HomeMy WebLinkAboutAQMP #31111111111111111111111111111111111111111111.111
*NEW FILE*
AQMP #3
.. a
aEW PO
. e
3 Iz Department
��cican''�r
of Community Development
1.
DATE: November 3, 1978
TO: Paul Ryckoff
FROM: Fred Talarico
SUBJECT: AQMP - Orange County Coordinating Committee meeting
of November 2, 1978.
In accordance with your request, I attended the November 2, 1978
AQMP - Orange County Coordinating Committee Meeting. Attached
for your review is a copy of the meeting agenda and information
distributed at the meeting.
1. Approval of minutes: The -approval of the minutes were
continued to the meeting of November 30, 1978.
2. Regional AQMP - Final Draft: The final draft of the AQMP
was reviewed by SCAG staff. Differences between the previous
draft and final draft were outlined.
3. Adjournment: The meeting was adjourned to Thursday, November
30, 1978 at 2:00 p.m., County Transportation Building.
General Information
A.) Public Hearing: AQMP - Final Draft
Time: 9:30 a.m. to 4;00 p.m.
Date: December 14, 1978
Place: Board Hearing Room
10 Civic Center Plaza
Santa Ana, CA
B.) Public Hearing: 208 Area Taste Treatment
Management Plan, SCAG-78 Growth
Forecast, and Amendments to Regional
Transportation Plan.
Time: 4:00 p.m. to 8:00 p.m.
Date: December 14, 1978
Place: Board Hearing Room
10 Civic Center Plaza
Santa Ana, CA
- 1 -
ci
0 0
TO: Paul Ryckoff - 2.
I have distributed copies of the summary AQMP
Environmental Quality Advisory Committee and
making recommendations to the City Council at
meeting. Additionally, I will be reviewing t
and giving you and CEQAG staff comments as so
Scott has agreed to give a short briefing to
of December 6th.
plan to the Citizens
they will review i-t,
their December 6, 1978
he AQMP - Final Draft
on as possible. Sandy
the CEQAC on the evening
It would probably bd appropriate to schedule City Council recommendations
on: 1.) AQMP - Final Draft; 2.) 208 Area Waste Treatment Plan; 3.)
SCAG-78 Growth Forecast; and 4.) Amendments to the Regional Transpor-
tation Plan for the December 11, 1978 City Council meeting.
If you have any questions, please contact me.
Respectfully,
Fred Talarico
Environmental Coordinator
FT/dt
I
u
0(
N'F1 rPC)uT uF A CT4
November 16, 1978
Mr. Jim Wilson, President
Southern California Association of
Governments
600 South Commonwealth Avenue
Suite 1000
Los Angeles, CA 90005
Dear Mr. Wilson:
RE: SCAG ALTERNATIVE GROWTH FORECASTS
The purpose of this letter is to reiterate the concern of the
Newport Beach City Council over the Alternative Growth Forecasts
prepared by SCAG as part of the proposed Regional Development Guide.
The Council felt it important to re-emphasize the City's position in
this matter due to the fact that these forecasts are scheduled for
public hearing and adoption by SCAG in the near future.
One primary area of concern relates to the potential cumulative
impact of the "Sum of Local Government Forecasts" alternative.
Of particular concern in this regard is the projected increase in
population of 3.03 million for the region overall and specifically the
projected 144 million increase for Orange County. It is the City's
position that such a growth rate would pose serious and far-reaching
consequences in terms of the region's ability to adequately respond
to the increased demands which would be placed on traffic circulation
and public service delivery systems, as well.as upon the Air Quality
Management Program and other critical support systems.
Another area of particular concern relates to the potential negative
impact of the Concentrated Growth Forecast and Coastal Plain/
Desert Forecast. An already -overburdened traffic circulation
system in the region's coastal areas would, in the City's view, suffer
serious negative impacts with the increased population and development
forecasted by these alternatives.
In light of the above, the City must again go on record in urging
SCAG to adopt planning policies and strategies which would lead to
implementation of the E-O or low -growth alternative. It is felt
that without such emphasis upon containing and guiding growth in
the region, local governments will be unable to adequately deal
with the cumulative impact of the resultant population and development
intensities.
City Hall • 3300 Newport Boulevard, Newport Beach, California 92663
U. S. Department of Interior Fish and
Wildlife Services '
Page Two
November 17, 1978
Sincerely,
PAUL RYCKOFF
Mayor
PR:jmb
xc: Orange County Flood Control District.
J
r'
•
L
Department of Community Development
DATE: November 8, 1978
TO: Mayor Paul Ryckoff
FROM: Fred Talarico
SUBJECT: October 1978 Draft Air Quality Management Plan
Pursuant to your request, I have reviewed the October 1978 Draft
Air Quality Management Plan. The Orange County area public hearing
on this document will be held on December 14, 1978' from 9:30 a.m.
to 4:00 p.m. at the Board Hearing Room, 10 Civic Center Plaza, Santa
Ana.
Local government are being asked to approve the plan prior to SCAG
and' SCAQMD approval and transmittal to ARB and EPA. They have indicated
that local approval means that the jurisdiction: "1.) agrees to the
growth forecasts':t'o be nhttiagtdd by the AQM.;-are •those contained in
the SCAG Development Guide; 2.) supports the recommended measures
in the plan or -recommends substitute measures; 3.) agrees to schedule
adoption of local implementation measures; and 4.) recommends that
SCAG and the District submit the plan to ARB and EPA."
I would suggest that you consider not supporting the final draft AQMP for
the following reasons:
1. SCAG Development Guide
At the November 1, 1978 Citizens Environmental Quality Advisory
Committee meeting, the Committee reviewed the "SCAG Development Guide"
and had serious reservations with it. A copy of their concerns has
been forwarded to the City Council under separate cover.
2. Recommended Measures
The October Draft AQMP while representing a substantial improvement
over the preliminary plan does not address all of the concerns expressed
by the City of Newport Beach in your letter of September 1978.
Additionally, five control measures: H-85 "Freeway Facility Changes";
H-86 "Wilshire Rail Line"; H-87 "Los Angeles People Mover;" H-88
"Freeway Widening;" and H-89 "Transit Systems Improvements" (pages
ix-221 thru ix-231) are exceedingly expensive and show small tMproye,=.
ments to Air Quality. Chapter xi•i•i of the. report suggests three. '
ppossible methods of funding these. hi;gh.ly e.xpens•i;ye, measures; "Al
Reprogrammi•,ng of projected transportation reven.ue.s to the. most cost
effective atr quality me.as.ures";'BJ "'Reallocati;on of existing state
and federal revenues so that the. position of these. reyenue.s allocated
to the SCAG region is, increased"; and C) "'Generation of Addi;tionai
Sources of Funds."
TO: • Mayor Paul Ryckoff - 2.
A) "Reprogramming": The Draft AQMP does not adequately address the
impact of the program on the entire SCAG area.
The plan does not demonstrate that the measures
in question H-85, 86, 87, 88, and 89 are: "cost
effect air quality measure."
B) "Reallocation": While increasing the regions return of taxes is
a highly desirable goal, the plan does not
indicate if these five measures would be the
most desirable. Additionally, their inclusion
represents a commitment to implementation that
is premature until such time as it can be
demonstrated that the addditional funds can be
secured and that this is the most appropriate
expenditure.
C) "Additional
Taxes": This strategy does not appear reasonable.
3. Adoption of Local Implementation Measures
AND
4.
^t Beach on
ission of
Based on the Citizens Environmental Quality Advisory Committee's
recommendations on the "SCAG Development Guide", the City's concerns
expressed in its letter of September 1978 and the additional resdr-
vations indicated with measures H-85 through H-89 staff would suggest
that it is premature to consider a commitment of the City to the
adoption of local implementation measures. The City Council may wish
to recommend to SCAG and the District that the Draft AQMP be revised
in light of the aforementioned prior to submission to ARB and EPA.
If you have any questions regarding the Draft AQMP or my comments,
please contact me.
Respectfully
Fred Talarico
Environmental Coordinator
FT/dt
�f
4
e
CITY OF NEWPORT BEACH
(714) 640-2110
November 16, 1978
Mr. Jim Wilson, President
Southern California Association of
Governments
600 South Commonwealth Avenue
Suite 1000
Los Angeles, CA 90005
Dear Mr. Wilson:
RE: SCAG ALTERNATIVE GROWTH FORECASTS
The purpose of this letter is to reiterate the concern of the
Newport Beach City Council over the Alternative Growth Forecasts
prepared by SCAG as part of the proposed Regional Development Guide.
The Council felt it important to re-emphasize the City's position in
this matter due to the fact that these forecasts are scheduled for
public hearing and adoption by SLAG in the near future.
One primary area of concern relates to the potential cumulative
impact of the "Sum,of Local Government Forecasts" alternative.
Of particular concern in this regard is the projected increase in
population of 3.03 million for the region overall and specifically the
projected 1_04 million increase for Orange County. It is the City's
position that such a growth rate would pose serious and far-reaching
consequences in terms of the region's ability to adequately respond
to the increased demands which would be placed on traffic circulation
and public service delivery -systems, as well as upon the Air Quality
Management Program and other critical support systems.
Another area of particular concern relates to the potential negative
impact of the Concentrated Growth Forecast and Coastal Plain/
Desert Forecast. An already -overburdened traffic circulation
system in the region's coastal areas would, in the City's view, suffer
serious negative impacts with the increased'population and development
forecasted by these alternatives.
In light of the above, the City must again go on record in urging
SCAG to adopt planning policies and strategies which would lead to
implementation of the E-0 or low -growth alternative. It is felt
that without such emphasis upon containing and guiding growth in
the region, local governments will be unable to adequately deal
with the cumulative impact of the resultant population and development
intensities.
City Hall • 3300 Newport Boulevard, Newport Beach, California 92663
•Ip •o
Mr. Jim Wilson, President
Page Two
November 16, 1978
The City appreciates the opportunity to again comment on this
important matter.
Sincerely,
/P , RYCKOFF L'
Mayor
PR:jmb
P0
O �
!� Department of Community
3 r
C'CIfnPN`'
DATL: November 22, 1978
•
Development
TO:. Mayor Ryckoff
FROM: Fred Talarico
SUBJECT: Orange'County Division - League of California Cities
AQMP-Poll
On November 15, 1978, we received the attached request from tfie
Orange County Division - League of California Cities. I have
prepared a response for your review (attached). The response
is based on our comments on the Preliminary Draft AQMP and
my draft letter for your signature.prepared November 21st.
If you agree to the response, Joanne could forward it to
Bob Haskell at League. If I can be of any assistance, please
contact me.
4j, lxzdualop-o�
Fred Ta arico
Environmental Coordinator
FT/dt
1) Letter League of California Cities dated 11/14/78
2) Staff response
CITY OF NEWPORT BEACH
MEMORANDUM: From Office of the City Manager
Dick Hogan, Director
TO_ ....... ........ Communi.ty..D.e-)ieJj).pmen.t .... N4Y.ecnber..28.., 1y78....
SUBJECT: CITY COUNCIL CONSENT CALENDAR ITEM H-3(e), DATED 11/27/78
The City Council, at their meeting on November 27, 1978, referred the attached
letter from State Senator Richardson to the staff for inclusion in an ongoing study.
The letter concerns the goals and policies adopted by regional governing bodies in
connection with the Air Quality Management Plan.
Please incorporate this item in your records as requested.
RLW:GJB:ib
Attachments
Reply wanted ❑
Reply not necessary ❑
RECEIVED
Ca 1110niky
D-1 : *Mm nt
, ••.at.
NOV 8 197801-
CITY NEWFC; LU.-CEACN,�
By...... ..1 ............
RO ftT L:���WY
N6•A
STATE CAPITOL
Su RAMENtO 95514
(016) .145.0088 California
�/ /// 1 1 1
D1ITRICT OFFICE n 1 ali forni ��a ,*ltafe
705 W. DVADTP. ROAD, SUITE 207 \�� IY h ?N' �`/M' NLVV
ARC.ADIA 01006 ,
(210) 445.4404
H. L. "BILL" RICHARDSON
1'✓i;:'. wi<.=!• ' STATE SENATOR
' TWENTY-FIFTH DISTRICT
CHAIRMAN
SENATE REPUBLICAN CAUCUS
COMMITTEES
ELEC[IONS AND REAPPORTIONMENT
NATURAL RESOURCES AND WILDLIPE
REVENUE AND TATATION
MEMBER �`�-••).
Pz"AL 1#nT=mAf
r
I 41." I�• •.i
2
cnl.i�. •
N
Members of the Newport Beach Ci'ty,Council November 15, 1978
Newport Boulevard
Newport
ort Beach, California 92663 /1
RE: AIR QUALITY MANAGEMENT,PLAN
In order to fully comprehend the significance of the goals
and objectives of the Air Quality Management District and the Southern
California Assobiation of Governments and their relationship to the
efforts of federal, state and regional regulatory agencies, to restructure
our society, it is necessary,to study Governor Brown's Urban Development
Strategy, the California Department of Housing Development regulations,'
SCAG's Land"Use Element, and the Air Quality Management Plan, and to
project the combined accumulative effect of the implementation of the
proposals contained therein.
Goals and policies which have been adopted by SCAG, ABAG and
other -associations of government include controlling the growth of pop-
ulation and of housing units, employment, and land use. They additionally'
include control of transportation, environmental management, education
("to achieve curricula to prepare students as complete functioning indi-
viduals in a contemporary society"), control of economic development,
regulation of open space, natural resources and recreation, in order
"to assure that everyone has an opportunity to attain an acceptable'
quality of life".
Included in the recommendations and alternatives set forth
in these documents are regulation of the number of vehicles which would
be allowed in a given area; efforts to control the distance people would
be permitted to live from their place of employment; increased population
density by restricting growth; established "incentives" for people to
move back into urban areas; placing a tax•or fee on parking facilities
for places of business; regulated business hours; control of transporta-
tion; controlling the distribution of goods and controlled production.
There has even been a recommendation that persons who intend to take a
trip by motor car be required to check with a government office to
determine if there are people going to the same destination or a desti-
nation en route, and in order to insure full vehicle occupancy such e':'A:r1lLL-2L
persons would be required to ride together even though they might bed' ,- M,
total strangers.
ii��/ ' •'ar
Re.. Air Quality Management Plan
Page Two
The average person refuses to believe such measures exist
until Lhey actually read the documents themselves. Since very few
people, including the executive board of SLAG, actually have the time
to road documents such as the Air Quality Management Plan (which is some
900 pages), the Land Use Element, Urban Development Strategy, etc., the
recommendations contained in such proposals are frequently adopted on
recommendation of staff, even though they have far reaching social and
economic impact.
It is my concern that the Air Quality Management Plan will be
adopted in the same manner. Before adopting the AQMP, I feel that
several vitally important questions should be answered. For example:
(1) Is clinical evidence available to prove beyond a reasonable
doubt that there is a direct correlation between the control measures,
air quality and public health?
(2) What are reasonable levels of air quality that can be
medically justified?
(3) Are present Federal standards aimed at protecting the hyper-
sensitive individual? If so, what percentage of the population is hyper-
sensitive, and do they suffer permanent damage to their health as a
result of present levels of air pollution?
(A) Are the federal standards adequate to meet health needs. If
so, why are California standards more rigorous?
(5) The South Coast Air Basin is considered an area of non -attain-
ment. That means the standards cannot be met under any circumstances.
If that is so, what level can we realistically attempt to achieve, and
what measures would be considered making a reasonable effort?
SLAG has already implied that they will use their authority to
review requests for Federal funds as a means of enforcing compliance with
what they consider to be reasonable control measures. In their words,
"this Air Quality Management Plan, or AQMP, presents an approach that
brings together both an air quality management agency with regulatory
powers, and land use and transportation planning agencies in a compre-
hensive planning effort."
Failure to adopt the measures which would restructure the life-
style of California citizens will result in the possible loss of Federal
'funds. Perhaps the time has come to reevaluate the price which must be
paid in the loss of local control, as well as the right of our cities
and state to determine their own standards, against the benefits derived
from the Federal funds we receive.
Sincerely,
H. L. "DILLWRICON
State Senator
DATE:
TO:
FROM:
SUBJECT:
Department of Community Development
December 4, 1978
Mayor Ryckoff
Fred Talarico
Orange County AQMP Coordinating Committee Meeting -
,November 30, 1978
The November 30, 1978, Orange County Coordinating Committee
Meeting Agenda is attached. Staff attended the meeting at
your request. The following briefly summarizes the meeting:
1. Call to Order: Paul Ray.er (Orange County CAD Office)
called the meeting to order. The committee lacked a
quorum.
2. Approval Minutes: Due to lack of quorum action on the
minutes was held till the next meeting.
Regional Draft AQMP-Final Draft -Recommendation: The
members present discussed the Orange County EMA responses
and recommendations to the Board of Supervisors on the
Draft AQMP. Major considerations discussed were as follows:
A. Mobile Source Controls
B. Aircraft Operations (increased load factor and
implications).
C.• Transportation System Improvements (discussion
'similar to concerns expressed by our response)
D. Fund (discussion similar to the concerns
expressed in our response)
Orange County EMA staff will be preparing a detailed response
to each proposed strategy in terms of support or suggesting
alternative measures. Additionally, Board of Supervisors will
be requesting each city within the county by mail -gram to
respond to the Draft AQMP.
It was discussed that any support for the AQMP should not be
given until changes have been made to the Draft Plan and
SCAG Executive Committee has taken action to recommend its
approval.
TO: Mayor Ryckoff -- page 2
The next meeting of the Coordinating Committee will be held
on December 28, 1978 at 2:00 p.m. in the County Transportation
Building.
Respectfully,
Fred
Atta
FT/j
a
A_ _.
�`'eWPoRr • _ •
M Department of Community Development
DATE:
TO:
FROM:
SUBJECT:
December 4, 1978
Mayor Ryckoff
Fred Talarico
Orange County AQMP Coordinating Committee Meeting -
November 30, T978
The November 30, 1978, Orange County Coordinating Committee
Meeting Agenda is attached. Staff attended the meeting at
your request. The following briefly summarizes the meeting:
1. Call to Order: Paul Raver (Orange County CAD Office)
called the meeting to order. The committee lacked a
quorum.
