ability to quantify these impacts. The LSTs provide a tool for analysis that is needed.
2)	Recommendation to Implement FY 2002-03 Environmental Justice Enhancement III-2 – Develop Expedited CEQA Analysis Process for Any Major Project Which Contains Commitments and Milestone Schedules for Implementation of "Super Clean Air Actions" and Amend AQMD’s Green Carpet Program Dr. Steve Smith, Program Supervisor of the AQMD’s CEQA section, gave the presentation on the staff proposal. The staff recommendation for implementing this EJ enhancement is to remove it from the CEQA context and, instead, link it to an existing AQMD program, the AQMD’s "Green Carpet" Priority Permitting Service for projects that meet one of four specified criteria. A project would qualify for access to the Green Carpet Program if the project applicant implements a clean air technology project as defined by the AQMD within five miles of the project site. Instead of calling the clean air technology project "super mitigation," it would be called "super clean air action." Super clean air actions consist of a list of clean technologies established by the AQMD, including fuel cells, alternative clean fuel engines with oxidation catalysts, etc. In addition, to qualify for the Green Carpet Program, the project would have to meet additional criteria such as the AQMD must be lead agency under CEQA, the project cannot be required by law for a period of at least three years, etc. Finally, the project applicant must contribute funding toward the super clean air action in an amount equal to or greater than one percent of the total capital cost of the proposed project.
3)	Report on the 2003 AQMP Measures Proposed by the Environmental Community Dr. Laki Tisopulos, Assistant Deputy Executive Officer, Planning, Rule Development and Area Sources, provided a report on the 2003 AQMP measures proposed by the environmental community. The NRDC and Coalition for Clean air submitted a letter to the AQMD on May 1, 2003 recommending a list of control measures for reducing the size of the "black box". Seven of the measures dealt with reducing emissions from the Ports. Emissions from ports and related operations represent a significant portion of the Basin’s emissions. These measures included the requirement for cold ironing during ship hotelling, fleet rule for yard tractors, diesel truck retrofits, electrification of cranes, use of low-sulfur fuel for ocean-going ships, cleaner switcher locomotives at rail yards, and a port "bubble" concept. Many of the port strategies have already been incorporated into the 2003 AQMP either as short-term measures or long-term strategies. For instance, cold ironing and low-sulfur fuel for ships are included as long-term strategies for U.S. EPA’s consideration, while the emissions from diesel trucks and trains, are being addressed by AQMD Control Measures FSS-05, FSS-06, and FSS-07. In addition, Proposed Rule 1198 – Intermodal Equipment is currently being developed to reduce the emissions from yard tractors at the Ports. The proposed port "bubble" concept needs to be further evaluated in order to resolve issues related to the extent of the AQMD’s legal authority, establishing baselines/reduction targets, and the Port’s authority over its tenants. Staff was asked to clarify the extent of the AQMD’s legal authority to regulate port-related sources such as ships to which staff responded that the AQMD is generally pre-empted from regulating sources that are under federal and state jurisdiction (e.g., ships, trains, and off-road equipment). The environmental community proposed additional measures for on-road and off-road mobile sources such as applying the feet rules to private fleets, mandatory retrofit requirements, an airport "bubble" rule and a CARB early vehicle retirement program. A statewide measure is proposed by CARB (i.e., ON-RD HVY-DUTY-3) which is applicable to on-road heavy-duty trucks and busses and would require emission reductions from existing and new truck/bus fleets. The application of the AQMD’s fleet rules to private fleets requires further evaluation by staff and additional Board direction may be needed to further pursue this measure. As with the port "bubble" concept, an airport "bubble" rule would require further evaluation to resolve similar issues. Two stationary source control strategies proposed by the environmental community include seeking further NOx emission reductions from RECLAIM sources and additional reductions from the coatings and solvent categories. AQMD staff will evaluate whether additional NOx emission reductions are feasible during rule development of the Control Measure CMB-10 of the 2003 AQMP. Additional reductions from coating and solvents may be possible through implementation of Control Measure CTS-10 and staff will further evaluate this during rule development. Finally, the environmental community recommended that the AQMD seek regulatory authority to further regulate consumer products beyond what CARB currently proposes. Staff agrees with this approach, and implementation of such a measure would depend on the AQMD’s ability to obtain additional authority to regulate consumer products. Staff proposes that the control measures recommended by the environmental community be included as control measure concepts under the 2003 AQMP’s Long-Term Control Strategy, initiate work with the stakeholders and seek resolution of the technical, legal authority, and funding/cost issues; implement the concepts as these issues are resolved as part of the future rulemaking. Staff was also asked to clarify the implementation process for long-term strategies. Staff responded that implementation of these strategies will be done through individual rule development, and the credit for such rules will be requested through submittals to U.S. EPA as revisions to the SIP.
