Coleman & Horowitt LLP article on AB 617 was published in the Winter Issue of the Association of Environmental Professionals Environmental Monitor.
Showing posts with label Air Quality. Show all posts
Showing posts with label Air Quality. Show all posts
Friday, January 4, 2019
Thursday, December 6, 2018
EPA Issues Findings of Failure to Timely Submit Valley PM 2.5 Plan
The U.S. Environmental Protection Agency issued a Notice of Findings in
the Federal Register (62720 Federal Register / Vol. 83, No. 234 / Thursday,
December 6, 2018) on Thursday that the
PM 2.5 Attainment Plan for the Central Valley is overdue and that if it not
completed and incorporated into the State Implementation Plan within 18 months-sanctions
will be imposed that could impact Federal Highway Funds, Offsets and eventually
could require a Federal Implementation Program (“FIP”).
This Notice was issued despite the fact that the San Joaquin Valley Air
Pollution Control District working alongside the California Air Resources
Control Board has approved its PM 2.5 Plan, and it is pending before CARB for
approval.
CARB is scheduled to vote on the plan in January. Until
then, the EPA said, "the state shall be treated as not having made the
submission… "We note, however, that CARB's submission represents a
significant step in the state's and district's multiyear effort to address the
act's attainment planning requirements," the EPA said.
The section in the Federal Register regarding sanctions and
a portion of the relevant Clean Air Act Section is set out below:
II.
Consequences of Findings
of Failure
To
Submit Complete SIPs
Under section 110(k)(1)(C) of the
Act, here the EPA determines that a SIP submission (or part thereof) does not
meet the EPA’s minimum completeness
criteria established in 40 CFR part 51, appendix V, the state shall be treated
as not
having made the submission (or part thereof). Sections 179(a) and 110(c) of
the CAA establish specific
consequences for failure to submit complete SIP submissions or SIP
elements required under part D of
title I of the Act, including the eventual imposition of
mandatory sanctions in the affected
area.
In accordance with the EPA’s sanctions sequencing rule in 40 CFR 52.31, the offset sanction identified in CAA section 179(b)(2) would apply in the
San Joaquin Valley
area 18 months after the effective date of these findings,
if the EPA has not affirmatively
determined by that date that the State has submitted a complete
SIP addressing the deficiency that is the basis for these findings. If, within 6 months
after the offset
sanction applies, the EPA still has not affirmatively determined that the State has submitted a complete SIP addressing the deficiency that is the basis for the findings, the highway
funding sanction
identified in CAA section 179(b)(1) would also apply in the San Joaquin
Valley. Under 40 CFR 52.31(d)(5), neither sanction
would apply if the EPA determines within 18 months after the effective date of these findings that the
State has submitted a complete
SIP submission addressing the deficiency
that is the basis for these findings.
Additionally, a finding of failure to submit a complete SIP submission
triggers an obligation under CAA section 110(c) for the EPA to promulgate
a FIP no later than 2 years after
the finding, unless the state has submitted,
and the EPA has approved, the required SIP submittal. Thus, the EPA would be required to promulgate a PM2.5 FIP for the San Joaquin Valley,
in relevant part, if
California does not submit and the
EPA does not approve all of the necessary SIP submissions within
2 years after the effective date of these findings.
Clean Air Act
179(b)(2)
(b) Sanctions
The sanctions
available to the Administrator as provided in subsection (a) of this section
are as follows:
(1) Highway
sanctions
(A) The
Administrator may impose a prohibition, applicable to a nonattainment area, on
the approval by the Secretary of Transportation of any projects or the awarding
by the Secretary of any grants, under title 23 other than projects or grants
for safety where the Secretary determines, based on accident or other
appropriate data submitted by the State, that the principal purpose of the
project is an improvement in safety to resolve a demonstrated safety problem
and likely will result in a significant reduction in, or avoidance of, accidents.
Such prohibition shall become effective upon the selection by the Administrator
of this sanction.
(B) In addition
to safety, projects or grants that may be approved by the Secretary,
notwithstanding the prohibition in subparagraph (A), are the following—
(i) capital
programs for public transit;
(ii)
construction or restriction of certain roads or lanes solely for the use of
passenger buses or high occupancy vehicles;
(iii) planning
for requirements for employers to reduce employee work-trip-related vehicle
emissions;
(iv) highway
ramp metering, traffic signalization, and related programs that improve traffic
flow and achieve a net emission reduction;
(v) fringe and
transportation corridor parking facilities serving multiple occupancy vehicle
programs or transit operations;
(vi) programs to
limit or restrict vehicle use in downtown areas or other areas of emission
concentration particularly during periods of peak use, through road use
charges, tolls, parking surcharges, or other pricing mechanisms, vehicle
restricted zones or periods, or vehicle registration programs;
(vii) programs
for breakdown and accident scene management, nonrecurring congestion, and
vehicle information systems, to reduce congestion and emissions; and
(viii) such other transportation-related programs as the
Administrator, in consultation with the Secretary of Transportation, finds
would improve air quality and would not encourage single occupancy vehicle
capacity.