2. Approval Minutes: Due to lack of quorum action on the
minutes was held till the next meeting.
Regional Draft AQMP-Final Draft -Recommendation: The
members present discussed the Orange County EMA responses
and recommendations to the Board of Supervisors on the
Draft AQMP. Major considerations discussed were as follows:
A. Mobile Source Controls
B. Aircraft Operations (increased load factor and
implications).
C•.. Transportation System Improvements (discussion
similar to concerns expressed by our response)
D. Fund (discussion similar to the concerns
expressed in our response)
Orange County EMA staff will be preparing a detailed response
to each proposed strategy in terms of support or suggesting
alternative measures. Additionally, Board of Supervisors will
be requesting each city within the county by mail -gram to
respond to the Draft AQMP.
It was discussed that any support for the AQMP should not be
given until changes have been made to the Draft Plan and
SCAG Executive Committee has taken action to recommend its
approval.
TO: Mayor Ryckoff -- page 2
The next meeting of the Coordinating Committee will be held
on December 28, 1978 at 2:00 p.m. in the County Transportation
Building.
Respectfully,
Fred arico
Attachment: Correspondence received at meeting.
FT/jl
a
I �
R. E. THOMAS
COUNTY ADMINISTRATIVE OFFICER
COUNTY ADMINISTRATIONOUILDING
515 NORTH SYCAMORE STREET
SANTA ANA. CALIFORNIA 9270I
TELEPHONE: 034-2345
AREA CODE 714
4-B5
COUNTY ADMINISTRATIVE OFFICE
November 28, 1978
TO: Supervisor Anthony, Ist District
SUBJECT: AQMP Issues
I. General
1) Section 172(b)(7) of the Clean Air Act requires the nonattainment
plan to "identify and commit the financial and manpower resources
necessary to carry out the plan provisions required by this sub-
section."
Section VIII.2 of the AQMP outlines eleven measures included in the
plan that will require changes in legislation and/or changes in
administrative codes or regulations. Of these, six measures require
state action, four require federal action, and one requires either
local, state and/or federal action.
In that the District cannot commit state nor federal financial and
manpower resources these measures might be taken out by either ARB
or EPA. This may result in local government having to unnecessarily
consider measures which are unacceptable to them or submit a "shortfall
plan" to ARB.
It must be kept in mind, however, that the'State Air Resources Board
has the authority to amend our AQMP. In that stringent measures are
required to meet the 1987 timeline, ARB may adopt measures (not
including land use) which are unacceptable to local government and
•require us to implement them. Our only recourse at that point would
be to take the matter to court.
2) Section 172(b)(10) - This section requires that we "include written -
evidence that ...the general purpose local government or governments...
have adopted by statute, regulation, ordinance, or other legally
enforceable document, the necessary requirements and schedules and
timetables for compliance, and are commited to implement and enforce
the appropriate elements of the plan."
Supervisor Anthony
November 28, 1978
Page 2
The required schedules and timetables for compliance and the commit-
ments to implement and enforce at least some elements of the plan are
embodied in the 208, RTP, and SCAG 78 reports. These documents will
not have been adopted by -January 31, 1979. Therefore, there can be no
commitment by local government to implement those measures in the AQMP
which relate to these documents.
When adopting the•AQMP,'are we nonetheless commiting this basin to.the
policies. of the 208, RTP and the Development Guide? What is the
relationship between the AQMP adoption and the "other" plans? Do not
the "other" plans represent this basin's commitment as required in
Section 172(b)87) of the Clean Air Act?
Further, we cannot reasonably expect any of the cities or counties
in this basin to adopt any portion of'the Plan until it is adopted.
As the schedule stands now, the Plan is to be -adopted by January 31,
1979 and sent forthwith to ARB..
Thus we are forced into a situation in which a Plan will be sent
to ARB which has not received the commitment, by resolution, etc.,
of local government.
This will require us, other counties and cities, to send letter's
of commitment after the Plan is adopted and sent to ARB. The District
and SCAG would be placed in a rather uncomfortable position of having
to represent to ARB that the adopted Plan will receive the support
-of local government. A goal which may be hard in fact to achieve.
3) Implementation cost estimates are inadequate. :•
4) There has not been sufficient time to integrate the component parts
(208, AQMP, Housing, RTP, SCAG 78) into what is essentially a 10
year growth plan for the basin.
II. Regional Transportation Plan
1) Section 176(d) of the Clean Air Act requires "Each department, agency,
or instrumentality of the Federal Government having authority to
conduct or support any program with air -quality related transportation
consequences shall give priority in the exercise of such authority,
-consistent with statutory requirements for alloca•tion.among States or
other jurisdictions, to the implementation of those portions of plans
'prepared under this section to achieve and maintain the national
primary ambient air quality standards. This paragraph extends.to,'but
is not limited to, authority exercised under the Urban Mass Transpor-
tation Act, title 23 of the United States Code-, and the Housing and
Urban Development Act."
By having some transportation capital projects in the AQMP are we to
understand that these projects are therefore ascribed some higher
priority than those in the RTP?
Supervisor Anthony _ •
November 28, 1978
Page 3 .
2) Regional Transportation, Maintenance, Development and Air Quality
Control Measures (1979-1988, Page XIII.6). "In all, the public sector
faces unfunded costs of $3.5 billion for system development and main-
tenance, and $1.4 billion for mobile source control measures. An
additional $2.3 billion in mobile source measures is assumed to be.
borne by the private sector."
The system maintenance and development costs through 1988 are projected
to be $18.4 bilion while the revenues are projected to be $15.1 billion,
a shortfall of $3.3 billton. This does not even include the required '
$1.6 billion needed to fund the public sector transportation control
measures nor the $2.3 billion that the private sector will be tabbed for.
Unfunded through 1988
$3.5 billion - system development and maintenance
+1.4 billion - mobile source control measures
$4.9 billion - shortfall 1979-1988
+2.3 billion - direct costs to private sector
$7.2 billion - Total additional funds required 1979-1988
"Unless additional funds are generated or costs are reduced as a result
of either projected delay or withdrawal, unfunded public sector costs
will total $4.9 billion." (page XIII.24) •
Accordingly, the Plan• recommends a combination of tax increases and
reallocation of currently unavailable funds to'finance both the mobile
source control measures, and transportation system development projects.;
The Plan proposes using a "Gas Tax Indexing" system within the district.
An indexed regional gasoline tax would link tax increases to some
price index e.g., wholesale, consumer, or possibly highway construction
(I do not understand that last one). :
With regard to currently unavailable funds the Plan supports a."fair
share" return of highway capital funds and maximum federal contribution
for transit capital projects.
There may be problems with both of these funding recommendations which
may result in our having to drop those capital intensive projects from
the Plan.
First, we should give serious consideration to Governor Brown's campaign
statements indicating that he will not increase taxes of any manner,
shape or form. Presumably, this would include gas taxes. If the
Governor means what he says, -then the projected $1.6 billion from this
source cannot be counted on.
Secondly, while the fair share concept sounds great for those of us
in Orange and Los Angeles Counties, it probably does not sound that
great to the State and other counties when it comes to paying for those
roads used by Orange and Los Angeles Countians enroute to Las Vegas,
r
Supervisor Anthony
November 28, 1978
Page 4
Lake Tahoe and Mommoth. Thus,'it is reasonabie to expect strong
opposition to any move to divert additional funds to this area. Further,
the State has shown a marked propensity for holding onto State Road
Funds in an apparent attempt to slow down freeway construction.
No matter how the -additional funds are ultimately provided for, neither
the AQMP nor the ARB's SIP can commit the State Legislature to increasing
State taxes. Thus we may have to limit the Plan to those measures
for which funding is.provided for under existing law.
3)'While the narrative for H-18.(Annual Inspection and Maintenance of
Light -Duty Vehicles) does not recommend the use of "loaded" tests, the
Recommendations for New Legislation, Section XIII.2 of the AQMP does.
Testing -vehicles in the "loaded mode" has not been demonstrated'to be
cost effective. Further, an ARB report recommended against the use of
a "loaded mode" test system in Us program. The "loaded mode" recom-
mendation should be deleted.
4) What is in the RTP "baseline"?
o do we agree with it?
o does OCTD agree with it?.*
o does the Orange County Transportation Commission agree with it? -
5) Is the implementation timetable provided for in the RTP realistic?
III. Development Guide
kg
1) What is the requirement going to be, if there is one at all, for local
government to adhere to these.projections?
2) If the LA/OMA project for the desert is not approved in 208, what ._
does that do to our population projections - reduce or postpone them?
3) What are the impacts on the AQMP of changing the Guide at this late date?
K. Paul Raver
Senior Administrative Analyst
< UNITED STATES ENVIRONMENTAL PROTECTION AGENAV 3 VV1
?�".�•!� REGION IX j98
215 Fremont Street
San Francisco, Ca. 94105 `' AN71j0NY
NOV 24 1978
Mr. Phillip L. Anthony
Supervisor, First District
Orange County Administration Building
P.O. Box 687
Santa Ana CA 92701
Dear Supervisor Anthony:
We have received and reviewed the Orange County Air Quality
Management Plan. The plan demonstrates the county's commit-
ment to comprehensive planning, both in its presentation of
innovative control strategies., and in the level of planning
expertise that it exhibits. There are; however, a few
critical issues which need to be discussed in more detail.
Transportation:
Page III of the Plan states that "The authority of local
governments to directly impact transportation sources of
pollutants is limited mainly to parking regulations and
traffic controls." This statement appears to be contradictory
to transportation strategies contained in the plan such as
encouraging higher occupancy vehicles, and implementing
staggered work hours.
Page 17 of the Plan states that "The Air Resources Board has
sole authority over mobile source and emission control
devices, including authority to require inspection/maintenance
(I/M) of these devices."
Although the State has primary responsibility for implementing
such a program, local governments have an important role to
play in I/M, by actively supporting passage of the enabling
legislation, and fostering an atmosphere of public acceptance.
The Board of Supervisors, as well as individual City Councils,
should consider adoption of resolutions advocating the I/M
program, and forwarding these resolutions to both the Southern
California Association of Governments (SCAG) and the South
Coast Air Quality Management District (SCAQMD), as designated
lead agencies for nonattainment area planning as well as to
the California State legislature.
Planning Process:
The extensive scope of the strategies described in the Pla
is commendable. However, it is not clear from discussions
on page I of the plan when legally enforceable commitments
necessary to ensure implementation of the plan will be
secured, as required by Section 172(b)(10) of the Clean Ai
Act (CAA). The Act also requires that these commitments
include an allocation of financial and manpower resources
necessary to implement the plan.
The plan mentions various intergovernmental structures which
have been used to integrate water quality and transportation
planning, with general plan development. We would like to
compliment you on your use of the these planning structures,
and would appreciate details of these communication processes:
The plan also indicates that public involvement through the
use of citizens groups, workshops, and public hearings is a
priority in Orange County. We would like to be kept advised
as to how this process operates, and how successfully it is
functioning. The plan must document the public participation
process, including a record of public comments along with
the subject and outcome of these workshops and public hearings.
questions,
Grasser of
Sincerely,
Jer�ohn Wise
Chief, Planning Bra:
Air and Hazardous M,
hesitate to c
(415)556-8064.
QITY OF NEWPORTWACH
I ROLL
COUNCILMEN
4iF 9 pTy�Gtf� Z��
CALL`
September 25, 1978
MINUTES
INDEX
I. ITEMS REMOVED FROM THE CONSENT CALENDAR:
1. A letter was presented from the Corona del Mar
Parking
Chamber of Commerce objecting to the additional
Prohibitio
red curbs on Jasmine, Iris and First Avenues and
(447F)
requesting the possible elimination of some of
the red curbs that now exist.
Motion
x
Staff was directed to write the Corona del Mar
'All Ayes
mber of Commerce advising them that the
ffic Affairs Committee was preparing a report
the Council regarding the red curbs and
t a staff report would be included.
\2Aport was presented from the Environmental
Quality Citizens Advisory Committee concerning
the Cib, 's position with regard to the Orange
County
OrCo
Airport
(195)
Motion
x
port.
Councilman Iii�1mnel stated since the news of the
aircraft disasb r in San Diego proved the need
for a new airpor in Southern California, he
would move to have he staff with the assistance
All Ayes
of Councilmen Heathe and Hummel summarize a
position paper on an a port location, which
motion carried.
Motion
x
3. The following resolutions we adopted:
All Ayes
County
Resolution No. 9435 requesting t P Orange
Transportation Commission to inclu'd within the
Orange County Federal Aid Urban Prog'Dam the
development of East Coast Highway from\Bayside
Drive to MacArthur Boulevard. (A report rom
the Public Works Department)
Resolution No. 9436 authorizing the Mayor and
City Clerk to execute an agreement between the
City of Newport Beach and Williamson and Schmid
E Coast Hw
Bayside to
MacArthur
R-9435
(2071)
E Coast Hw
So'ly Side
\St Impry
Motion
for engineering services in connection with East •
Coast Highway southerly Side Street Improvements
from Jamboree Road to Avocado Avenue, Contract
No. 1990. (A report from the Public Works
4. The Mayor's letter to the Southern California
J mboree t
Avdo
R-943
(3072)
x
Air Qualit
Management
Plan
Association of Governments regarding tie City's
im
"Response to the Prelinary Draft of the Air
All Ayes
Quality Management Plan_ was approved'(3071)
Motion
x
5. A report from the City Manager regarding the
proposed change in election dates suggested by',•"(12F)
the Newport Harbor Area Chamber of Commerce..was
Electio-n
All Ayes
received and ordered filed. d
6. A report was presented from✓th'e/Cit"y Attorney
regarding "Valet -Parking.
Parking
Prohibitic
(447F)
Pr2ppseld Ordinance being, AN ORDINANCE OF THE
CITY OF NEWPORT BEACH AMENDING SECTION 12.40.065
ENTITLED "VALET PARKING ON PUBLIC STREETS AND
Volume 32 - Page 249
ns
CITOOF NEWPORT BEA
COUNCILMEN
�i'�� ytiG2Z
f 9�i ��psa�s
ROLL CALL J'
September 25, 1978
MINUTES
INDEX
Motion
x
LOTS" TO THE NEWPORT BEACH MUNICIPAL CODE, is to
All Ayes
be resubmitted for first reading on October 10,
1978,
7. A letter from Charles B. Baur regarding the
WCH Widening
installation of curbs, gutters and sidewalk in
57th St to
front of his business and his objections concern-
SA River
ing the project was presented.
(2552)
The following people addressed the Council
opposing the installation of curbs, gutters
and sidewalk in connection with the Public Works
contract for the widening of Pacific Coast Highway
57th Street to the Santa Ana River: George C.
Gillette, representing Charles Baur, who presented
a petition beAring 652 names; Ninsa Jarvis,
representing the Newport Shores Community Associa-
tion; and Charles Baur.
Motion
x
e letter from Charles Baur was referred to the
All Ayes
a aff for reply.
K. AD TIONAL BUSINESS:
Motion
x
1. A pu is hearing was set for October 24, 1978 on
Traffic
All Ayes
the f llowing:
Phasing
(3006)
A revi by the City Council of the decision of
the P1 ing Commission in the application of
the Traf c Phasing Ordinance to the request for
A+
two 20,00 square foot office buildings by
Signal Dev lopment Company on Lots 18, 19, 43
and 44, Tra t 3201 located at 4060 and 4100
Campus Driv and 4063 and 4101 Birch Street,
southeasterl of Campus Drive and southwesterly
of Dove Stree across from the Orange County
Airport.
2. A report was pr ented from the Public Works
BI Bulkhead
Department regar ng the Balboa Island Bulkhead
Coping
Coping Repair, Co tract No. 1860,
Repair
(2870)
Motion
x
The staff was autho ized to substitute a sub -
All Ayes
contractor for the ite work on this contract.
3. The City Manager addr sed the Council in regard
Balboa Bay
to the change in lease 9 under the Balboa Bay
Club Lease
Club Lease.
(183)
Resolution No. 9437, aut rizing International
R-9437
Bay Clubs, Inc., to ruble certain portions of
the Balboa Bay Club premix a and establishing
the rate of rental payments to the City for
subleases of the Balboa Bay lub premises for
Motion
x
commercial purposes for to in excess of one
All Ayes
year, was adopted.
Scott Hightower, President of t e Balboa Bay
Club, addressed the Council and ubmitted the
letter of request.
Mayor Ryckoff declared the meeting adjo rned at
10:25 p.m.
Volume 32 - Page 250
CITY OF NEWPORT BEACH
714 640-2110
Southern California Association
of Governments
600 So. Commonwealth Ave., Suite 1000
Los Angeles, California 90012
Attention: Mr. Mark Pisano, Executive Director
Gentlemen:
Attached are initial comments on the Draft Air Quality Management
Plan. Reconciling these comments and those from various local
jurisdictions with the plan may be a momentous task. How.can
SCAG, the District and the jurisdictions come together, and who
makes final determinations? It is not clear what is expected of
local jurisdictions, and what costs they will be expected to pay.
•' Overall, many of the control measures affect only small tonnages•
of emission from many different sources at a relatively high cost
per ton. Implementing such controls would be nonproductive and
not cost effective. If implementing all or most of the measures
in the Draft Plan is considered necessary to meet 1982 and 1987
standards, we believe this goal will not be achieved. It does
not appear possible to implement all or most controls. ,
The only control measure listed for large electric generating
plants isS-6, for sulphur dioxide and that is rated negative under
Feasbility/Financial because of increased costs of fuel. If ef-
fective measures were taken for these large sources many or most
of the small tonnage, high cost per ton measures could be deferred
or even eliminated. These measures should include reducing the
tonnages of emissions from the electrical generating plants, and
until controls technology for NOx emissions is available. And be-
cause NOx output from non-nuclear electric generating plants is
large regardless of fuel burned, a program of economic incentives
to phase -out their use should be developed to avoid modifying the
• equipment to extend useful life. No large new fossil -fuel burning
generators should be permitted in the basin whether external com-
bustion or turbine. This approach will require conservation; con-
tinued work on other sources and providing information to the public
on the environmental trade-offs between conventional and nuclear
power sources. No such effort has apparently been made. It is
City Hall • 3300 Newport Boulevard, Newport Beach, California 92663
Page -2-
Southern California Association
of Governments
quite possible the public will endorse the'use of a potential'
environmental threat (nuclear) against an existing and certain
threat (fossi.l fuel). Also, the power companies have not provided
data on the growth that can be accommodated with existing capacity.