4)	Status Report on 2003 Air Quality Management Plan Dr. Elaine Chang, Deputy Executive Officer, Planning, Rule Development and Area Sources, presented an update on the proposed modifications to the draft 2003 AQMP. Staff has proposed modifications to the draft Plan primarily as a result of new emissions inventory data as well as information and comments received from the public. The proposed modifications revise the emissions inventory, control strategy, attainment demonstration, and the transportation conformity budgets. The net change in the summer planning inventory in 2010 is an additional 30 tons per day of VOC and 24 tons per day of NOx. The major inventory revisions include increased lawn and garden equipment emissions (from CARB) as well as other revisions due to updated emission factors, correction in calculations, and other technical corrections. While the revised control strategy is substantially the same, some of the control measures have been revised based on public comment. Also, CARB staff has moved the federal measures to long-term strategies, reduced their commitment relative to short-term control measures (to mid-point of reduction range rather than high-end), and removed the tiered long-term strategy in favor of a larger black box for which strategies and commitments have to be identified later. SCAG staff has also revised the Regional Transportation Strategy and Control Measures including updating the emission reductions projections, Transportation Control Measure identification / implementation, and Reasonably Available Control Measures analysis. The revised emission inventory and control strategy have only a slight effect on the attainment demonstration, and the modeling analysis still shows demonstration with the PM10 standard in 2006 and the ozone standard in 2010. Dr. Chang gave a brief summary of transportation conformity budgets, explaining that these emission budgets are established for milestone and attainment years and that attainment year budgets are applicable to future year conformity determinations. The transportation conformity budgets reflect existing control programs, short-term control measures and TCMs (i.e., no black box reductions). Staff has developed a transportation conformity backstop measure (TCB-01) in the event that additional emission reductions are needed. Dr. Chang also discussed the framework of a PM10 transportation conformity budget trading mechanism (as authorized by §93.124(c) of the federal conformity rule), which allows excess reductions of primary PM10 and precursors to be traded for travel-based direct PM10 increases in later year conformity analyses. Dr. Chang mentioned that U.S. EPA has recently expressed concern with the trading mechanism and an inter-agency conference call is scheduled for next week to discuss this issue. Dr. Chang concluded her presentation by informing the Committee that the regional public hearings will be held on July 21 and 23, 2003 and the adoption hearing will be held on August 1, 2003. Barbara Baird, District Counsel, highlighted two major policy issues for the Governing Board. Ms. Baird outlined the differences between two scenarios included in the proposed 2003 AQMP. Scenario 1, recommended by AQMD staff, sets reduction commitments by agency for long-term reductions based on the extent of agency contribution to emissions (i.e., approximately 30 tons per day VOC for AQMD and approximately 230 tons per day VOC and 110 tons per day of NOx for CARB). CARB prefers Scenario 2 which proposes a joint commitment for the grand total of the required long-term reductions. A conflict resolution process is available in the event that CARB adopts Scenario 2. The second policy issue of note is U.S. EPA’s assertion that the AQMD and the state cannot commit reduction obligations to the federal government. Consequently, the 2003 AQMP includes two attainment demonstration options relative to emissions associated with federal sources. Option 1 relies on the federal government to achieve 68 tons per day of NOx reductions whereas Option 2 excludes any reductions from federal sources. Option 2 would therefore add to the emission burden facing the AQMD when devising an attainment strategy for the PM2.5 and 8-hour ozone standards. Public comments were received on this item. Gretchen Hardison, representing the City of Los Angeles, stated that the Los Angeles City Council has established a position to support the 2003 AQMP, though the City wished to bring to the attention of the AQMD, CARB, and U.S. EPA the following key issues of concern: 1) economic impacts to ports and airports, 2) jurisdictional issues, 3) emission reduction commitments by state and federal governments, 4) cross-media and localized impacts, 5) extension of fleet rules to private fleets, 6) outreach during rule promulgation, and 7) equitable and cost-effective design of control strategy. Curt Coleman, representing the California Manufacturers Association, expressed support for AQMD staff’s recommendations relative to Option 1 (i.e., assign 68 tons per day to U.S. EPA) and Scenario 1 (i.e., agency commitments for specific long-term reductions). Todd Campbell, representing the Coalition for Clean Air, expressed concern with the minimal reduction commitments in the Plan, encouraged the development of suggested control concepts into defined control measures, stressed the need to address emissions from the ports, and generally believes that the AQMD has greater authority than assumed and should be more proactive in achieving reductions from a broad range of sources.
5)	2003 Coachella Valley PM10 State Implementation Plan Dr. Julia Lester, PM10 Program Supervisor, briefed the Committee on the draft 2003 Coachella Valley PM10 State Implementation Plan (CVSIP). When the Board approved the 2002 CVSIP in June of 2002, they directed staff to revise the emission inventories and transportation budgets when the latest CARB emission factors and other local planning assumptions were finalized and approved. In the 2003 CVSIP, staff has updated the emission inventories, modeling demonstrations, and transportation conformity emission budgets for Coachella Valley. The 2003 CVSIP includes a request to U.S. EPA to replace the previous conformity emission budgets as soon as they determine that the 2003 CVSIP budgets are adequate. This is necessary for SCAG’s upcoming conformity determinations.
6)	Rule 2202 Activity Report Rule 2202 Summary Status Report submitted, no comments.
7)	Monthly Report on Environmental Justice Initiatives Item #4 – CEQA Commenting: a. CEQA Document Commenting Update: Written report submitted, no comments.
8)	Other Business None.
9)	Public Comment None.

The meeting adjourned at 10:35 a.m.

Attachment

Attendance Roster
 

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
MOBILE SOURCE COMMITTEE

JUNE 27, 2003

ATTENDANCE ROSTER
 

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