In considering
such measures, the State should seek to ensure adequate access to downtown,
other commercial, and residential areas, and avoid increasing or relocating
emissions and congestion rather than reducing them.
(2) Offsets
In applying the
emissions offset requirements of section 7503 of this title to new or modified
sources or emissions units for which a permit is required under this part, the
ratio of emission reductions to increased emissions shall be at least 2 to 1.
Thursday, October 18, 2018
Issues in Air Quality
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.
Tuesday, July 31, 2018
Comments on AB 617 Blueprint
Friday, June 22, 2018
AB 617: San Joaquin Valley APCD Identifies Fresno and Bakersfield Under Community Monitoring
As part of AB 617 the local air districts are to identify preliminary and final lists of recommended communities to CARB. The initial list of communities was identified in April, and a more refined list will be provided in July. The California Air Resources Board (CARB) will publish lists in August and finalize them in September.
The SJVAPCD in the preliminary round of identifying communities provided a laundry list of disadvantaged communities that are effected by the large transportation corridors located in the Valley. http://www.valleyair.org/community/documents/Initial-2018-Community-Recommendations.pdf In this next round the District has specifically identified South Central Fresno, and North Central Bakersfield.
AB 617 requires CARB to develop a
monitoring plan for the state, and then select, based on the plan, the highest
priority locations to deploy community air monitoring systems. Once the
communities and relevant emissions are identified, various options for control
measures are to be proposed.
By July 1, 2019, air districts would be required to
deploy monitoring systems in the selected locations, with data to be published
on the CARB website. Air districts would also be authorized to require any
stationary sources that emit air pollution that materially affect the selected
location, to deploy a fence-line monitoring system. Once the communities are identified an advisory committee working with the local district can identify control measures, enhanced enforcement, land use controls and other methods to reduce emissions affecting the community.
Additional locations would be selected to deploy community air monitoring systems on an ongoing basis by January 1, 2020, and every year thereafter as appropriate based on the monitoring plan.
. Additional locations would be selected to deploy community air monitoring systems on an ongoing basis by January 1, 2020, and every year thereafter as appropriate based on the monitoring plan.
Tuesday, March 20, 2018
AB 617 COMMUNITY AIR PROTECTION PROGRAM
AB 617 COMMUNITY AIR PROTECTION
PROGRAM
By Lee N. Smith
This memorandum addresses AB 617 Garcia (the Community
Air Protection Program), Chapter 136, Statutes of 2017. There is also a short discussion of the
recently released (2/7/2018) California Air Resources Board (“CARB”) “Concept
Paper” and the accompanying “Draft Process and Criteria for 2018 Community
Selections.”
I.
Summary
AB 617 was approved by the California legislature in
conjunction with AB 398, which was an extension of the Cap & Trade program,
in an effort to garner support from the diverse interested parties in the air
quality arena. It is a far-reaching bill
that is intended to identify populations/communities in California that are
being cumulatively impacted by local air quality, and requires that additional
monitoring or mitigation be taken. In
particular, it calls for the development of a plan for monitoring communities
that are cumulatively impacted. The
Concept Paper and the Draft Process and Criteria for Community Selection, which
are discussed at the end of this memorandum, contain proposed policies that
will directly impact local air districts.
One of the major concerns with AB 617 is the apparent
interest by some groups to use inexpensive monitoring devices that cannot
produce results that are likely to be sufficient to meet the technical and
evidentiary requirements under the state and federal clean air acts.
II.
Cap & Trade
AB 398
AB 398 authorizes
CARB to continue the GHG Cap & Trade program until 2030 and resolves
certain questions over the future of cap-and-trade while working to meet the
state’s target to cut GHG emissions to 40 percent below 1990 levels by
2030. Support by industry for the
additional cap-and-trade regulation was an apparent desire to avoid command and
control of greenhouse gas emissions as opposed to the economic incentives and
compliance alternatives under the existing Cap & Trade program.
III.
AB 617
A.
Summary
AB 617 requires CARB to develop a monitoring plan for
the state, and then select, based on the plan, the highest priority locations
to deploy community air monitoring systems.
Once the communities and relevant emissions are identified, various
options for control measures are to be proposed.
By July 1, 2019, air districts would be required to
deploy monitoring systems in the selected locations, with data to be published
on the CARB website.