It is desirable that figures be prepared based on the SCAG popula-
tion forecast showing separate effects on power demand.of residen-
tial, commercial and industrial growth.
Regarding significant impacts, where control measures are assigned
negative impacts, they may still be feasible actions. Some ex-
amples are:
1. In N-9•, a Cost effectiveness of $2,000/ton is estimated,
and under Financial Technical Feasibility the impact
is negative for the reason."it is not certain what the.
financial or technical impacts might be."
• 2. In S-1 and S-2, a negative impact is assigned to Water
Quality/Solid Waste. If only added cost is involved to
dispose of the waste, this should be reflected in Cost
Effectiveness, and a positive impact listed; depending.
on cost.
.3. In S-6,.the use of low sulfur fuel is assigned a negative
financial impact under Feasbility, because of increased
costs for ultra low sulfur oil. Since fuel content may
be in'some cases the most effective measure available, it
should not be ruled out for negative Feasibility, but kept
in the inventory for Feasibility depending on effective-
ness and cost compared to other measures.
We believe that Non -Technological measures, T-1 and T-2 are inappro-
priate, particularly for large sources of emission. It would not
be feasible to newly impact populated areas for reductions elsewhere.
There are no data to indicate that specific areas would not experi-
ence deterioration of air quality from implementation of this measure.
It is very important that there be a continuing evaluation of dif-
ferences within the basin. It is likely that different control
measures will be appropriate for different areas within the basin.
On Page I-5, at the bottom, it is stated that "The plan has suf-
ficient control measures to assure annual increments of progress
in reducing the air pollution emissions to meet air quality stand-
ards . . .". On Page IX-6 bottom and IX-26 bottom, it is stated .
Page -3-
Southern California Association
• of Governments
that.the AQMP does not•contain enough'measures to meet both
federal and state NO2 standards. On Page I-30, it is.stated
that "Adoption of all proposed measures would result in attain-
ment of ozone, carbon monoxide and nitrogen dioxide federal
standards by 1987." On Page IX-60, Paragraph IX.3.6, it is
noted that there are almost enough measures identified to attain
the state SOp'standard by 1987. We suggest that the standards
should be met and that uncertainties and appropriate control
measures should be addressed.
We welcome the opportunity to submit comments on the plan, and '
will continue to participate in the effort to improve -air quality.
Sincerely,
• PAUL RYCKOFF
Mayor
CC: South Coast Air Quality
Management District
Ms. Alice MacLain, President
Orange County Division -
League of California Cities
Mr. Sandy Scott, Orange County
Environmental Management Agency
•
CITY OF NEWPORT BEACH
COMMENTS ON DRAFT
• AIR QUALITY MANAGEMENT PLAN
September 25, 1978
CHAPTER I
"SUMMARY"
Page I-7 "Table III": This table indicates for most cases of pollution
That should "growth" not occur within the region that current control for
the most part would allow the region to achieve the clean air standards.
There should be discussed the alternative of no -growth from an environ-
mental, political, social, and economic point of analysis. Additionally,
the potential for allowing growth to pay for pollution control should be
considered. The figures shown for daily emission tonnages are significantly
lower than those in Table VIII, Page I-29. Whether or not the difference
results from the assumption at bottom of Table VIII, it would be desirable
to use consistent figures.
• Pam "Top paragraph": In discussing the reductions in emission re-
quiredd, it mentions that the models can be used to test the reduction ef-
fects of certain sources, for example mobile, stationary and natural on air
quality concentrations and that these calculations will help define the most
efficient overall control strategy. Will these models be used for point
sources and by grids, as indicated on Page 44?
Page I-39 "Table IX"- Control Measures: These controls do not include
measures for large steam generators. It would appear that efforts to meet
required standards would be greatly facilitated by providing such controls
and by developing a plan to phase -out existing large generators as their
useful lives are amortized. This would mean also that no new fossile fuel
burning facilities of this magnitude should be permitted in the basin, by
offset rule or otherwise. A reduction of 81 tons per day is projected for
electric power generating equipment, a 60% reduction (S-6)•. The phasing -out
of conventional'generator facilities would avert concerns over the use of
high sulfur oil, the costs involved in requiring low sulfur oil and the
emissions that would result even from low sulfur oil or natural gas.
Nontechnological Control Measures: The new source offset programs, T-1
. and T-2, would be appropriate only if the new permitted sources had zero
additional impact on any populated areas. There appears to be no unpopulated
area in SCAB which could safely take additional deterioration of air quality.
This measure might be feasible for small sources such as dry cleaning plants,
but does not appear appropriate for large sources.
Page I-37 - Significant Impacts: For health effects the assumption is made
7_tFa_t__e_acb of these control measures will'havLx a positive impact because air
quality standards are health related." The nontechnological measures, Page .
IX-70 and IX-71, T-1 and T-2 cannot be assumed to have a positive health
impact, nor a positive effect in improving air quality.
Page I-80 "Table X": This table reviews the recommended control measures
• approved by each subregion. The chart should be revised or deleted. Pres-
ently it is too general and lumps together all approved measures. The degree
of commitment varied greatly from region to region and within tactics. One
subregion's policy to encourage an action is given the same weight as another's
dedication to fund as required. The chart therefore misrepresents sub -
regional policy and allows the reader to misread local support for individual
strategies.
CHAPTER II
"INTRODUCTION"
Page II-3: The clean air act requirements for analysis of an "identification
and commitment of manpower and resources for plan implementation" is not
provided within the draft plan. Items identified at the bottom of the page
"(a)" are not identified within the plan.
Page II-13 and 14: The cost reductions from air pollution by pollutant
receptors are dated 1974 and should be updated to the base data year to allow
for meaningful comparison. Additionally, who directly benefits from cost
reductions'should be documented.
• CHAPTER III
"GOVERNMENTAL SETTING"
Page 111-17- Local government approval section should be revised to indicate
t ath theT Preliminary Draft AQMP was submitted for local government review.
on September 11, 1978, for return comment by October 2, 1978, a fifteen work-
ing day period.
CHAPTER V
"EXISTING AIR QUALITY BASELINE - 1976"
Page V-17 "Figure 9": The 1975-76 Inventory Summary indicates that the follow-
ing pollutants are natural (areawide).
THC - 43.9%
RHC - 18.6%
• Would these natural pollutants preclude attainment of clean air standards,
and how have they affected determination of national clean air standards?
This may be even more significant for Orange County (Pages V 26 and 27).
.Page V-21, Chapter V, Basyear Emission Inventory, Figure 13-Oxides of Nitrogen:
Under. stationary sources, the pie chart shows that power plants are responsible
for,23.7% of the daily tonnage - 122.8 tons per day for SCAB and Ventura County.
-2-
This figure appears low. Page V-41, Table 5 Stationary Inventory, Power
Plants are listed for 122.7 tons per day of NOx and 210.49 tons per day
of SOx. These figures appear to differ somewhat from those in working
paper 2B, Table VII.
CHAPTER VII
"FORECASTS"
Page VII-82 "Appendix III": This appendix provides a five year capital
improvements program proposed by SCAG Regional Airport Operators. SCAG
should further document Orange County Airport proposals and the City allowed
to input on determining growth forecasts.
CHAPTER IX
"AQMP CONTROL STRATEGIES"
A. General Comments
1. It appears that the overall effect of the control strategies
will be the lessening of local control. The cumulative effect
of the strategies, if all were to be adopted, would be to put
• the City in a position of enforcing state and federal policy
within a specific set of parameters.
2. The overall effect of the strategies would be to increase the
cost of local government. The plan does not adequately address
the major issues of:
"Who pays for clean air?"
"Who is causing pollution?"
"Who benefits directly from funds expended?"
"What is each jurisdiction's fair share of costs?"
"Are Newport Beach residents being asked to pay for
pollution caused by industry many miles from the City?"
An adequate response to these questions should be provided
prior to the submission of the draft plan for adoption and imple-
mentation.
3. A majority of the strategies contain too many unknowns (in -
determinates) to allow for an adequate review and evaluation.
Several of the strategies remain in theory or concept level
and are beyond analysis capabilities at this time.
-3-
4. A measure of general commitment to the implementation of
any of the strategies is needed. For instance, a wholehearted
effort by City "A" could easily be eliminated by token com-
pliance by City "B".
5. Many control strategies are included for small sources and at
varying cost effectiveness. It does not appear practical to
implement so many measures. Among the largest stationary sources
are electric generating plants. Control measures are not pro-
posed for these sources, with the exception of S-6. Control of
these sources would make unnecessary many of the measures listed
for smaller sources.
Specific Concerns
Chapter IX, AQMP Control Strategies, Page IX-6 Summary of Control Measures,
(last paragraph) states that "The AQMP does not contain enough.measures to
meet both the Federal ozone standards and the State NO standard." On Page
IX-26,there is the following "It appears certain that here are not enough
measures to meet the Federal NOp standard by 1982." We believe that measures
should be designed and implemented to meet these standards.
Page IX-30, Oxides of Nitrogen Control Measures: Controls are listed for
medium and small steam generators (N-8). As mentioned elsewhere, controls
• for large steam generators should be included. An effective program for
these sources would mean that controls on many high cost effectiveness, or
smaller sources, could be postponed or even eliminated. No,new large con-
ventional steam generators should be permitted in the basin by offset rule;
or otherwise.
On Page IX-60, Paragraph IX 3.6, it is noted that there are almost enough
measures identified to attain the State S02 standard by 1987. At the bottom*
of the page, in a footnote, it is mentioned that recently adopted measures
would allow attainment of the S02 standard (assuming the availability of
natural gas for use in power,plants) and with some uncertainty, the sulphate
air quality standard. It would be desirable that the uncertainties indicated
be eliminated.
#H-1 Pa a IX-82 : This strategy would decrease jet commercial operations
y %. Tote extent that this strategy would reduce jet commercial
operations at Orange County Airport, the City may wish to support the strategy.
The City must consider the potential 11% reduction impact on LAX increasing
expansion pressure on Orange County Airport.
#H-2 (Page IX-84): This strategy would affect jet aircraft ground taxi
operations. To the extent that this strategy would increase noise levels,
the City would oppose this measure.
#H-4 (Page IX-88): This strategy would establish a four day, forty hour
work week. The City would oppose this measure at present.
#H=5• Page IX-90 : This strategy would provide for carpool preferential
parking. To the extent that this strategy is desired by the City,, it would
require additional City staffing. The strategy would require changes to the
in
existing zoning code requirements and additional enforcement within City -
operated lots.
#H-6 (Page IX-92): This strategy would modify new general aviation air-
craft engines. To the extent that this strategy would allow for maintenance
or reductions in noise levels in addition to reduced emissions, the City
will support. If reduced emissions equipment allowed for increased noise
levels, the strategy would be opposed.
#H-7 Page IX-94): This strategy would require emission controls on con-
struction an—Tc landfill equipment. The City may experience increased costs
for equipment and services. The City is willing to absorb increased cost.
to some degree to support the strategy.
#H-8 Pa a IX-96 : This strategy would require hydrocarbon exhaust con-
tros on tractors, graders and loaders. Comments are the same as for #H-7
above.
#H-10 (Page IX-100): This strategy would involve towing jet aircraft in
lieu of taxi operation. To the extent that the strategy would reduce
emissions and noise levels,'the City supports this measure. Any increase
in noise level'effected by the strategy would suggest City opposition.
#H-13 (Page IX-105): This strategy would require a regional effort aimed
at limiting future increases in trip -making. To the extent that the
• strategy would reduce emission and trips, the City will support. The
strategy though., calls for $5,000,000 annual cost.to local government (see
general comments).
#H-16 (Page IX-111): This strategy would modify jet aircraft engines to
meet T09 feaeral'regulation standards. Comments are the same as for H-6.
#H-18 (Page IX-113). This strategy would require inspection and maintenance
of Tight -duty ve icles. The City may experience increased costs for equip-
ment and services. The City is willing to absorb increased costs to some
degree to support this strategy.
#H-22 (Page IX-123): This strategy would require emission control for '
new utility equipment. The strategy will involve increased costs to the
City as it replaces existing utility equipment.
#H-23 (Page IX-124): This strategy would provide for increased bicycle
trips by:
1) Increased annual funding
2) Require new buildings to provide facilities.
3) Encouraging shower/locker facilities at empl.oyment
4) Increased home deliveries
5) Bike path dedications in new developments.
-5-
•
To the extent that the strategy would reduce emissions and trips, the
City will support. The strategy though calls for $10,000,000 annual cost
to local government (see general comments). Additionally, the City may wish
. to review and comment on divergence of funds to improve bicycle system for
.any needed highway improvements.
#H-24 (Page IX-128)_: This strategy would improve technological controls
for on -road vehicles. This would involve an increase cost to the City.
To the extent the City is willing to absorb costs, it will support this
strategy.
#H-25 (Page IX-130): This strategy is to eliminate aircraft delays, calls
for airport -site improvements. City's position will depend on the effect
on Orange County Airport.
#H-27 (Page IX-133): This strategy involves a decrease use of auto by
diversion to pedestrian trips. To the extent that this strategy would
reduce emissions and trips, City may wish to support. The strategy though,
calls for $2,000,000 annual costs to local governments (see general com-
ments). Additionally, to the extent that this would decrease funding for
circulation system needed improvements, City may wish not to support.
#H-28 (Page IX-135): This strategy would curtail organic solvent emissions
from marine coatings. The City may wish to oppose this strategy. The
• strategy would provide for a financial negative impact on remaining marine
service and repair industry within Newport Harbor.
#H-34 (Page IX-144): This strategy involves an expanded employer carpool
program. This strategy would cost $22,500,000 annually for public and
private employers (see general comments). To the extent that this strategy
would reduce emissions and trips and the City's willingness to absorb costs,
it may wish to support the strategy.
#H-35 (Page IX-146): This strategy calls'for automatic traffic control
systems. Annual costs to local governments - $5,040,000 (see general
comments). To the extent that this would reduce funding for circulation
system needed improvements, the City may wish to oppose.
#H-38 (Page IX-154): This strategy affects jet aircraft ground operations.
If this strategy- would increase noise levels, City would oppose.
#H-41 (Page IX-160): This strategy would reduce transit fares. Annual
costs to ocal government/transit districts - $25,800,000 (see general
comments). To the extent that this would reduce funding for circulation
system needed improvements; the City may wish to oppose..
• #H-43 (Page IX-164): This strategy would affect printing operation. The
impact on locaTgovernments is not indicated. City costs for conversion
of existing equipment might be required.
#H-44 (Page IX-165): This strategy would affect road construction. Annual
costs to Toca government are not indicated.
20
#H-50 (Page IX-173): This strategy affects natural gas and oil production.
City may wish to support this strategy as a means of reducing emissions.
#H-58 (Page IX-182): This strategy would provide for auto free zones (26)'
within the region. There is no way to measure the potential impact of this
strategy on the City. It would be necessary to identify precisely each auto -
free zone.
#H-60 (Page IX-184): This strategy involves the use of electric powered
ve icles for 10°, of all trips less than twenty miles. Potential impact on
City operations as a majority of City vehicle trips would be under twenty
miles. Clear definition of implementation measures is.needed. If conversion
to electric powered vehicles is mandated, substantial costs to the City would
be involved.
#H-60 (Page IX-186, Electric Vehicles: Under significant impacts, environ-
menta , air quality negative impact should be listed. Considerable electri-
cal energy would be required for charging batteries. The NOx reduction,
if the estimates are valid, is insignificant, while the S02 and particulate
emissions are increased.
#H-62 (Page IX-189): This strategy involves controls on in -harbor and dock-
side transfer of petroleum products. The strategy has potential impacts
on the harbor activities. The City may wish to stress pleasure/small craft'
exclusions from requirements.
#H-63 (Pate IX-190): This strategy involves significantly expanded levels
of transit service within region. The estimated annual costs to local govern-
ments would be $103,000,000 (see general comments). The costs of this pro-
gram may reduce funds available for circulation system improvements.
#H-67 (Page IX-197): This strategy involves increasing automobile costs
bydoubling existing parking costs in commercial and industrial centers.
If this strategy were to be applied uniformly to regional shopping center/
financial areas (Newport Center), decreased retail sales and desirability
could be assumed. Further, moneys siphoned off by surcharge would reduce
disposable income. The strategy has a potential significant impact on the
City's financial position.
#H-68 (Page IX-200): This strategy involves economics disincentives to
travel in congested areas (freeway tolls). To the extent that this strategy
would provide an incentive to growth within our area, the City may wish to
oppose. Increase evaluation of the impacts of the strategy is required.
The reductions W omissions shown may be considerably lower than would be
experienced.
• #H-69 (Page IX-202): The negative economic impacts maybe less -than antici-
pated. For example, this measure might force carpooling , or other efficien-
cies, reducing the effect on employment and disposable income. Under social
impact, equity, the assumptions may not be valid.
#H-70 (Page IX-205a): This strategy involves reduced parking costs for
carpools. The annual costs to local governments.and employees would be
-7-
$86,400,000. This program has a potentially significant economic impact
on the City (see general comments). The strategy would, though, provide
0 for reduced emissions and trips.
#H-71 (Page IX-2.5b): This strategy provides for increased use of rail,
air and DUS for inter -city travel. Potential City impact includes in-
creased noise levels from aircraft operations/flights and loss of revenues/
transfer of funds from agencies which provide for circulation system im-
provements.
#H-74 (Page IX-211): This strategy would eliminate on- street •parking•on
arterials during peak periods. There should be defined exactly what
arterials would be affected and the impacts on each. Additionally, the
funding source must be defined and then analyzed by the City of potential
impacts.
#H-76 (Page IX-215): This strategy calls for the development of para-
transit services. There should be provided detailed cost estimates and
funding sources as this could provide a significant economic impact on
local governments. To the extent that costs•and funding levels of circula-
tion system proposals would not be affected, the City may wish to.consider
supporting this strategy as a method of reducing emissions and trips.
