This memorandum was prepared for the
Manufacturers Council of the Central Valley
Coleman
& Horowitt, LLP
Attorneys
at Law
The
following are the items that were identified that may be of interest to the
MCCV Working Groups with respect to Air Quality Issues.
1. AB
617
AB 617 is the statute that was passed last year along with the
revisions to the Cap & Trade and emphasizes enhanced source monitoring in
certain identified communities. With respect to the Valley, South Fresno and
Shafter have been identified.
2.
Community
Steering Committee Applications
The SJVAPCD is considering hiring third party Service
Providers to assist in developing the steering committees for the communities
identified in the initial round. This is an exerpt of the related staff report:
To ensure that this new and extensive community engagement
process is successful and meets your Board’s expectations, the use of services
to assist the District may be necessary. Given the short timeframe under state
law, District staff is seeking your Board’s approval to contract with
experienced service providers to assist in the facilitation of these steering
committees and with community outreach and participation.
3. CARB
October Board Meeting- October 25-26, 2018
In particular the cap and trade program is being considered,
this is from a letter that was circulated to the business community urging
participation at the CARB meeting and sign on to a group letter.
Last year, the California
Legislature passed legislation (known as AB 398) to renew the state’s
cap-and-trade program. The goal is to reduce carbon emissions, while also
containing costs for California families. The California Air Resources Board
(CARB) will be implementing the policy. To be sure that CARB follows the
legislation passed, they are to “avoid adverse impacts on resident households,
businesses, and the state’s economy.” There is an indication that CARB is
ignoring this direction and proposing to increase the costs that will impact
the economy. There is an effort by industry to get people to this meeting and
sign on to the following:
California Air Resources Board
10001 I Street
Sacramento, CA 95814
Dear Board Members,
As a group of concerned
businesses and consumers in California, we are united in strongly opposing
specific provisions of the proposed amendments to the regulation for
administering Cap-and-Trade for the period of 2020 to 2030. Specifically, we
believe the proposed Price Ceiling would fail entirely at its statutory purpose
of controlling costs that are placed on households, businesses, and the overall
economy.
Assembly Bill 398 (Garcia,
2017) directs the California Air Resources Board (CARB) to include a Price
Ceiling in the proposed regulation to control the prices of allowances. When
setting the Price Ceiling, the legislation specifically directs CARB to “avoid
adverse impacts on resident households, businesses, and the state’s economy.”
This important and straightforward direction reflects a widespread and
bipartisan recognition that the costs of climate regulations must be managed in
order for the regulations to be successful and avoid driving California
consumers, workers, and businesses into insolvency.
Unfortunately, CARB is
proposing to set a Price Ceiling that is nearly twice as high as experts
recommend. This proposal threatens to impose unaffordable, runaway costs on all
Californians, and violates the legislative directions to “avoid adverse
impacts.” This includes adding up to $1.08 to the cost of a gallon of gasoline,
as well as potential cost increases on energy, food, and other necessities.
These cost increases will
dramatically impact California consumers, workers, and businesses, who already
contend with some of the highest costs of living in our nation.
For these reasons, we are in
strong opposition to the lack of proper price-containment provisions in the
proposed amendments. We ask CARB to consider an approach to cost-containment
that is more aligned with the Legislature’s direction in AB 398.
Thank you for your
consideration.
4. SJVAPCD
October Board Meeting- October 18, 2018
5.
CAC
Meeting
A. PM
2.5 Plan
i.
District’s Summary
Update on District PM2.5 Planning Efforts – Sheraz Gill,
Deputy APCO, provided an update on the status of the District’s PM2.5 planning
efforts. For the past three years, the District and the California Air
Resources Board (CARB) have led an extensive public process to develop an
attainment strategy to address multiple federal PM2.5 standards. This public
process has included multiple workshops and public meetings, Public Advisory
Workgroup meetings, and regular discussions at Citizens’ Advisory Committee and
Environmental Justice Advisory Group meetings. Through the public engagement process,
the District and CARB have identified a comprehensive list of potential new regulatory
and incentive-based measures to achieve significant emissions reductions from
both stationary and mobile sources. Modeling conducted by CARB as part of the SJVUAPCD
Governing Board planning process demonstrates that the Valley will attain all
three PM2.5 standards by their respective deadlines. The District posted the
draft plan for public review on August 31, 2018. The District and CARB are
working to finalize the remaining elements of the plan prior to posting the
final draft of the plan for public comment ahead of the November 2018 Governing
Board meeting where the plan is scheduled to be considered for adoption.
ii.
Recommendations to the Board from Subcommittee
Due to the breadth and complexity of the plan, CAC members
felt additional time to review and analyze the plan was necessary prior to
making any recommendations to the Governing Board. To allow for this time, the
CAC voted to convene a meeting of the full committee on November 6, 2018, to
consider adopting recommendations for the Governing Board on the District’s
2018 PM2.5 Plan. To facilitate an enhanced review of the plan, CAC members
voted to create an ad hoc subcommittee which will meet in October 2018 to
review the plan further and report back to the CAC at the November 2018.
6 Additional Issues of Interest
A. Dairy
Sustainability Summit
Showcase California’s world-leading achievements in
sustainable dairy farm practices and the role dairy plays in the global food
system Explore new ways for dairy farmers to continue improving environmental
sustainability, develop new business opportunities, and reduce on-farm costs Highlight
information, technology, and services that can support dairy farmers’ efforts
to meet continuing challenges, further improve efficiency, and ensure economic
and environmental sustainability. https://www.cadairysummit.com/.
B. SNAPS
Excerpts from an Industry
Email, this may be a foreshadowing of the AB 617 program.
The California Air Resources Board (CARB)
is developing a project to better characterize air quality in communities near
oil and gas operations. The Study of Neighborhood Air near Petroleum Sources
(SNAPS) includes limited-term, intensive air quality monitoring with a particular
focus on production facilities. This project can also provide valuable
information to support the Community Air Protection Program (CAPP), formed
pursuant to AB 617.
Under SNAPS, candidate communities for
monitoring are identified based on their proximity to oil and gas wells, and
from public suggestions. CARB staff will locate stationary trailers equipped
with state-of-the art monitoring technologies in communities for up to four
months to determine air quality. The trailers are capable of measuring toxic
air contaminants (TACs), volatile organic compounds (VOCs), particulate matter
(PM), metals, and criteria pollutants. An analysis of available air pollution
measurements, local characteristics, public input, and potential partnerships
in each candidate community will help to prioritize trailer deployment. Staff
will analyze the air quality measurements obtained through trailer monitoring
to characterize exposures to measured pollutants. Where appropriate, the Office
of Environmental Health Hazard Assessment (OEHHA) will perform a more in-depth
health analysis, potentially including risk assessment. Some air monitoring
data will be posted in real-time and CARB will publish a complete analysis of
results in separate reports for each site.
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