Air districts would also be authorized to require any
stationary sources that emit air pollution that materially affect the selected
location, to deploy a fence-line monitoring system.
Additional locations would be selected to deploy
community air monitoring systems on an ongoing basis, by January 1, 2020, and
every year thereafter, as appropriate based on the monitoring plan.
The program also includes annual hearings to support
continual improvements in implementing the network of community air monitoring
systems.
Within one year, air districts that encompass
identified communities would need to adopt a community emissions reduction
program consistent with the state strategy and including emissions reduction
targets, specific cost-effective reduction measures, an implementation schedule
and enforcement plan. These programs
could include measures for reducing emissions from the contributing sources or
categories of sources, including, but not limited to, stationary and mobile sources.
Ensuring continuous progress towards fulfilling the
statewide strategy, every year CARB is required to select additional locations
with high cumulative exposures for participation in the program. The legislation further requires CARB to
update the state-wide strategy at least once every five years.
B.
Community
Participation
CARB is required to consult with environmental justice
organizations, affected industry and other stakeholders in preparing the
state-wide strategy, including holding at least three public workshops in
different parts of the state.[1]
Air districts must similarly consult with CARB,
individuals, community-based organizations, affected sources, and local
government in developing the community emissions reduction program. It is our understanding that initial
community identification will occur in April of 2018.
C. BARCT
AB 617 also requires air districts that are in
nonattainment to adopt an expedited schedule to implement Best Available
Retrofit Control Technology (“BARCT”) for existing sources of air
pollution that were covered by Cap & Trade - a market based control program
- as of January 1, 2017, and where such standards have not been updated within
the last decade. The law offers
compliance flexibility in how the standards are met.
AB 617 was intended to enhance consistency of
regulatory standards by requiring the state board to establish and maintain a
statewide clearinghouse for the technologies used across the state to
define the best available control technology (for new sources that emit
criteria air pollutants), BARCT, and for related technologies for the control
of toxic air contaminants.
D. Increased Enforcement
AB 617 also increases the maximum criminal and civil
penalties enforceable by the districts and CARB and requires affected air
districts to prepare annual reports describing actions taken and the results of
those actions.
IV.
Concept Paper
On February 7, 2018, CARB’s Office of Community Air
Protection released a draft Concept Paper[2]
which is the initial proposal for the framework of the Program that was
discussed at three full-day public workshops held throughout California in late
February. Comments received on the
Concept Paper will be used in the development of a draft version to be released
in May 2018. The following is a synopsis
of the 45-page report that addresses the more relevant sections.
A.
CARB
Identifies Responsibilities Under the Air Protection Program to Include:
• Identifying communities with the highest
cumulative exposure burdens and annually selecting priority communities for
deployment of community air monitoring campaigns and/or community emissions
reduction programs.
• Developing a
statewide strategy, including measures to reduce emissions and exposure,
methods for identifying contributing sources, and criteria to serve as the
benchmark that air districts must meet when developing and implementing
community emissions reduction programs.
• Preparing a
statewide air monitoring plan to provide criteria and guidance for
developing community air monitoring campaigns.
• Establishing and
maintaining an emissions control technology clearinghouse.
• Establishing a
statewide uniform system of annual emissions reporting for certain categories
of sources.
• Assessment and
identification of the most heavily burdened communities will be based on a
compilation of data sources and factors characterizing cumulative exposure to
criteria air pollutants and toxic air contaminants within disadvantaged
communities. These sources include:
• Information
about concentrations of criteria air pollutants and toxic air contaminants
from measurements, air quality modeling, or other information quantifying
exposure burden.
•
Identifying sensitive receptors
(e.g., schools, day care centers, hospitals), exposed population, and proximity
to mobile, area-wide, and stationary emissions sources of concern, including
freeways.
• Density of
contributing emissions sources and magnitude of emissions within the community.
•
Public health indicators
that are representative of the incidence and/or exacerbations of disease.
• Cancer risk
estimates based on air quality modeling.
• Socio-economic
factors such as poverty levels, unemployment rates, and linguistic
isolation.
B.
Air
District Responsibilities
CARB
is proposing that air districts provide recommendations as to specific
communities for deployment of community air monitoring campaigns and/or
development of community emissions reduction programs.
According
to CARB, the air districts are tasked with establishing the air monitoring
campaigns, as well as developing and implementing the community emissions
reduction programs because of their apparent expertise and experience.
CARB’s
plans include actions that are specific to air districts:
•
Adopt air district rules that
reflect the most stringent emissions limits, applicability, and best practices
and associated cost-effectiveness.
• Assume that air
district Best Available Control Technology (“BACT”) and T-BACT determinations
for new sources reflect the most stringent limits.
• New air district
rules and emissions limits to meet AB 617 requirements for the expedited
installation of BARCT.