#H-77•(Pa2e IX-217): This strategy involves expanding and extending the
existing and planned freeway network. There should be defined the extent
of any proposed expansion or extension of the freeway network. The City
will need to review c1•osely for consistency with City policy. Potential
economic impact to City; in addition to environmental. Under significant
impacts, social, equity, the negative impact may be•invalid, particularly
if combined with No.'s H-68, H-69 and H-80. The assumptions used.to arrive,
at this negative impact may not be valid.
#H-78 (Page IX-219): This strategy involves incorporating non-residential
uses into res� ent1al neighborhoods. The measure would be implemented
through general plan and zoning changes. To the extent that this would be,
achieved by regional, state or federal requirements, this should be opposed,
as usurpation of local control. As a concept,this would be consistent with
adopted City policy - with local control.
#H-79 (Pa a IX-220 : This strategy would require employees (w/over 100
emp oyees to participate in ride -sharing programs. This program would
involve increased costs to local governments in enforcement and participa-
tion. -Annualized costs and funding figures would be needed.
• #H-84 (Page IX-228): While this strategy does not appear to significantly
impact the City, it would be necessary to determine and document potential
routes, costs, environmental, social and economic impacts, the costs to
local'governments and other factors needed to allow for a reasonable review
of the strategy.
in
fse'eg
(Page IX-231): This strategy involves an energy conservation audit
rorm I isstrategy would entail increased funding at local levels
general comments).
• #N-2 (Page IX-234): This strategy would require a residential retrofit
program for energy conservation measures. This program would entail in-
creased funding at local levels (see general comments).
#N-3 (Page IX-237): This strategy would require solar water heaters in
a retrofit program for residences. This program would require increased
funding at local levels (see general comments).
#N-4 (Page IX-240: This strategy would require the installation of energy,
conservation street lighting. This program would require substantial
funding at local levels (see general comments).
#1-5 (Page IX-243): This strategy would curtail NOx emissions from resi-
dentia eaters. Increased local costs for review and inspection (see
general comments).
#N-6 Pa a IX-245 • This strategy would require reduced NOx emissions from
new water eaters (residential). Increased local costs for plan check and
enforcement could be anticipated (see general comments).
• #N-8 (Page IX-2477-: Our comment on
measure. a assumptions used in
feasibility impacts, seem to imply
or no cost.
Page IX-30 applies for.this control
indicating negative economic energy and
that standards should be met with less
#N-9 (Page IX-249).: The combined cycle equipment that has been proposed
for expansion or standby use at some steam plants employs gas turbines.
Such expansion would add significant emission tonnages. The negative
impact listed for feasibility Financial/Technical raises a question as to
the emission reduction projected and as to the usefulness of the control
measure itself.
#N-13 (Page IX-255): This strategy includes modifications to marine -diesel
engines. Potential impact on harbor activities. It would be necessary to
define scale of strategy and enforcement program.
#N-15 (Page IX-258): This strategy would require solar water heaters for
new residences. Impacts on the City would be economic, social and environ-
mental. Enforcement jurisdiction, aesthetics and energy factors dictated
at regional, state and federal levels of government.
#1-16 (Page IX-260): This.strategy would affect stationary gasoline engines.
Some increased costs at local level might be anticipated.
#N-17 (Page IX-261): This strategy should be defined.
M
#P-2 (Page IX-266): This strategy involves control of fugitive dust from
unpaved roa s; are fields, etc. The annualized annual costs do not appear
reasonable -- documentation should be requested. 'Potential for growth in-
ducing and environmental impact should be evaluated.
#P-6 (Page IX-272): .This'strategy involves the control of particulates
from woodwor ing operations. To the extent that the City wishes to preserve
his type of use, which presently exists in the Cannery Village, the City,
may oppose.
#P-7 (Page IX-274 : This strategy is directed at the collection, processing
and disposalof solid wastes.. What is cost to local governments?
#T-1 (Pa.e IX-295): The positive impact raised for environmental, air quality
is questionable As mentioned before, with large sources, it appears that
implementation of this rule would result in an adverse impact on new areas.
The SOHIO, Long Beach, project is termed an offset case, yet the power plant
where emissions are to be abated, is some distance away from the terminal.
#T-2 (Page IX-97): As noted in #T-1, it does not appear possible for large
sources to c2
onstitute a one to one offset in the same location and it will
not be found feasible or possible to newly impact population areas with
air pollution in a trade off.
' #17-4 (Page IX-299): This strategy would be to control permits based upon
location. T e City opposes this strategy as it does not reduce emission
and does remove land use decisions from local control.
#T-5 (Page IX-300): This strategy would control the time of day that emis-
sions are allowed. This measure does not seem advantageous.
#T-7 (Page IX- p0 L This strategy involves indirect source controls. The
City opposes this strategy. The strategy implies loss of local control on
land use decisions and no practical benefit from the strategy has been es-
tablished.
&T (Page IX-304): This strategy involves federal facilities (indirect
source review thereof). The City may wish to consider,a modified version
of this strategy that would require federal financing to meet air quality
standards imposed on the City by the federal government.
#T-9 (Page IX-305): There is no identification of the strategies beyond
acronyms listed. Should be clarified.
CHAPTER X
"SUBREGIONAL PLANS"
This section does not clearly identify how the subregional plans relate to
the AQMP. The matrix developed also does not indicate the type of commitment
-10-
made by the various subregions
are not identified as to
Additionally, the subregional elements
• 1) Who prepared each document?
2) If the subregional element was adopted, and, if so, by whom?
•
3) How much commitment does it -represent?
4) How does what the subregions have approved correspond to
SCAG's preliminary draft?
While we have participated in preparation of the Orange County subregional
element, it does not have City approval, and approval should not be inferred.
CHAPTER XI
9987 EXTENSION"
Page XI=19 "Questions": This section outlines four questions dealing with
transportation issues. The City may need to carefully review SCAG Regional
Transportation Plan and/or modifications suggested within this section to
ascertain what would be consistent with adopted City policy.
CHAPTER XIII
"RESOURCES TO IMPLEMENT PLAN"
This chapter should define the total resources necessary to implement the
plan. While the plan is 2"+ thick, exactly one page is devoted to implemen-
tation. The 'statement that it is premature to consider how the plan
would be implemented in terms of financial resources is not reasonable.
The statement that: "local government will adopt alternate revenue measures"
is also not reasonable and is contrary to the concept of the recently voter
approved tax limitation. Further, the statement that: "the state will
assume responsibility for some functions formerly financed by local govern-
ments," is not necessarily accurate in either the short or long run. Additional-
ly, it suggests usurpation of local control, which is undesirable.
CHAPTER XVIII
"SUMMARY: ENVIRONMENTAL IMPACT REPORT"
The City requests -a copy of the full EIR and any attachment, to be received
at the earliest date possible.
-11-
CHAPTER XIX
"APPENDICES"
It was previously indicated
that subregional
plans were to be attached•.
as appendices to•the AQMP.
As indicated in
our general comments, it is
not clear how local concerns
will be coordinated
and combined into the
plan.
-12-
ORANGE COUNTY ENVIRONMENTAL MANAGEMENT AGENCY
Work Program Description
FY 1979-80 OWP
Task 8010.01
December 20, 1978
Revision and Review of the 1979 AQMP
Task Objective
To revise the AQMP in response to ARB and EPA review comments
and requirements, and to incorporate the results of further
analysis and evaluations.
Previous Work
Preparation of sub -regional AQMP element.
Task Description
o Provide assistance in plan revision process.
o Provide sub -regional review and comment of proposed AQMP
revisions.
o Incorporate public input to plan revision review.
o Incorporate local agency input to plan revision.
o Provide sub -regional assistance to local agencies
(26 cities) through plan revision review and analysis.
o Conduct workshops for city staff contact persons (from
each city in Orange County), for elected officials, and
for the general public.
o Continue assistance to Orange County Air Quality Manage-
ment Plan Coordinating Committee(includes Cities, County
and OCTC representation).
o Prepare a staff analysis with recommendations for the
Board of Supervisors, Orange County Cities, and the
Coordinating Committee.
Products and Schedules
o Updated Subregional AQMP element (April 1980).
Costs
Staff Staff Consultant Total
Months Costs Cost Cost
8 $24,000 0 $24,000
ORANGE COUNTY ENVIRONMENTAL MANAGEMENT AGENCY
Work Program Description
FY 1979-80 OWP December 20, 1978
Task 8010.02
Implementation of the 1979 AQMP
Task Objective
To assist local agencies in implementing adopted measures,
development (OCEMA) of pilot programs and in developing acceptable
alternatives to the adopted measures in the AQMP.
Previous Work
Preparation of sub -regional AQMP element.
Task Description
o Develop commitment agreements from local governments in
Orange County.
o Pilot programs to be conducted by the EMA include programs
related to measures H-4, H-5 and H-23.
o Identify potential alternate measures from among the five
sub -regional AQMP elements.
o Analyze alternative measures to establish emission reductions
equivalent to adopted AQMP measures.
o Assist local agencies in adopting alternative measures
where appropriate.
Products and Schedules
o Commitment agreements (January 1980).
o Report on alternates to adopted AQMP measures (March 1980)
o Pilot Programs reports (May 1980).
Costs
Staff
Staff
Consultant
Total
Months
Costs
Cost
Cost
6
$18,000
$30,000
$48,000
ORANGE COUNTY ENVIRONMENTAL MANAGEMENT AGENCY
Work Program Description
FY 1979-80 OWP
Task 8010.05
December 20, 19781
Reasonable Further Progress (RFP) Reports
Task Objective
To document for the July 1980 "Reasonable Further Progress (RFP)
Report" subregional actions and progress toward meeting RFP
reduction goals.
Previous Work
Subregional coordination of AQMP activities and technical
assistance to 26 cities, County, and special districts.
Task Description
o Develop and maintain an inventory of subregional actions
implementing the AQMP.
o Estimate the emissions reductions resulting from subregional
actions.
Products and Schedules
o Inventory of subregional actions implementing the AQMP
(May,1980).
o Report of subregional actions and estimated emissions
reductions for incorporation in the 1980 RFP report
(May, 1980).
Costs
Staff Staff Consultant Total
Months Costs Cost Cost
6 $18,000 0 $18,000
ORANGE COUNTY ENVIRONMENTAL MANAGEMENT AGENCY
Work Program Description
FY 1979-80 OWP December 20, 1978
Task 8010.06
Localized Air Quality Conditions
Task Objective
To develop more complete information about localized air qulaity
conditions and problems in Orange County.
Previous Work
Task Description
o Model the effects of projected major transportation and
land use developments.
o Field monitor air quality conditions in locations
identified as potential problem areas (SCAQMD task).
o Provide air quality and emissions data for epidemiological
studies to be conducted by Orange County Human Services
Agency, Public Health and Medical Services.
Products and Schedules
o Report on localized air quality conditions and impacts in
Orange County (June, 1980).
Costs
Staff Staff Consultant Total
Months Costs Cost Cost
6 $18,000 $10,000 $28,000
JAN
AQMP approve
and submitted
to ARB
1979
FEB MAR APR MAt JUN JUL
Final edit
Begin
Complete
ARB
of
Addendum
Addendum
submit
AQMP
per ARB
per ARB
SIP to
Changes
Changes
EPA
evelop Reasonable Further
omplete JRFP Repert
RFP report
Submit
rogress Report
RFP through
through
RFP
(RFP)
Report Committee
Committee
Report to
Structure
Structure
ARB
BEGIN
END
I
Complete
E97
2 year work plan 2 yr.
Work Plani
omp ete &
Begin Subregional Plans distribute
Guidelines subregion -
al Plans
Guidelines
omp ete
Begin Technical Component Guidelines Distribute
Technical
Component
Guidelines
AUG SEP OCT NOV
Begin Complete
Addendum Addendum
per EPA per EPA
Chan es Changes
IBegin FY80-81 lComplete
OWP Process I OWP
Begin Implementation Process of AQMP. Complete sche- Continu-
lork with Local Governments to Develop dule of Imple- ing Imple-
chedule of Implementation. Develop mentation. Com- mentation
Substitution of Strategies Policy pplete & Distri- of
9 bute Substitu-
tion of Strate- AQMP
0
1]:Ir'
JAN
FEB MAR APR MAY
1980
JUN JUL AUG SEP OCT
FINAL EDITED Distribute
AQMP AQMP for
Comment
egin RFP Complete RFP Report through Submit RFP
Report RFP Committee Structure Report to
Report ARB
•
LSu
mplete
bregional
ans '81
Complete
Technical
Component
81
r -1
LA
NOV DEC
Begin Subregional Plans
Guidelines
'82
Begin Techinical
Component
Guidelines '82
Begin FY 81-82 Complete
QWP Process FY 81-82
OWP
JAN FEB MAR APR MAY
Submit '81
AQMP to
ARB
1981
JUN JUL AUG SEP OCT NOV DEC
Preparation of
1982
AQMP
Begin RFP Complete RFP Report through Submit RFP
Report RFP Committee Report to
Report Structure ARB
Complete and Distribute
Subregional Plans
Guidelines
Complete
ubregional
Plans
Co lete and Distribute Complete
T icai Technical
Components Guidelines Components
Begin FY 82-83 Complete
OWP Process FY 82-83
OWP
IN,
JAN
MComment
FEB MAR APR MAY
JUN JUL
n
Begin RFP Complete RFP Report Submit
Report RFP Through RFP Report
Report Committee to
Structure ARB
AUG SEP
1983
OCT NOV' DEC JAN
ARB Submit
SIP to
EPA
Begin FY '83-'84 Complete
OWP Process FY '83-'84
OWP
1
n
•
�k
Air Quality Conference Calls for
Changes in Clean Air Act
The Clean Air Act and its supple-
mentary enforcement regulations,
enacted by the Environmental Pro-
tection Agency (EPA), must be
modified to avoid severe national
economic and social disruption,
delegates to the national Air Qual-
ity Conference agreed at the con-
clusion of a two-day meeting held
in San Francisco last month.
Some 400 leading business, labor
and government officials from
throughout the country attended
the conference which featured
speakers, panel discussions and re-
ports on the various impacts of the
Clean Air Act and its 1977 amend-
ments and proposals for a c t i o n
programs to modify the act.
Specifically, the conference fo-
cused on the economic impacts of
complying with the Clean Air Act,
the technical and medical bases for
the national air quality standards
set by EPA, and the processes and
decision -making mechanisms used
to develop metropolitan a r e a air
quality plans.
The conference was co -spon-
sored by the California Council for
Environmental and Economic Bal-
ance (CCEEB), the American Petro-
leum Institute, the Bay Area Coun-
cil, the California Labor Federation,
AFL-CIO, the Coalition of Labor and
Business, the Construction Industry
Advancement Fund, the Internation-
al Union of Operating Engineers,
Local No. 3, and the State Building
and Construction Trades Council of
California.
Those attending the conference
agreed that the meeting was quite
successful in that it clearly articu-
lated the problems inherent in the
Clean Air Act and it focused on a
variety of realistic political and ed-
ucational strategies to achieve
modifications in the legislation.
D u r i n g the meeting, attendees
were told repeatedly that enforce-
ment of the existing legislation and
its supplementary regulations will
halt the nation's economic expan-
sion and could result in the loss of
as many as one -and -one-half mil-
lion jobs.
An underlying theme throughout
the conference discussions w a s
that those seeking changes in the
Clean Air Act must develop more
effective political and educational
strategies than have been used in
the past, if they expect any modifi-
cations to be enacted by Congress.
A number of speakers noted that,
while it is very unlikely Congress
Continued on Page 6
Environment
and the Economy
FEBRUARY 1979 VOL. 6, NO. 2
Georgine, Hawkins Dispute Clean Air Act Impacts
Two sharply conflicting views on
the potential impacts of the 1977
amendments to the Clean Air Act
were aired at the opening session
of the Air Quality Conference.
Robert A. Georgina, President of
the AFL-CIO's Building and Con-
struction Trades Department in
an -
and lead to an unacceptable loss
of jobs.
Georgina said the Building
Trades will fully support 'a bal-
anced approach committed to en-
vironmental goats, but equally
committed to economic growth
and jobs.
Noting that the labor movement,
including the Building Trades, had
supported the purposes of the
Clean Air Act from "the begin-
ning," Georgina said "both from
the public health and the work-
place environment point of view,
It is our members and their fam-
ilies who will realize the greatest
benefits from the act."
However, Georgina noted, there
is a "wide, perhaps unbridgeable,
distance" between supporting the
objectives of the act and agreeing
to the process that has developed
from the 1977 amendments.
any process that "meets its admin-
istrative difficulties with a com-
plete embargo on construction..."
"It is absolutely necessary to
clear smog from the air of Los An-
geles —but evacuation of the city
is not an acceptable solution," he
added.
Georgina said the three primary
problems with the 1977 amend-
ments are Its rigid time limits, an
all or nothing regulatory format
which precludes incremental
gains, and "Draconian" enforce-
ment.
"Just as the quantity and quality
of the air pollution problems vary
by locality, so must the solution
to these problems," he said, add-
ing that it is far more important
to accomplish a steady year -by -
year improvement in air quality
with a program that can absorb
factors of work preservation and
economic growth than to try, and
fall, to meet some "mystic" dead-
line.
A prime example of unreason-
able EPA enforcement procedures,
he said, is the July 1 deadline for
mentatfon Plans (SIPS) for improv-
Ing air quality.
If EPA's proposed sanctions for
states not meeting the deadline are
Implemented, Georgina said, "it
will be an economic catastrophe
f the first magnitude.
"Imagine, if you can, the results
of just the five largest industrial
states failing to meet the ... dead-
line for an approved SIP. One -and -
one -half million building trades-
men out of work and billions of
dollars in production stopped dead
in Its tracks."
Contradicting Georgina was
David Hawkins, Assistant Adminis-
trator for Air, Noise and Radiation
of the federal Environmental Pro-
tection Agency (EPA), the agency
charged with enforcing the Clean
Air Act and its amendments. Haw-
kins argued instead that strict en-
forcement would lead to cleaner
air without anv significant disruo-
jobs.
Instead of joining in a coopera-
tive effort to meet the goals of the
Clean Air Act with minimal eco-
nomic effect, Hawkins said, indus-
try and business groups are try-
ing to thwart any Improvement in
the nations air quality.
"It appears that the new dooms-
day prophets are some business
and industry groups who raise the
specter of economic peril, alleged-
ly caused by our health and social
legislation. The mounting attack on
the Clean Air Act is an example of
these cries of Impending disaster.
"What we are seeing is a pattern
of gross exaggeration and distor-
tion of the act's provisions as part
of a scare campaign to change the
law; legalistic obstruction of the
regulatory process; and, uncritical
use of scientific studies which suit
industry's needs no matter how im-
plausible the results," he added.
Hawkins argued that enforce-
ment of EPA regulations would not
stop economic growth, citing_ the
emission offset ruling, which, -he-
said, allows new construction in
-•"dirty -air- areas"- provided- that
there are "compensating emission
reductions from existing sources
and that emissions from the pro-
pposed new source are minimized
by using very good control tech-
nology."
Noting that claims have been
made that the ambient air quality
standards are unrealistically strict
and should be changed, Hawkins
said "most reviews of the available
data does not support the claim..."
"The simple fact is there will al -
be debates about whether a
given standard is too strong or too
weak. Such debates are fine, but
they should not become an excuse
for doing nothing to reduce exist-
ing health problems. Many cities
are far a.b o v e existing health
standards. Would it really be good
policy to tolerate these conditions
for decades more while we search
for perfection in setting health
-standards
Finally, he warned the confer-
ence delegates that "if you are
looking to Congress for relief,
don't."
"If the intent of this conference
Is to kick off a campaign to dis-
rupt the cleanup effort that is un-
derway by diverting attention to
the legislative arena, I think a ma-
jor mistake is being made. Indus-
try will not have changed the po-
litical context of the policy debate
that raged between 1976 and 1977.
And worse, a renewed debate
risks a slowdown in cleanup ef-
forts that are reasonable and are
what people want ..."
"We at EPA feel bound to re-
sist that kind of slowdown and we
will."
Page 2
40
EPA Changes Ozone Standard
The Environmental Protection
Agency (EPA) has changed its
standard for ozone following con-
tinued criticism that the old stand-
ard was far too harsh, based on
faulty or incomplete data and was
not necessary to protect the public
health.
The new standard increases the
amount of allowable ozone in urban
air by 50 percent, from .08 parts per
million to .12 parts per million.
Francisco last m o n t h. The new
standard was announced only a few
days after the conference conclud-
ed.
Many medical and technical ex-
perts have long maintained that the
EPA air standards are excessively
strict and that they could be in-
creased significantly without harm-
ing the public's health. In fact, nu-
merous experts believe the stand-
ards should be raised to .25 and
Conference
Continued from Page 1
will consider any changes in the act
within the next two years, the legis-
lation could be modified as early as
1981, if the delegates and the
groups they represent work togeth-
er in convincing Congress of the
need for change.
Michael R. Peavey, CCEEB Presi-
dent, said the co-sponsors plan to
follow-up on the conference recom-
mendations by working w i t h t h e
harshly criticized at the national Air no detrimental i m p a c t on public I plementing the suggested political
Quality Conference h e I d i n S a n health. strategies.
California Council for BULK RATE
U.S. POSTAGE
Environmental & PAID
Permil No 10715
Economic Balance San Frepcisco, CA
215 Market St. • Suite 930 San Francisco, CA 94105
Q 1ft�'C�ti(i OF K
Cp"sMUNITY 0-fVF»L0PMC4T.
6360 W nEWP0 'T ,
N"PORT 8CH CA !>2660
Page 6
LUNCHEON TRIO —Listening to speakers at the Tuesday, January 16, luncheon meeting
of the Air Quality Conference were (left to right) Michael R. Peavey, President of the
California Council for Environment and Economic Balance; Robert Krueger, a Texas
businessman and former Congressman; and Thomas McPherson of Florida, a member
of the National Commission on Air Quality. (Photo by Cynthia Johnston.)
Conference Delegates Told
National Coalition Is Needed
A broad -based coalition "for jobs
and profits and a healthy environ-
ment" is essential if industry and
ger, a Texas busin
mer Congressman.
The national coalition concept
was seconded by Michael R. Pee-
vey, President of the California
Council for Environmental and' Eco-
nomic Balance, who, in closing the
conference, outlined various cours-
es of action the delegates could
take in working to modify the Clean
Air Act.
These actions, which Peeve y
noted are not mutually exclusive,
Include:
—working with the National Com-
mission on Air Quality to have in-
dustry and labor's concerns reflect-
ed in the commission's report to
Congress;
—working with Congress for leg-
islative change;
—continue working with EPA and
flexibility in the act's regulations;
—organizing similar conferences
In various parts of the country to
bring concerned people together
to organize programs for action;
and,
—forming a national coalition
which would also pursue any or all
of the other proposed action plans.
Peavey said such a coalition
must be "ecumenical in its nature,
It must be inclusive rather than ex-
clusive. Everybody must be able to
participate; nobody should be ex-
cluded."
Peavey said delegates attending
the San Francisco conference "are
Continued on Page 5
Experts Say EPA
Air Standards Are
Overly Stringent
Excessively stringent air pollu-
tion control standards, set by the
Environmental Protection Agency
(EPA) to implement the Clean Air
Act, cost the nation's industrial
and business sector nearly $9 bii-
ditures, according to Dr. Phyllis
Mullenix of the Harvard University
School of Medicine.
Furthermore, Dr. Mullenix told
attendees at the Air Quality Con-
ferdnce, in setting the air quality
standards, the EPA Ignored major
scientific studies, including those
of its own Science Advisory Board,
which Indicated the public's health
would be protected adequate[
y
with standards which were much
less stringent.
Dr. Mullenix was joined in her
criticism of the air standards by
R. Robert Brattain, an air pollution
control consultant and former
chairman of the Technical Advis-
ory Committee to the California Air
Resources Board.
Brattain said that many scientific
experts were highly critical of the
standards when they were set and
continue to be so.
Mullenix specifically pointed to
EPA's ogle standard, saying the
proposed' TO allowable parts -per
million (from .08 parts per million)
could be increased to .20 parts per
million without adversely affecting
public health.
"The difference in control costs
between those standards is $8.7
billion per year," she said. "That
Is a terrible price to pay for faulty
scientific judgment."
She said that most scientific
data shows that no ill effects have
resulted from exposure to ozone
concentrations below .30 parts per
million, adding that the issue
raises "serious questions about
EPA's commitment to conducting
an objective assessment of the
available scientific evidence."
Furthermore, Dr. Mullenix said,
Continued on Page 5
Page 3
0
Speakers Tell Delegates Facts,
Education Key to Law Changes
If industry and labor leaders want
to achieve significant changes in
the Clean Air Act and its 1977
amendments, they must substitute
reasoned and substantiated argu-
ments for the confrontation tactics
of the past several years, two for-
mer top officials of the Environ-
mental- P_rotection_Agency (E.P A -)-
told the Air Quality Conference del-
egates.
Both William D. Ruckelshaus, for-
mer EPA administrator and current-
ly Vice President of Weyerhaeuser
Company, and John R. Quarles, Jr.,
a Washington, D. C., attorney who
formerly served as Deputy Adminis-
trator for EPA, told the conference
that more facts and less rhetoric
s h o u l d be the strategy of those
seeking changes.
While agreeing that industry and
labor have good reason to criticize
the Clean Air Act as amended and
the regulations for enforcement set
down by EPA, Quarles warned that
continued confrontations with the
EPA, Congress and environmental-
ists will do nothing to enhance in-
dustry and labor's legitimate con-
cerns.
!'I think that most people in the
public are very much in support of
clean air and clean -water_.and._the_
environmental g o a I s, and, at the
same time, they have sort of a
sense that the achievement of these
goals has got to be balanced
against the cost and feasibility,"
Quarles said.
"But, when it comes down to a
heated emotionalized confrontation
to choose between health protec-
tion and the impacts on industry,
the public is going to choose health
protection every time.
"And so, the challenge is how
can the issues be presented to
Congress in an atmosphere that
does not become emotionally super-
charged, so that the practicalities
of administering the program can
be understood, specific problems
can be identified and solutions can
be actually moved through the Con-
gressional or administrative proce-
dures," he added.
Ruckelshaus said all those in-
volved in the Clean Air Act debate
should not consider advocates for
different positions as "the o t h e r
side." This attitude has contributed
Noting that current EPA Adminis-
trator Douglas M. Costle has at-
tempted to minimize confrontations,
Ruckelshaus added that apparently
Costle's attitude has not trickled
down to others within the agency.
He urged environmentalists not
to try to achieve their goals by liti-
gation, but rather to work with in-
dustry and labor within the frame-
work of reasoned argument. He
also warned against viewing the act
as cast in stone, noting that politi-
cal changes might alter the law rad-
ically in the future.
Specifically, Ruckelshaus rec-
ommended that industry and labor
representatives s h o u l d not use
macroeconomic data on impacts of
the act, but, instead, use micro -
economic data. Such data, he said,
should focus on the costs and other
impacts of program implementation
for a specific project.
Narrowing the field of economic
evidence will strengthen the case,
he said, since translation of micro -
economic data into broader macro-
economic forecasts often results in
exaggeration and distortion of evi-
dence.
Ruckelshaus also recommended
that the EPA adopt an educational
posture in its dealings with Con-
gress. The agency should not be
reluctant to point out shortcomings
of the laws it administers and
should offer suggestions for im-
provements. And, in its regulations,
he said, EPA should provide a se-
ries of choices, whenever possible
for those affected to achieve com-
pliance.
Continued on Page 5
Page 4
Ruckelshaus
Continued from Page 4
Quarles said those seeking
amendments to the Clean Air Act
should:
—develop f a c t u a l analyses of
problems and avoid exaggeration
and inflammatory rhetoric;
—develop ways to achieve legiti-
mate environmental g o a l s while
—broaden the base of public un-
derstanding of environmental is-
sues by involving as many groups
as possible in the legislative and
regulatory processes. in this con-
text, Quarles said he was pleased
that organized labor groups were
active in the conference and he rec-
ommended that industry and labor
groups reach out to other organize-
tions—such•as the League of Wom-
en Voters —for Involvement in their
efforts to change the act.
Both speakers cautioned against
expecting any changes in the law
from Congress before 1981 at the
earliest. Ruckelshaus s a i d C o n-
gress might consider amending the
law after it received the recommen-
dations of the -National Commission
on Air Quality, which was formed
by Congress to review the effective-
ness, Impacts and problems of the
act and its -amendments.
California Council for
Environmental and Econotc Balance
Officers
Katherine Dunlap ...........Chairman
William R. Robertson ...Vice -Chairman
Michael R. Peavey ..........President
Robert Shelton ............Secretary
Thomas C. Ellick ...........Treasurer
Environment and the Economy: Pub-
lished monthly by the California Council
for Environmental and Economic Bal-
ance, 215 Market Street, Suite 930, San
Francisco, California 94105. Subscrip-
tion price: $3.00 per year.
Air Standards I National
Continued from Page 3
"recent evidence suggests that
EPA is more concerned with try-
ing to force the scientific evidence
to support Its preconceived no-
tions of where the standards
should be set than with trying to
establish standards which most ac-
curately reflect the scientific evi-
dence,"
EMS air quality control standards
are faulty because they are based
on a zero -risk philosophy.
"We do not have a zero -risk so-
ciety and no one has ever sug-
gested that we pay the price for
one in any human endeavor, in-
cluding health protection, except
for the single case of air pollution
control," Brattain said,
objective of air pollution
he added, should be a
f pollution control which
izes human satisfaction in
with all of the other things
in the environment wnicn also con-
tribute to human satisfaction —
such things as jobs, schools, art
museums and hospitals, for ex-
ample."
Brattain also criticized the fact
that "the agency responsible for
enforcing the standards _sets the.
standards ..."
"EPA owes its very existence to
the fact that there are strict stand-
ards to enforce and they are given
the right to set them as strict as
they want.
"Furthermore, if the AAQS (am-
bient air quality standards) are
violated they are the prosecuting
attorney, the judge and the jury
rolled into one. EPA is not about
to say that the air pollution prob-
lem is less serious than we have
been led to believe and to suggest
that their budget be cut," Brattain
added.
In summary, he said, "a healthy
economy and a healthy environ-
ment are inseparable goals."
Continued from Page 3
not here to participate in or be a
lynch mob to seek the gutting of
the Clean Air Act, but, in fact, to
make the act work better, to make
It more rational, logical and rea-
sonable for all."
He added that "issues such as
the Clean Air Act must be resolved
In the public arena through the po-
volve trade-offs in terms of staking
out what is the public interest, in
terms of the environment, jobs,
economy, unemployment, s o c i a l
status."
Finally, he urged the delegates
to work for a coalition "that is rea-
sonable, that is rational" and, if
such a coalition is formed, "I think
we can succeed in the goals we
have set"
Krueger told the delegates that
"it is Important to every person In
this country that we have a strong
and growing economy."
"if once we get Into a no -growth
posture, what happens to those
minorities, the poor, those who
have not found their way into the
economic mainstream? For some
of us who weren't born poor, we
may be all right. In a no -growth
society we may hold onto what we
have, but if you once stop enlarg-
ing that economic pie, what hap-
pens to the man who is looking for
a chance for a little larger piece
of pie?"
Krueger also urged the dele-
gates to organize a full education-
al effort on the effects of the Clean
Air Act and suggested that both
the Council on Wage and Price
Stability and the General Account-
ing Office should be asked to pro-
vide assessments of the economic
costs of some of the EPA regula-
tions.
Next year, he said, will be a dif-
ficult one for advocates of easing
environmental controls on industry
because it will be a presidential
election year. "Who wants to be
Identified as being anti -environ-
ment, as being for dirty air?" he
asked.
Page 5
• 0 4
THE ORANGE COUNTY AQMP
COORDINATING COMMITTEE
NoVem W Z.
Thursday, 9t�te�eN—�6'; '1978
2:00 P.M.
COUNTY TRANSPORTATION BUILDING
1020 North Broadway
Santa Ana, California
AGENDA
OCT 3' 1970;"
A ¢�y�¢�wpvzi
1. Call to order
2. Approval of minutes of meeting of September 21 and ajourned
meeting of September 28, 1978.
3. Regional AQMP - Final Draft - Staff
4. Other Business
5. Adjournment to Thursday, December 7, 1978, at 2:00 P.M.
County Transportation Building
oFe
o
A ti o LINTY OF (4�
AQMP
FINAL DRAFT AIR QUALITY MANAGOv NT PLAN
The Environmental Management Agency is co -sponsoring a series of workshops in
Orange County on the Final Draft of the Air Quality Management Plan. You can
attend a workshop in your area to voice your opinions about the clean air measures
included in the Draft Air Quality Management Plan. The draft plan has undergone
public analysis to determine the response to the transportation, industrial,
and energy conservation measures being considered for implementation in mid-1979.
The Final Draft which demonstrates that Air Quality standards can be obtained,
lists sufficient measures to reduce pollution to the allowable emissions level,
for this basin by 1987. The purpose of the workshops is to give the public the
opportunity to comment on the measures which have been selected. The comments
received at the workshops will be included in the final plan to be released in
January, 1979.
HUNTINGTON BEACH
Tuesday, November 28, 7:30 p.m.
Basement of the Police Dept.
2000 Main St.
Public entrance south side of bldg.
FULLERTON SANTA ANA
Wednesday Nov. 29, 7:00 p.m. Wednesday Nov.29,,2:00pm
Main Library Board/Supervisors Hearing
353 W. Commonwealth St. Room/County Hall of Admin.
Entrance on Amerige St. 10 Civic Center Plaza
LAGUNA HILLS
Thursday Nov. 30, 7:00 p.m.
Consumer Room, Basement level
Sears Roebuck Store
Laguna Hills Mall
E1 Toro Road
An official public hearing on the Final Draft, together with all comments received,
will be held on Thursday, December 14, 1978, between 9:30 a.m. and 4:00 p.m. in the
Board of Supervisors Hearing Room, County Hall of Administration, 10 Civic Center
Plaza, Santa Ana.
ED
G
De�Y.
�'d- NOV ' 1978D-
01 P CITY OF
,Q NEWPORT BEACH,
CALIF.
G E w �/
11 1 MeV
FINAL DRAFT AIR QUALITY MANAGOVENT PL91
The Environmental Management Agency is co -sponsoring a series of workshops in
Orange County on the Final Draft of the Air Quality Management Plan. You can
attend a workshop in your area to voice your opinions about the clean air measures
included in the Draft Air Quality Management Plan. The draft plan has undergone
public analysis to determine the response to the transportation, industrial,
and energy conservation measures being considered for implementation in mid-1979.
The Final Draft which demonstrates that Air Quality standards can be obtained,
lists sufficient measures to reduce pollution to the allowable emissions level,
for this basin by 1987. The purpose of the workshops is to give the public the
opportunity to comment on the measures which have been selected. The comments
received at the workshops will be included in the final plan to be released in
January, 1979.
HUNTINGTON BEACH
Tuesday, November 28, 7:30 p.m.
Basement of the Police Dept.
2000 Main St.
Public entrance south side of bldg.
FULLERTON SANTA ANA
Wednesday Nov. 29, 7:00 p.m. Wednesday Nov.29,,2:00 pm
Main Library Board/Supervisors Hearing
353 W. Commonwealth St. Room/County Hall of Admin.
Entrance on Amerige St. 10 Civic Center Plaza
LAGUNA HILLS
Thursday Nov. 30, 7:00 p.m.
Consumer Room, Basement level
Sears Roebuck Store
Laguna Hills Mall
E1 Toro Road
An official public hearing on the Final Draft, together with all comments received,
will be held on Thursday, December 14, 1978, between 9:30 a.m. and 4:00 p.m. in the
Board of Supervisors Hearing Room, County Hall of Administration, 10 Civic Center
Plaza, Santa.Ana.
co°Fig-�
NOV6 epr'e�t
mEwp /n o
� cRF�cH,
AQMP
We are pleased to present the Summary of the Draft Air Quality Management
Plan (AQMP) for your review, comment and approval. The Draft AQMP has
been sent to all cities and counties in the South Coast Air Basin. The
review period on the Draft Plan and Draft EIR will close on December 15,
1978. Only comments received by that date will be considered in prepar-
ing the Final Plan and EIR. We request that actions approving or dis-
approving the Plan be taken by your jursidiction and submitted by
January 15, 1978.