Some
of the duties of the District are discussed in detail in the Process and
Criteria Draft which is discussed herein.
C.
Additional
Proposed Measures
In addition to District actions, CARB is suggesting:
• CARB-mandated
mobile source technology and fuel measures that will advance zero and near-zero
emissions technologies.
• Review and
potential revision of CARB airborne toxic control measures (ATCMs) and
suggested control measures for mobile, area-wide, and stationary sources.
• CARB and air
district incentive funding for mobile, area-wide, and stationary sources to
accelerate deployment of the cleanest technologies and associated
infrastructure, with a focus on zero-emissions technologies wherever feasible.
• Facility-based
approaches for reducing emissions.
• CARB and air
district mechanisms for targeted enforcement activities.
• Enforceable
agreements.
• Transportation-related
strategies to reduce community-level emissions impacts such as alternative
truck routes, preferential access for the cleanest technologies, and
geo-fencing.
• Strategies to
create more sustainable communities, including reducing vehicle miles
travelled, encouraging active transportation, and urban greening.
• Resources to
support education and community advocacy on land use planning and California
Environmental Quality Act (CEQA) review.
• Mitigation strategies such as air filtration,
buffers, and vegetation barriers.
In addition to the Concept Paper, the technical criteria,
requirements for public process, and timelines for the air district and
community, self-recommendations are available in the Process and Criteria for
2018 Community Selections.
V. The Community Air Protection Program
Process and Criteria
The
Community Air Protection Program DRAFT Process and Criteria for 2018 Community
Selections[3] were
drafted to help identify the criteria for identifying the communities that will
be addressed under their plan:
1)
Community Self-Identification -
There is a process for communities to essentially nominate themselves for
consideration. Such nominations are
submitted to the local Air Districts for review.
2)
There is also a section to assist
air districts in providing initial, and then final, recommendations for
identifying local target communities.
The Process and Criteria sets out numerous data resources that a District
should use in its review. Sources the districts are to review include:
a.
Information about concentrations of
criteria air pollutants and toxic air contaminants from measurements, air
quality modeling, or other information quantifying exposure burden.
b.
Sensitive receptors (e.g., schools,
day care centers, hospitals), exposed population, and proximity to mobile and
stationary emissions sources of concern, including freeways.
c.
Density of contributing emissions sources and
magnitude of emissions within the community, including mobile, area-wide, and
stationary sources.
d.
Public health indicators that are
representative of incidence or exacerbation of disease related to air quality.
e.
Cancer risk estimates based on air
quality modeling.
f.
Socio-economic factors such as
poverty levels, unemployment rates, and linguistic isolation.
3)
Air District initial submittals and
later final assessment are first due in April 2018, then the final in July of
2018. The Process and Criteria documents
contain a list of the information required to be in an air district’s
submittals. Additionally, there are
specific requirements for the public review process despite the short timeline
for review and implementation of the CARB plan.
VI.
Timeline
One
of the concerns with the Concept Plan and the Process and Criteria is the short
timeframe proposed per statutory requirements.
The timeline under the process identified in this document is as
follows:
February
2018: Draft Process and Criteria for 2018
Community Selections released.
April
30, 2018: Initial community list from air
districts submitted to CARB.
July
31, 2018: Final air district 2018 Community
Selections recommendations submitted to CARB.
August
2018: CARB posts recommended communities
with Community Air Protection Program
Framework
and planning documents for public comment.
September 2018: Board meeting to consider selection of 2018 communities.
Lee N.
Smith is a partner in the litigation department of the firm's Fresno and
Sacramento offices, and is heading the firm's Environmental and Agricultural
Law Department, where he provides representation to clients in the areas of
Environmental Law Compliance and Litigation, the California Environmental
Quality Act (CEQA), Land Use, Proposition 65, Water Law and Litigation in the
Central Valley. His experience includes air quality and hazardous
materials compliance, food safety, and water quality at both the federal and state
levels. He has handled cases involving
the EPA, Cal-EPA, the Central Valley Regional Water Quality Control Board, CalRecycle,
the San Joaquin Valley Air Pollution Control District and other environmental
agencies. He has also been involved in federal litigation involving the
Clean Water Act (CWA), the Clean Air Act (CAA), the Comprehensive Environmental
Response Compensation and Liability Act (CERCLA), and the Resource Conservation
and Recovery Act (RCRA) as well as state court litigation concerning pesticide
contamination, CEQA and Proposition 65.
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2017, Coleman & Horowitt, LLP
[1] 2/22 in Oakland, 2/27 in Bakersfield, 2/28 in
Riverside. https://ww2.arb.ca.gov/our-work/programs/community-air-protection-program-ab617/community-air-protection-program-events
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