This Plan has been prepared in response to Federal and State requirements.
Failure to submit and implement an air quality plan could mean a loss of
much of the region's Federal funds as a result of the sanctions in the
Clean Air Act.
Before the Southern Californai Association of Governments (SCAG) and the
South Coast Air Quality Management District (District) adopt the plan and
transmit it to the California Air Resources Board (ARB) and the U.S.
Environmental Protection Agency (EPA), local governments are asked to
approve the plan. Approval of the Draft AQMP means that the jurisdic-
tion agrees the growth forecasts to be mitigated by the AQMP are those
contained in the SCAG Development Guide, (2) supports the recommended
measures in the plan or recommends substitute measures, (3) agrees to
schedule adoption of local implementation measures and (4) recommends
that SCAG and the District submit the plan to ARB and EPA.
The Draft AQMP recommends air quality policies relating to growth, sewage
treatment plants, highways and air quality standards; reasonably available
air pollution control measures for implementation before 1982; and measures
to be studied by 1982 and implemented afterwards. We have had staff draw
these recommendations from the comments on the Preliminary Draft AQMP which
was published in August of this year. The preliminary plan presented the
results of studying various control measures suggested by cities, and AQMP
subregional agencies, the Districts' Advisory Council, the transportation
commissions, the EPA, the ARB, and others. Even though some of these
measures were not likely to be acceptable to this region, each measure was
reviewed for its impact on our economy, our society, and on reducing air
pollution emissions. Background material and details can be found in the
pull plan (900 pages) and we have mailed a copy to your city through the
offices of the chief administrative officer.
The Draft AQMP has been developed to meet air quality requirements while
mitigating the impacts of growth in the region. If we can accomplish this
goal, the imposition of federal sanctions required under the Clean Air
0 6 r
PAGE TWO
Act Amendments of 1977 can be avoided. These sanctions include reduced
federal financial assistance to the region, as well as denial of permits
for major new industrial applications. These actions, enforceable through
citizens' suits, could cost the South Coast Air Basin upwards of one billion
dollars a year. The document before you is designed to prevent such sanctions
through a reasoned, cost conscious approach to meeting air quality standards
while still permitting economic growth for our region.
An EIR has been prepared by an independent consultant. The EIR Summary is
Chapter XV of the full plan. Copies are available on request.
We seek your approval and request your review and comment on this very
important plan before it must be adopted. Additional information can be
obtained from either the District (572-6377) or SCAG (385-1000) and from
David Di Julio, Program Manager, AQMP, 600 South Commonwealth Avenue,
Suite 1000, Los Angeles, California 90005.
Sincerely,
Al McCandless, Chairman James i son, President
South Coast Air Quality Southern California Association
Management District of Governments
October, 1978
ERRATA
Summarv/Chapter I
1) On page I-9, replace the third policy from the top on Regional Transit
Development with;
o As a part of the FY 79-80 regional planning effort,
SCAG in consultation with County Transportation
Commissions and transit operators, will develop
and document in the RTP a plan for long and short
range public transportation improvements designed
to meet basic public transportation needs. This
plan will be implemented according to the schedule
adopted with that plan.
2) Table VIII (page I-20) shows TSP allowable emissions and AQMP required
reductions only for the case when background concentrations are not
included. Under current EPA regulations, background cannot be deleted
from air monitoring readings -- in this case the allowable emissions
would be 16 (federal) and 7 (state) tons/day; the AQMP required re-
ductions in 1987 would be 269 and 278 tons/day to meet federal and
state standards respectively.
3) In Table IX -A (page I-40), a page with measures 13-23 was inadvertentTy
omitted; these measures are enclosed (page I-40A) with these errata.
� O�C
NLP/ �Fj`
Feq�e�,9,8F
•
•
` Y I
i
Table
IX -A (Contd.)
Imolemeg no Acenc /
Reduction
(Tons/Oay)
Annualized
f
Control Measure Year o?-5malementat1on
8B7T
ost
13.
Emission Controls for
SCAQMD; 1980
0.2
0.2
$207,000
Small Relief Valves (H-19)
14.
Subatitute Coatings Used
SCAQMD; 1982
10.3
12.3
$10,990,000
in Metal Furniture and
Fixtures Manufacturing
(H-20)
16.
Substitute Coatings Used
SCAQMD; 1962
9.3
9.3
$552,400
in Fabrics and Paper
Products Manufacturing
(H-21)
16.
Emission Controls for
PAB; 1980
2.1
12.7
S8,447,000
Lawnmowers and Garden
Equipment (H-22)
17.
Increased Bicycle/
Caltrans, Local
O.8
0.5
S10,500,000
Pedestrian Facilities
Govt., Private
(H-23)
Sedtor; 1980
18.
Imoroved Emission
ARS, Auto Mfg;
--
52.0
S84,775,000
Controls for Motor
1983
Vehicles (H-24)
19.
Reduce Jet Aircraft
FAA, Airport Op_r-
---
0.5
$1,130,000
Queuing Delays (H-25)
a* ors, Airlines;
1983
20.
Substitute Coatings
SCAQMD; 1982
2.6
2.6
3300jOOD
Used in Industrial
Maintenance (H-26)
21.
Substitute Coatings
SCAQMD; 1985
--
2.4
$1,111,000
Used in Ship Construction
(H-29)
22.
Emission Controls on
SCAQMD; 1981
1.4
1.4
$720,000
Gasoline Bulk Plant
Operations (H-29)
23.
Fugitive Emission
SCAQMO; 1980
8.6
8.6
Savings
Controls for Random
Leaks at Refineries
(H-30)
I-40A
PUBLIC MEETINGS
Workshops
All these workshops will discuss the Air Quality Management Plan, 208 Areawide
Waste Treatment Management Plan, SCAG-78 Growth Forecast Policy, Amendments to the
Regional Transportation Plan and Environmental Impact Reports.
Oct. 30 RIVERSIDE COUNTY: 9:00 - 2:00 p.m., Commons, University of California,
Riverside
Nov. 11 LOS ANGELES COUNTY: 9:00 - 12:00 Noon, Rosemead Community Center, 3936
N. Muskatel, Rosemead
Nov. 15 SAN BERNARDINO COUNTY: 7:00 p.m., Lower Commons, California State
College, San Bernardino
Nov. 17 ORANGE COUNTY: 10:00 -•t:00 p.m., Newport -Harbor -Costa Mesa Board of
Realtors, 401 N. Newport Blvd., Newport
Special Workshops
These workshops address the plans as noted:
Nov. 8 IMPERIAL COUNTY: 7:00 - 9:00 p.m., Chamber of Commerce, 1100 Main St.,
El Centro (Development Guide & Amendments to the RTP)
Nov. 14 LOS ANGELES COUNTY: 7:30 p.m., Webster School Cafeteria, 3602 Winter
Canyon Rd., Malibu (water quality)
Nov. 15 LOS ANGELES COUNTY: Pasadena Lung Association 7:30 - 9:30 p.m., Faculty
Dining Room, Pasadena City College, 1570 E. Colorado, Pasadena (air
quality)
Nov. 16 LOS ANGELES COUNTY: 7:30 p.m., Wilson Nigh School Multi -Purpose Room,
16455 Wedgeworth Dr., Hacienda Heights (water quality)
Nov. 28 ORANGE COUNTY: 7:30 p.m., Police Department Basement, 2000 Main St.,
Huntington Beach (air quality)
Nov. 29 ORANGE COUNTY: 2:00 p.m., Board of Supervisors Hearing Room, County
Hall of Administration, 10 Civic Center Plaza, Santa Ana (air quality)
Nov. 29 ORANGE COUNTY: 7:00 p.m., Fullerton Main Library, 353 West Commonwealth
Street, Fullerton (air quality)
Nov. 30 ORANGE COUNTY: 7:00 p.m., Sears Roebuck Consumer Room, Laguna Hilts
Mall, E1 Toro Road, El Toro (air quality)
VENTURA COUNTY: Date and meeting place to be announced. (Development
Guide & Amendments to the RTP)
Hearings
Unless otherwise indicated, hearings are scheduled from 9:30 a.m. to 4 p.m. for
the Air Quality Management Plan and 4-8 p.m. for the 208 Areawide Waste Treatment
Management Plan, SCAG-78 Growth Forecast Policy, and Amendments to the Regional
Transportation Plan. All hearings include Environmental Impact Reports.
Dec. 4 LOS ANGELES COUNTY: Board of Supervisors Hearing Room, 500 W. Temple
St., Los Angeles
Dec. 6 SAN BERNARDINO COUNTY: Chambers of the Board of Supervisors, 175
W. 5th St., 2nd Floor (use rear entrance), San Bernardino
Dec. 8 LOS ANGELES COUNTY: West Covina City Council Chambers, 1444 Garvey
Ave., West Covina
Dec. 12 IMPERIAL COUNTY: Chamber of Commerce, 1100 Main Street, El Centro
(4-8 p.m. only; Development Guide and RTP Amendments)
Dec. 13 VENTURA COUNTY: Lower Plaza Assembly Room, County Government Center,
800 S. Victoria, Ventura (3-6 p.m. only; Development Guide and RTP
Amendments)
Dec. 14 ORANGE COUNTY: Board Hearing Room, 10 Civic Center Plaza, Santa
Ana
Dec. 15 RIVERSIDE COUNTY: Board of Supervisors Hearing Room, 14th Floor,
4080 Lemon St., Riverside
t - ". A
SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
600 South Commonwealth Avenue, Suite 1000, Los Angeles, California
November 1, 1978
The bi-weekly Clearinghouse Listing is distributed to inform your agency of all applications for
federal assistance from our region, in accordance with OMD Circular A-95. Also, the listing
includes state -sponsored plans and projects, environmental documents, and local plans.
The listing is organized by counties. Projects in each county are grouped by type of review
(A-95's; Environmental Documents; State Plans; Local Plans; State -Funded Projects) and funding
sources. Projects which have multi -county impacts that have been identified during the initial
processing of applications have been cross-referenced by county. State plans and other multi -
county plans, projects and proposals are grouped under the Multi -County heading at the beginning
of the listing. Notices of Preparation of Draft Environmental Documents are at the end of the
listing.
Should you wish to indicate the interest of your jurisdiction or comment on a proposed project's._
relationship to comprehensive planning, areawide coordination or environmental impacts, please
contact Mary D. Louie, (213) 385-1000, Extension 369, prior to:
November 15, 1978
SCAG Document: (Type of Review)
SCAG File No. MC-9116-SO
report is the draft air quality management plan for the South Coast Air Basin jointly
submitted by the South Coast Air Quality Management District and SCAG. It has been prepared
pursuant to the Lewis Clean Air Act and the Federal Clean Air Act under the auspices of the
California State Air Resources Board and the U. S. Environmental Protection Agency. The
accompanying environmental document identifies potential environmental impacts. The plan affects
the counties of Los Angeles, Orange Riverside, San Bernardino and 120 cities. Comments are _
requested by December 15, 1978; comments on the plan should be addressed to David Di Julio,
AQMP Program Manager, SCAG, and comments on the EIR should be addressed to Joann Aplet, AQMP
Planning ,Manager, Air Quality Management District, (213) 572-6377.
Southern California Association of
r
MC-9118-SD
Population, Housing, Employment and LandUseForecast for the six counties in the SCAG region-
and
an accompanying environmental document. Comments should be directed to Dennis Masyczek,
Development Guide Program Manager, SCAG, by December 15, 1978.
Southern California Association of Governments MC-9117-SD
Draft 208 Areawide 'Waste Treatment Management Plan &,Draft EIR
Tgi"s report is ffie draft 20$-reawide Waste Treatmenf Management Plan for the South Coast Planning
Area. It has been prepared pursuant to the Clean Water Act and under the auspices of the
California State Water Resources Control Board and the U. S. Environmental Protection Agency.
The accompanying draft EIR identifies potential environmental impacts resulting from the
implementation of the Draft 208 Plan. The plan affects the counties of Los Angeles, Orange,
Riverside, San Bernardino, Ventura and 124 cities. Comments should be addressed to Roger J. Riga,
208 Program Manager, by December 15, 1978.
Oveatar 1. 137i
PagePage 3
t00gT!
A-95: hater Pollution - EPA
State water Resources Control Board RC-3033-wP
Study of water Reclamation in the Chino Basin
Sa25,:00 (Pro, act Cost) I S313,750 (Grant ge)uest) 1 $33,125 (State)
Request fora tep I plan of study for a droject to supply reclaimed water for agricultural
recreational and r4thae9t purposes, The project will demonstrate alternative uses of re-
claimed water to the Chino Basin by expansing the Ely Basin Recharge Program to 3aslns
1 and 2 , construction of a pumping facility, and by fetarmination of the conditions ,nder
wnich reclaimed water Can safer be uSod to recharge the groundwater.
A-95. Aid to aidhways and Jrban Mass Transit - DOT
Southern California Association of Governments
Amendment 42 to 1979-83 Transportation Improvement Program
Attached at the end of the Clearinghouse Listing is Amendment w2 consisting of highway and
transit projects submitted for review by county transportation commissions. P1AG and VCAG.
SCAG Executive Committee will review the projects on 1ovember 2. Corments should be directed
to Oscar Abarca at SCAG.
A-95: ronibus Crime Control Act - OCJP/LEAA
Constitutional Rights Foundation MC-9103-CJ
Delinquency Prevention Education
$IS2,300 / S152,300
Request for funds to establish Youth and the Administration of Justice, a course on the criminal
justice system, and interagency liaison committees to coordinate program cooperation between
schools and justice agencies in 1$ California communities yet to be determined. Ventura,
Orange, San Bernardino and Riverside counties may be included.
A-95: Manpower Programs - OOL
Campesinos Unidos, Inc. NC-9089-MP
Comprehensive Migrant and Seasonal Farmworker Program
$111001300 / $1,100,300
Funds requested to provide 500 farmworkers manpower and supportive serrites, to Include class-
room training, work experience, on -the -jab training, tuition assistance, health radical supple-
mental assistance, nutritional information and transportation. The program series Imperial,
San Diego, Orange, Can Bernardino and Riverside Counties,
A-95: Direct Federal Activity
Department of the Army
MC-8868-OF
Santa Ana River Main Stem - Final EIS
An environmental document has been submitted for a flood control project consisting of (a)
construction of a new reservoir upstream from Prado Dam near the towns of Mentone and East
Highlands; (b) flood plain management of the reach between Mentone Dam and Prado Dam; (c)
Improvement of Oak Street Drain 1n the City of Corona; (d) modification of the existing
Prado Dam and expansion of the existing Prado Reservoir; (a) improvement of the existing
Santa Ana River flood control channel downstream from Prado Reservoir to the ocean,, (f)
improvement of the lower, Santiago Creek Channel; (g) development of water conservation,
recreational and wildlife enhancement facilities In and alongg the above; (h) acquisition
and protection of natural amenities in Santa Ana Canyon; and (i) acquisition and preservat
of a 92-acre salt marsh area for impact mitigation and for protection of endangered specie,
habitats.
A-95: Library Construction and Services -HEW
Public Library Film Circuit MC-9054-LC
Quality Control for Library Films
$65,926 / $11,625
Request funding to establish one central quality control system for interlibrary film loan
program thirteen libraries located in Los Angeles County and two libraries to Orange County.
The project would provide for a mechanical inspection process of 16M films upon their receipt
after each loan.
Inland Library System MC-9107-LC
Inland Library System Interlibrary Loan Project
$44,500 / $44,500
Request for funds to provide support for interlibrary loan functions among eleven member
libraries of the Inland Library System during transition period when statewide location devices
become available. The project will serve Riverside, San Bernardino and Inyo Counties.
Inland Library System MC-9051-0
Alternative Funding of Libraries
S45.000 1 345.100
Request for runat to ni re a grants development specialist to research, identity and submit
project prooasals to private foundations and other alternative sources of funds. Intention it
to demonstrate public libraries need not rely soiey an taxes as their sources of support. Funds
are included for clerical support and instructional materials for the ;nland Library System
Libraries. Note: The Inland Library System is a cooperative system,of eleven public libraries
established under a joint powers Agrearant to serve Riverside, San 2ernardino Ina Inyo Counties.
inland Library System
Inland Library .ystem :hicano Cuitaral :enter
S125,130 / 5125,.00
A new 7,SCO square foot branch library ,ill pe constructed in a Wined netgnoorhOod service
area (NSA) Of the 0ity of San Bernardino. Tnis latiliti respctds to a library needs assessment
Of the Mexican -American carrunity conducted in 1977-73, gequesled funds will provide specialized
staff and materials to develop tais °at'lity as a centellited Service and training unit for the
entire 'niand Library System. ;tote: -^a :^•'and-Torary S; star is a :ooeratlie Salem of eleven
public libraries established ender a ,''oin' ,ewers agree^ent `A serve Riverside, San 3ernari'no
and :nyo Counties.
STATE CAMOL
SACnA>ffiNTO 95814
(916) 44"088
DISTMCT OFFICE
735 W. DD.u= ROAD, S r
it
IC
oOEpcNL
NE�p SO
'I
L. "BILL" RICHARDSON
STATE SENATOR
TWENTY-FIFTH DISTRICT
CHAIRMAN
SENATE REPUBLICAN CAUCUS
COMIInTEES
EI.ECTIONS AND REAPFORtIONMENS
NATDDAL IRESOOECES AND WILDLIFE
REYENOE ANO TA TION
MEMBER ,
SELEET cOm. 3 LE r 4 f A
PENAL Si;T'U}•t0~119 ~-• ••\ J
(
CITY OF
2 Pdi;JOFi zE9CH,
CALi1.
ti
Members of the Newport Beach City Council November 15, 1978
3300 Newport Boulevard
Newport Beach, California 92663
RE: AIR QUALITY MANAGEMENT PLAN
In order to fully comprehend the significance of the goals
and objectives of the Air Quality Management District and the Southern
California Association of Governments and their relationship to the
efforts of federal, state and regional regulatory agencies to restructure
our society, it is necessary to study Governor Brown's Urban Development
Strategy, the California Department of Housing Development regulations,
SCAG's Land Use Element, and the Air Quality Management Plan, and to
project the combined accumulative effect of the implementation of the
proposals contained therein.
Goals and policies which have been adopted by SCAG, ABAG and
other associations of government include controlling the growth of pop-
ulation and of housing units, employment, and land use. They additionally
include control of transportation, environmental management, education
("to achieve curricula to prepare students as complete functioning indi-
viduals in a contemporary society"), control of economic development,
regulation of open space, natural resources and recreation, in order
"to assure that everyone has an opportunity to attain an acceptable
quality of life".
Included in the recommendations and alternatives set forth
in these documents are regulation of the number of vehicles which would
be allowed in a given area; efforts to control the distance people would
be permitted to live from their place of employment; increased population
density by restricting growth; established "incentives" for people to
move back into urban areas; placing a tax or fee on parking facilities
for places of business; regulated business hours; control of transporta-,
tion; controlling the distribution of goods and controlled production.
There has even been a recommendation that persons who intend to take a
trip by motor car be required to check with a government office to
determine if there are people going to the same destination or a desti-
nation en route, and in order to insure full vehicle occupancy such Date-L 7- b
persons would be required to ride together even though they might be : 2L.:':T13:
total strangers.
n.i, •:Y
1 I'
[1
0 0
Re: Air Quality Management Plan Page Two
The average person refuses to believe such measures exist
until they actually read the documents themselves. Since very few
people, including the executive board of SCAG, actually have the time
to read documents such as the Air Quality Management Plan (which is some
900 pages), the Land Use Element, Urban Development Strategy, etc., the
recommendations contained in such proposals are frequently adopted on
recommendation of staff, even though they have far reaching social and
economic impact.
It is my concern that the Air Quality Management Plan will be
adopted in the same manner. Before adopting the AQMP, I feel that
several vitally important questions should be answered. For example:
(1) Is clinical evidence available to prove beyond a reasonable
doubt that there is a direct correlation between the control measures,
air quality and public health?
(2) What are reasonable levels -of air quality that can be
medically justified?
(3) Are present Federal standards aimed at protecting the hyper-
sensitive individual? If so, what percentage of the population is hyper-
sensitive, and do they suffer permanent damage to their health as a
result of present levels of air pollution.?
(4) Are the federal standards adequate to meet health needs. If,
so, why are California standards more rigorous?
(5) The South Coast Air Basin is considered an area of non -attain-
ment. That means the standards cannot be met under any circumstances.
If that is so, what level can we realistically attempt to.achieve, and
what measures would be -considered making a reasonable effort?
SCAG has already implied that they will use their authority to
review requests for Federal funds as a means of enforcing compliance with
what they consider to be reasonable control measures. In their words,
"this Air Quality Management Plan, or AQMP, presents an approach that
brings together both an air quality management agency with regulatory
powers, and land use and transportation planning agencies in a compre-
hensive planning effort."
Failure to adopt the measures which would restructure the life-
style of California citizens will result in the possible loss of Federal
funds. Perhaps the time has come to reevaluate the price which must be
paid in the loss of local control, as well as the right of our cities
and state to determine their own standards, against the benefits derived
from the Federal funds we receive.
Sincere
H. L. "BILL RICH DSON
State Senator
� SEW �kr • ... .
�0 Department of
Community Development
DATE: November •22,. l978
TO: Mayor Ryckoff
FROM: Fred",,�4alaric6
SUBJECT: Staff -comments Draft SCAG-78 Growth Forecast Policy
Summary EIR.
Pursuant -to your request, I have reviewed both your
and the Draft EIR on the SCAG-78 Growth Forecast.
the City may wish to add the following comments to
draft response:
Surface Water Page ':III-23
comments
feel that
your
The discussion of potential impact due to surfifoe water should
include a,di.s,cussion of the San Diego Creek Watershed/Upper
Newport Bay. The.discussion-should include 208 priortization
of this area and .some mention of its' anticipated urbanization
under proposed SCAG-78 and'each alternative.
Transportation Systems Page III-103
The Draft EIR does not adequately address the impact of
SCAG-78 Growth Forecast on the Orange County Transportation
System. A heavy reliance is placed on the Regional Transportation
Plans' implementation, Many measures of this plan may not be
acceptable region wide. Primary concerns deals with RTP proposals
for Central Los Angeles area. The section does not deal with
impacts on aviation facilities (although address potential
mitigation measures) or noise impacts from any transportation
system necessary to support the growth forecast. Due to this
oversight, this section of the Draft EIR is inadequate.
If you have any questions regarding the -above or on the Draft
EIR please contact rye.
Respectful "40�
Fred Talarico
Environmental Coordinator
FT/dt
,
'Y'M
qWcounty of Orange
MN(O 0
TO. AQMP - City Staff Contacts DEPT/DIST:
%
`
P®Faso-i 24
i
DATE: November 28, 1978
FROMgobert Bilbey EMA/AQMP/Transportation Planning
SUBJECT: Draft of County Comments for AQMP
Enclosed is a copy of County Staff's proposed comments on the Draft AQMP for
your review. The next City Staff Contact Meeting will be held on Thursday, December
7, 1978 at 2:00 p.m. at the County Transportation Bldg.
1020 N. Broadway, Suite 100
Santa Ana, Ca.
We would appreciate your comments on the enclosed at this meeting together with
a copy of your citys' official comments on the latest AQMP Draft.
RB:rb
Attachments
o r
av 011xctA,
\ %• N6WP�Ay1F+
00
DATE: November 28, 1978
TO AQMP - City Staff Contacts DEPT/DIST,
FROMgobert Bilbey EMA/A9MP/Transportation Plannin4 _
SUBJECT: Draft of County Comments for AgMP
Enclosed is a copy of County staff's proposed comments on the Draft AQMP for
your review. The next City Staff Contact Meeting will be held on Thursday-. December
7 1978 at 2:00 p.m. at the County- Transportation Bldc.
1020 N. Broadway, Suite 100
Santa Ana, Ca.
a copy- of your cites' offyioial comments on the latest_AQ„Py„Drarft.
RB:rb
Attachments
RECEIVED
NOV291978e*
Mayor
City of Newport
>. Beach
0
DRPFrposes Qnl9
For d�sous
STAFF PROPOSED COMMENTS
FOR THE
DRAFT AIR QUALITY MANAGEMENT PLAN
COUNTY OF ORANGE
ENVIRONMENTAL MANAGEMENT AGENCY
November 27, 1978
RECEIVED
1YOV 2 91978 c.
Mayor
City of Newport
Beach
rrarr
11/16/78
The California Lewis Air Quality Management Act (1976), and the Federal Clean
Air Act (as amended in 1977) set in motion the Air Quality Management Plan (AQMP)
process, an effort designed to achieve a clean and healthful air environment in
Southern California. Through an arduous exercise of analysis and evaluation, review
and comment, the effort has developed a draft AQMP document that responds to the require-
ments of the Lewis Act and the Clean Air Act. This staff recommended plan, and
supporting EIR, is undergoing final review and 'comment prior to formal adoption action
by the SCAG Executive Committee and the SCAQMD Board in January, 1979.
The Draft AQMP is not an implementation or action plan at this stage. It contains
a list of control measures the details of which must be developed and specified prior
to individual implementation. It is'a concept document, basically, which logs the
general foundation for actions to be taken in the next phase of the AQMP.
The County of Orange, as a designated sub -regional AQMP agency, has been involved
extensively in the AQMP process, and the draft AQMP is responsive to many of the concerns
and issues that arose throughout the County during preliminary input, review, and
comment. There are, however, some general and specific issues that remain unanswered,
and, indeed, may be unanswerable at this stage in the evolving AQMP. These comments,
then, may provide something of a foundation for the next cycle in the AQMP process..
GENERAL ISSUES
MEETING STATE AND FEDERAL AIR QUALITY STANDARDS
It is stated policy; "To attain Federal and State Health Standards at the earliest
achievable date." (Draft AQMP, P I-7). This is consistent with Section 40462 of the
Lewis Act which requires compliance with state standards, "...at the earliest possible
date..." Section 172. (a) of the Clean Air Act, however, requires attainment of federal
primary (health related) standards not later than December 31, 1982, with a possible
deadline extension for photochemical oxidant and/or carbon monoxide compliance to
December 31, 1987. With these specific attainment deadlines and attendant federal
funding sanctions, compliance with the Clean Air Act requirements is of principal concern
in the Draft AQMP.
The California Air Resouces Board has determined that the entire South Coast Air
Basin, including Orange County, is in violation of the federal primary standards for
oxidant, CO, NO2, and total suspended particulates (TSP). The Draft AQMP does not
provide for attainment of standards for any of these four pollutants by 1982. It does,
through, provide sufficient measures to attain oxidant, CO, and NO2 standards by 1981.
The draft plan, Chapter XI, contains the required documentation for an extension of
oxidant and CO compliance to 1987. However, the Clean Air Act provides for no such
f
Page -2-
extension in the case of NO2. The plan as proposed, then, places the region in
jeopardy of federal funding sanctions for non-compliance with the NO2 standard by
the statutary deadline. Although open to legal debate, it appears that legislative
relief will be necessary to correct this situation.
Total suspended particulates (TSP) are a special problem in this area. Analysis
shows that despite new, controls on particulate emissions, the standard can never be
attained in this Basin unless there is a change in EPA requirements to permit the
deletion of natural background levels from air monitoring readings. If this change is
made, particulate standards can be attained in 1982 as required by law. Because of• the
Basin's proximity to desert wind blown sand, standards could be violated even if
all man -generated pollutants were removed. Such a change would require administrative
action only. The plan also is required to demonstrate that it is making "Reasonable
Further Progress" (RFP) each year towards meeting the air quality standards. RFP is
defined by the Clean Air Act as annual incremental reductions in emissions for each
pollutant, which are sufficient to attain standards by the required date. The draft
AQMP contains RFP reduction "goals" (P. I-21-25) which apparently fulfill this require-
ment. However, these 'goals" are not'correlated directly in the plan with anticipated
implementation scheduling so as to assess their validity.
Another requirement of the plan, and one which is a potential problem, is that
it must show attainment and maintenance of state and federal air quality standards. Maint-
enance of the standards beyond attainment is not addressed adequately in the Draft
AQidP, a deficiency that ;should be corrected in the next cycle of the AQMP process.
IMPLEMENTATION AUTHORITY/RESPONSIBILITY
The Draft AQMP contains some seventy measures that are recommended for imple-
mentation, and which require a variety of adoption and implementation actions by a
plethora of public and private agencies. Many of the control measures, especially some
of the most effective ones, fall within the.authority of the state and federal govern-
ments. Others are beyond the purview of governments to compell, necessitating reliance
on voluntary compliance by private companies and individuals. in the first instance,
should the state and/or federal governments fail to exercise their authorities to
adopt some of the measures contained in the plan, an additional burden for emissions
reductions will have to be borne by less effective, and more costly and disruptive
lated through the AQMP process, requires a legally
measures. The Clean Air Act, as trans
Is
Page -3-
enforceable local and regional commitment to the plan as a condition of EPA approval.
No such prior commitment is required from higher authorities of government. This .
makes it difficult to evaluate the Draft AQMP, because no indication has been given
that the necessary exercise of state and federal authority will follow local adoption
of the plan. Similarly, "voluntary" measures may not have legal standing to be included
in the plan, making uncertain what measures may have to be included ultimately to
achieve the air quality standards.
Implementation responsibility also is not adequately specified in the Draft AQMP.
Many measures require multi -jurisdictional responsibility for implementation, but the
role and actions of each agency is not differentiated, making it impossible for
individual agencies to comment adequately on measures for which they are only partly
responsible.
STATUS AND STANDING OF SUB -REGIONAL ELEMENTS
Following from the issue of authority and responsibility is the question of what part
the sub -regional elements have had in the regional planning process, and what their
status and standing is to be after adoption of the AQMP.
Reference 'to regional elements as "plans," and incorporation of the elements
in the Draft AQMP as appen$ices lends to them an implied standing that is not warranted
in fact. The elements were developed as an initial screening of actions that local
governments could take'to reduce air pollution emissions. These measures were then to
be evaluated along with all other measures being considered for the AQMP. This initial.
screening and overall evaluation has not been discussed adequately in the plan.
of more importance is the question'of the status and standing of the sub -regional
elements after adoption of the AQMP. The draft correctly states, "The local governments
are participating through the sub -regional planning process in the selection of the most
reasonable measures for the AQMP. If the regional measure is not implementable by the
jurisdiction the option of adoption of tactics which provide an equivalent reduction
for each jurisdiction is available. The Sub -regional plans provide such alternative
measures." (Draft AQMP, P I-33). This is the essential.function of the sub -regional
elements after plan adoption, i.e. a source of possible alternative actions for local
governments. This function must be made absolutely clear in the final plan so that the
sub -regional elements, in and of themselves, do not become an enforceable part of EPA's
approved and published plan.
Page -4-
CONSISTENCY WITH SCAG-78
One stated policy of the Draft AQMP is, "To plan for population and industrial
growth in the region by offsetting the air pollution impacts of that growth."
(Draft AQMP, P I-7). Growth and development were built into the baseline emissions
projection, and therefore the effects of that growth are accounted in the calculation
of emission reductions necessary to attain the air quality standards. To the extent
that actual growth and development are consistent with that used in the baseline
projection, air quality impacts, then, will be mitigated.
The growth and development that have been used in the AQMP baseline projection are
those in the draft revision of the Regional Development Guide, SCAG-78. A commitment
to the AQMP, by extension therefore, is a commitment to allow growth and development
only consistent with SCAG-78. This commitment is both logical and reasonable. However,
the Development Guide is a dynamic tool of regional planning. It is a regional consensus
of how much the area is expected to grow, and where regional•resources will be applied
to support that growth. This consensus, necessarily, is subject to change. A
commitment to the AQDIP/SCAG-78 is more of commitment to change the AQMP to maintain
consistency with base line projections which may change with the evolution of growth and
development as will.be documented in future editions of SCAG-78. This dynamic aspect
of AQMP/SCAG-78 consistency must be explained more completely in the final AQDIP.
ECONOMIC EFFECTS
There are three economic impact issues that, if not neglected entirely, are inade-
quately addressed in the draft AQMP. First, the costs of environmental improvement are
inflationary and i�hey're distributed regressively. The estimated $500 million/year cost
to implement the AQMP will .be borne through the consumer market (90%) and through govern-
ment taxing structures (10%), resulting in a general inflation in the price of goods and
services. This inflation bears most heavily on lower and fixed income groups, and the
magnitude of the burden (estimated at $50/capita/year) warrants more extensive discussion
in the plan.
A second issue is the extent to which small, marginal businesses and industries will
be impacted by the extended SCAQMD rules proposed in the draft AQMP. Small, marginal
operations generally have little pricing flexibility to pass pollution control costs on
through the market. And the added costs of such controls,
1' 1
Draft
11/16/78
if absorbed internally, can determine the very existance of non-existance of the firm.
s the possibility of regulatory relief in such cases, and/or
The plan needs er addres
external funding of controls.
And finally, the economic analysis of the draft plan reliesonannualized
costs
s
for tactic evaluation, anJapproach which is valid over may
be to implement
tends to wash -out the high initial capital costs that may art of overall evaluation.
the tactics. It is important that capital investment be made a p
Fundin
(Comments on funding are being prepared
uality Conditions and Effects
Localized Air 4 '
The draft AQMP is a macro plan and does not account for localized conditions an
effects. Reliance on proportional estimates of basin -wide emissions reductions needed
of ects 'the standards tend to understate the problem. For example Co violations of
in a relatively small area of South Central Los
Federal Standards areirost persistent
2)4y9les County. A proportional reduction of basin -wide CO emissions may not reduce
problem area sufficiently to bring it into compliance with
source emissions in this p NO2 where the problem area tends to be
standards. A similar situation exists for, not be
west Central Los Angeles County• The clean Air Act provides that standards may specific
QMP area.
violated more than once each year at any location in the .ATherefore, sp
problem areas, such as have been noted, must be analyzed in much more detail during
the next AQMP cycle.
Technological Uncertainty_ Mp indicates, in general, that further
The supporting analysis for the draft on productive, cost effective,
s are the
technological controls on sources of emissionStandards moSomething over 2/3 of all
and acceptable way to attain the Air oechnol many cases, however,
tactics recommended in the draft are technological measures. Iin other cases where
ate the development of some future technology• are not
tactics anticipate problems of applying that technology
technology exists to support a tactic, the p acceptability of
discussed. Consequently, the productivity, cost effectiveness, and accep f control
such measures may be over -stated. More work on the technological feasibility Q
tactics needs to be done in the next AQMp cycle.
Draft
11/16/78
Analytical Uncertainty
The evaluation analysis from which the draft AQMP was designed have an
inherent degree of uncertainty that is much greater than is indicated
in bestthat
document. The emissions inventory and forecast, although perhaps t
have been produced anywhere, are calculated rather than measured inventories, and
therefore subject to errors of assumption and calculation. Further, the relative
air quality effects of geogenic (natural) vs. anthropogenic (man-made) emissions
is not understood clearly and is a topic of current professional debate. The
Air Quality Modeling for the draft plan is also subject to a wide range of uncertainty.
Rollback models were used in calculating needed reductions for NO2 and CO, and a
modified rollback applied for particulates. As the plan states,
11 ..rollback models
are not recommended except for preliminary screening purposes." Similarly, the
EDIA model for oxidant is a preliminary tool rather than a firm base for evaluation.
In addition, the estimated effectiveness of the proposed.control measures is also
bability of error, then, is very high, and the
questionable. The compounded pro
valuation needs to be described in detail so that
'uncertainty of the analysis and e
desision makers understand that they are making choices based upon preliminary
information.
SPECIFIC ISSUES
In addition to the general concerns outlined above, the County has a number
of specific comments about the proposed control measures. For purposes of analysis
and discussion, the measures have been grouped into eight categories as shown in
the attached tables.
Draft
11/21/78
MOBILE SOURCE EMISSION CONTROL DEVICES (TABLE 1)
This category of proposed AQMP measures points out the.necessity of state and
federal regulatory action if this region is to attain the federal air quality standards.
These measure, if implemented, will achieve approximately �k of RHC and No. emission
reductions needed to meet federal standards, and over 80% of required CO reductions at
a combined cost of about $200 million/year, or only 1/3 of the estimated annualized cost
of the AQMP. Further, excluding control measure H-64 which produces little emissions
reduction, the least cost effectiveness figures for RHC, NO and .CO are $1,325/Ton,
$1,125/Ton, and $250/Ton zespectively,figures which make these measures highly competitive
among the other proposed control tactics. Based upon the analysis, then, this category
of measures must have a high priority for adoption and implementation. And it must be
made clear to the state and federal governments that this region requires and strongly
supports the ekercise of their authority over this category of AQMP measures.
Specific measures which merit special.support are H-7, H-15, H-16, H-18, 11-24, and .
H-64. Tactic H-18 is the annual inspection and maintenance of all light -duty motor
vehicles. This program, now being phased -in under state legislation, is an EPA require-
ment for the oxidant and.CO compliance deadline extension to 1987. That requirement
aside, the program merits'support as being both productive and cost effective. The
most efficient and effective means of implementating this tactic remains to be
determined, i.e. centralized (Hamilton Test Systems)/decentralized (licensed garage and
gas station) testing. Support of either specific implementation means should be withheld
pending further information.
Control measure•H-16, Modify Jet Aircraft Engines, has been proposed by EPA and is
under review prior to formal promulgation. Considering the extent of jet aircraft
traffic in this basin and the 'indicated emissions reductions, the region should participate
actively in this review to assure that an effective rule results.
Tactic H-24 calls for ARB to impose more stringent controls on motor vehicles, and
corollary tactics H-7, H-15, and H-54 would extend controls to off -road vehicles.
Support for these tactics indicates a willingness on the part of this region to bear the
additional costs of such controls. This willingness must be communicated clearly in
requesting state.action on these measures.
The remaining three measures in this category cannot be supported at this time.
H-6 has safety implications that must be resolved. 1I-22 would effectively legislate
the 2-cycle utility engine out of existance, an engine which is used for reasons of
Page -2-
economy, and ease of operation and maintenance. Phasing out of this engine may not be
desireable in the long -run. And finally, N-13 seems superfluous considering that it
contributes only a 0,4 Tons/Day reduction in NOx emissions.
INDUSTRIAL EMISSION CONTROL DEVICES (TABLE 2)
This category of stationary source tactics requires the development of highly'
specialized control technology and hardware, most of which is not specified in the
tactic descriptions. Eliminating or reducing emissions at their source of origin, -
in general, is the most cost effective and cost efficient approach to air pollution
control. However, the scale and complexity.of this category of controls calls into
question whether or not these measures can be developed and implemented as scheduled
in the draft AQMP.
It is also questionable whether H-90, Future Improvement of Technological.Controls,
should be included in the AQMP as a control measure. Account must be made for evolutionary
improvements in Best Available Control Technology,(BACT). However, it would seem more
appropriate, and less vulnerable to criticsm, if it were credited as part of the emissions
projections.
INDUSTRIAL OPERATIONS & MAINTENANCE TACTICS (TABLE 3)
This group of tactics produces a total reduction in RHC of 24 Tons/Day at an
aggregate cost effectiveness of $2700/Ton.• Enforcement of these measures, however,
is questionable. The SCAQMD is understaffed to adequately inspect permitted sources'
and devices now. Adoption of these measures would require -considerable additional
staff resources to monitor on -going operation and maintenance for compliance with new
control rules. No estimate of,'this additional resource commitment is made in the draft
AQMP. These measures cannot be supported without such an estimate.
ORGANIC BASE CONVERSION TO WATER BASE SOLVENTS/FORMULATIONS (TABLE 4)
The conversion from various organic base formulations to water base, as proposed
in this group of control measures, would yield a combined total RHC reduction of 90
Tons/Day or almost 1/3 of the reduction necessary to attain federal standards, at an
aggregate cost effectiveness of $1615/Ton. However, two concerns must be addressed in
the AQD1P before these measures can be supported categorically. First, possible water
iv r
page -3-
quality impacts of these tactics have been ignored. The chemical compositions of water
based formulations, especially paints, include heavy metals and heavy metal compounds
which could conceivably enter waste water systems in sufficient quantities to create
treatment problems. This possibility needs thorough examination. And second, conversion
to water based formulations could place Southern California industry at a competitive
disadvantage in national markets. For example, federal contract specifications for
paints typically call for organic base formulations, and a local contractor could be
excluded from bidding by not being able to meet specifications. Or, the market for some
industrial goods and services (such as marine coatings) might simply move out of the
region (in this case, perhaps to San Diego) to avoid the conversion. In any case,
there are some potentially significant economic impacts'of these measures that have not
been discussed in the draft plan.
AIRCRAFT OPERATIONS -(TABLE 5)
(The Orange County Airports Division is preparing comments on this category of
control measures).
PJ
Draft
11/21/78
Reduced Auto Travel (Table 6)
The control tactics in this category have general local government support
as evidenced by the fact that they are contained in the Orange County preliminary
sub -regional AQMP element and they are being implemented, to one degree or another,
throughout the County. However, approval of these tactics as AQMP measures cannot
be given without further specification of the role that local governments are to
be assigned in implementing these multi -jurisdictional measures. In addition, more
information is required as to how and at what scale each measure will be implemented.
EnploXees Ridesharing Program
Measure H-34 and supporting measures H-4 and H-5 are based on an objective of
increasing average work trips auto occupancy from a current figure of approximately
1.2 persons per vehicle to 1.3 persons per vehicle. This objective translates into
require "capture rates" of 3+ person carpools (or their equivalent in terms of van -
pools, buspools, or taxipools). However, the description of H-34, does not specify
what the program is to be, although an annualized cost of $38 million is estimated
to implement it. At a minimum, an outline of the "program" is required prior to
approval.
Similarly with H-13, Voluntary Trip Reduction, the measure description specifies
only that a $5 million per year media campaign will be launched, ,...to promote the
regional goal of improving air quality through voluntarily curtailing increases in
automobile trip making." This goal, or objective is not translated into any program
that can be approved at this time. The same is the case with H-23/27, Increase
Bicycle/Pedestrian Facilities. Expansion and/or improvement of bicycle and walking
facilities are on -going throughout Orange County. Without some specified degree of
"increase," any additional requirement for 'local commitment is unclear, and approval
must be withheld pending clarification.
Transportation System Improvement/TSM (Table 7)
As with the tactics to reduce auto travel, H-35, Traffic Signal Synchronization
is consistent with the orange County preliminary sub -regional AQMP element and is
being implemented county -wide where warranted by traffic conditions and available
funding. Again, however, approval of H-35 as an AQMP measure is contingent upon
more project specific information as to where the "6600 high volume intersections"
are located, phasing of implementation, and available funding.
Draft
H-89 Transit Improvement also is not sufficiently defined for approval at this time.
Control tactics H-85, H-86, H-87 and H-88 cannot be supported by the County
of Orange as AQMP measures. These are high capital investment projects with little
positive impact on air pollutant emissions. Inclusion of these measures in the
AQMP could mean priority diversion of scarce funds from other regional transportation
needs. As is stated in the discussion of each of these measures, they, ..will be
implemented for reasons other than air quality." Therefore, they should compete
for transportation funds based only on their merits as transportation projects-.
Any air quality benefits to be realized are secondary and should not be given
priority consideration in capital investment decisions.
Miscellaneous (Table 8)
The three RHC reduction measures in this category are supported by the County.
However, this support must be qualified in the case of F-36, Voluntary Retirement of
older Cars. Delay in implementing this tactic reduces its effectiveness as these,
high polluting vehicles are phased out of the fleet inventory by attrition. it
seems doubtful that the statutory mechanisms for this measure can be in place for .
scheduled 1980 implementation, and postponement,of this program beyond 1980 will
seriously degrade its usefulness.
The County also supports the NOX tactics in this group, especially the energy
conservation measures N-1 and N-2. The County has established an Energy Committee,
part of whose charge is a study of energy conservation. Their findings, and
consequent local actions, are expected to complement and/or supplement the Commercial,
instutional and Industrial Audits, and the Residential Retrofit called for in the
draft AQMP.
TABLE 1
MOBILE SOURCE EMISSION CONTROL DEVICES
Tactic
H-6 Modify New Gen. Aviation Aircraft Engines
H-7 Emissions Standards, New Non -farm, Off -road
Heavy Duty Vehicles
H-15 Emission Standards for New Farm Equipment.
H-16 Modify Jet Aircraft Engines
H-18 I/14
H-22 Emission Controls, lawn mowers & Garden Equipment.
H-24 Improved Emission Controls for Motor Vehicles
H-64 Apply On -Road Motorcycle Emission Standards to
Off -Road Motorcycles
N-13 Retardation of Fuel Injection Timing for Marine
Diesel Engines
Emission Reduction (1987)
RHC NOX CO PART 502.
5.6 (+3.5) 97.6
5.7 28.3 72.6
1.9
0.7
18.2
21.4
0.8
29.5
61.7 .
66.6
500
12.7
1.2
116.3
52.0
83.4
561 20.6
2.6
2.8
0.4
163.6 177.9 1398 20.6
0l
TABLE 2
INDUSTRIAL EMISSION CONTROL DEVICES
Tactic
Emission
Reduction (1987)
H-46
Chemical Manufacturing
RHC
NOX CO
PART
SOZ
1.4
H-47
Paint Manufacturing
1.4
H-48
Rubber Products Manufacturing
1.1
H-57
Pharmaceutical Manufacturing
0.6
I-I-90
Future Improvement of Technological Controls
33.0
33.0
N-7
Emission Controls on Cement Kilns
8.6
55.0
3.8
N-8
Emission Controls on Medium and Small Steam
Generators
12.3
N-9
Emission Controls on Gas Turbines
3.0
N-10
Emission Controls on Industrial Boilers
26.9
N-11
Emission Controls•on Refinery Heaters
49.5
N-14
Emission Controls on Glass Melting Furnaces
5.9
N-16
Emission Controls on Stationary Internal
'
Combustion Engines
9.5
'
P-3
Filter Dust from Pharmaceutical Mfg.
0.4
P-4
-Filter Dust from Rubber Products Mfg.
2.7
S-1
Petroleum Coke Calcining-80% Reduction
.9
1717.
S-3
Fluid Catalytic Cracking-70% Reduction
410
S-4
Refinery Fuel Burning Sources
5.5
S-5
Sulfur Content of Diesel Fuel
19.9
S-6
Electric Power Generating Equipment-60%
Reduction
135.0
37.5
143.9 0
274.3
11.7
10
TABLE 3
'INDUSTRIAL OPERATION & MAINTENANCE TACTICS
Emission Reduction (1987)
Tactic
" RHC NOX CO PART S22-
0.5
H-9
Leaky Process Systems, Non Refinery
0.2
H-19
Relief Valves
1.4 "
H-29
Gasoline Bulk Plants
8.6
H-30
Refinery Fugitive Emissions
"
5.6
H-42
Metal Cleaning
0.9
H-56
Oil Tank Cleaning
6.7
H-62
Marine Vapor Recovery Operations
23.9 0 0 0 0
0
0
TABLE 4
ORGANIC BASE CONVERSION TO WATER BASE SOLVENTS/FORMULATIONS
Tactic
H-20/32
Metal Parts & Products Mfg.
H-21/40
Fabric & Paper Product Coatings
H-26
Machinery Maintenance
H-28
Marine Coatings
H-31
Magnetic Wire Coatings
H-37
Automobile Coatings
11-39
.Metal Coil Stock Coatings
H-43
Printing Operations .
H-44
Cut Back Asphalt
H-45
Furniture Coatings
H-54
Automobile Refinishing
H-59
Basic Wood Furniture Coatings
H-65
Aerospace Coatings
Emission Reduction (1987)
RHC NOX CO PART
28.3
9.3
2.6
2.4
1.2
6.3
8.4
14.9
4.3
2.7
6.3
3.2
0.7
90.6 0 0 0
S�
[i7
•
0
TABLE 5
AIRCRAFT OPERATIONS
Tactic
Emission
Reduction (1987)
RHC
NOX CO
PART
H-1
Increased Air Passenger Load Factor
0.9
2.2
1.0
H-2
Jet Aircraft Ground Taxi Operations
2.7
14.2
6.6 .
H-25
Reduce Jet Aircraft Queing Delay
0.5
2.3
1.1
4.1
0 18.7
8.7
S02
0
•
$ABLE 6
'REDUCED AUTO TRAVEL
Tactic
Emission
Reduction (1987)*
RHC
NOX
CO
PART S02
H-4
Modified Work Schedules
3.4
2.4
29.2
0.2 .
H-5
Parking Management Carpool Preferential Parking
0.3
0.4
2.6
0.1
H-13
Voluntary Trip Reduction
11.3
13.7
92.6
1.8
H-23/27
Increase Bicycle & Pedestrian Facilities
0.5
0.4
5.0
0.1
H-34
Rideshare Program
6.6
8.0
54.4
1.4
22.1
24.9
183.8
3.6 0
* Corrected for the Inter -relationships among tactics.
•
TABLE 7
TRANSPORTATION SYSTEM IMPROVEMENT/TSM
Tactic
H-35 Traffic Signal Sync.
11-85 Freeway Transit & Carpool Exclusive Lanes
H-86 Wilshire Rail Line
H-87 LA Downtown People Mover
H-88 Congestion Relief/Fwy Widening
H-89 Transit Improvement
* Corrected for the Inter -relationships among tactics
Emission
Reduction (1987)*
RHC
NOX CO PART S02
0.9
(0.3) 8.7
1.8
2.1 14.2 0.2
0.3
0.4 2.4
0.1
1.0
1.9
(+0.1) 15.8
0.6
0.8 4.8 0.1
5.6
2.9 46.9 0.3 0
•
TABLE 8
,MISCELLANEOUS
Tactic
_
Emission
Reduction (1987)
RHC
NOX
CO
PART S09
H-11
Electrify Rail Yards
4.4
17.7
7.3
1.3
•
H-36
Voluntary Retirement of Old Cars
9.2
1.9
'76.8
H-72
Improved Trucking Efficiency
4.1
9.7
38.0
0.9
N-1
Energy Conservation: Commercial,
20.9
Institutional & Industrial Audits
N-2
Energy Conservation: Residential Retrofit
10.7
N-5
Alter Design of New Residential Space
15.8
Heaters
N-6
Alter Design of New Residential Water _
3.7
Heaters
P-9
Control Dust Emissions from
31.5
Construction and Demolition
•
17.7
80.4
122.1
33.7 0
I
PROPOSED CONTROL MEASURES
TACTIC CATEGORY
1) Mobile Source Emission Control Devices
(9 measures)
2) Industrial Emission Control Devices
(19 measures)
3) Industrial Operation & Maintenance Tactics
(7 measures)
4) Organic Base Conversion to Water Base
Solvents/Formulations (13 measures)
5) Aircraft Operations
(3 measures)
6) Reduced Auto Travel
(5 measures)
7) Transportation System Improvement/TSM
(6 measures)
8) Miscellaneous
(8 measures)
EMISSION
REDUCTION
Tons/Day
(1987)
RHC
NOX
CO
PART
163.6
177.9
1398
20.6
37.5
143.9
0
11.7
23.9
0
0
0
90.6
0
0
0
4.1
0
18.7
8.7
22.1
24.9
183.8
3.6
5.6
2.9
46.9
0.3
•17.7
80.4
122.1
33.7
TOTALS 365.1
430
1769.5
78.6
SR
0
•
274.3
0
0
0
0
0
0
274.3
Tons/Day.
• 4
THE ORANGE COUNTY AQMP
COORDINATING_ COMMITTEE
Thursday, November 30, 1978
2:00 P.M.
COUNTY TRANSPORTATION BUILDING
1020 North Broadway
Santa Ana, California
AGENDA
b�Y RECEIyED
\> DConl i ,p
L
"I"yfl.n
etnyt
1978tS ,
TBFEACH'LIF.
1. Call to order.
2. Approval of minutes of meeting of September 21, adjourned meeting
of September 28, and meeting of November 2, 1978.
3. Regional AQMP - Final Draft - Recommendations.
4. Other Business.
5. Adjournment to Thursday, January 18, 1979, at 2:00 P.M.,
County Transportation Building
Note: Minutes of meetings are being sent out from EMA office.
RECEIVED
NOV281978►
Mayor
City of Newport
a Beach �`
R. E. THOMAS
COUNTY ADMINISTRATIVE OFFICER
COUNTY ADMINISTRATION BUILDING
515 NORTH SYCAMORE STREET
SANTA ANA. CALIFORNIA 92701
TELEPHONE: D34-2345
AREA CODE 714
4-B5
COUNTY ADMINISTRATIVE OFFICE
November 28, 1978
TO: Supervisor Anthony, 1st District
SUBJECT: AQMP Issues
1. General .
1) Section 172(b)(7) of the Clean Air Act requires the nonattainment
plan to "identify and commit the financial and manpower resources
necessary to carry out the plan provisions required by this sub-
section."
Section VIII.2 of the AQ14P outlines eleven measures -included in the
plan that -will require changes in legislation and/or changes in
administrative codes or regulations. Of these, six measures require
state action, four require federal action, and one requires either
local, state and/or federal action.
In that the District cannot commit state nor federal financial and
manpower resources these measures might be taken out by either ARB
or EPA. This may result in local government having to unnecessarily
consider measures which are unacceptable to them or submit a "shortfall
plan" to' ARB.
It must be kept in mind, however, that the State Air Resources Board '
has the authority to amend our AQMP: In that stringent measures are
required to meet the 1987 timeline; ARB may adopt measures (not
including land use) which are unacceptable to local government and
'require us to implement them. Our only recourse'at that point would
be to take the matter to court.
2) Section 172(b)(10) - This section requires that we "include written '
evidence that ...the general purpose local government or governments...
have adopted by statute, regulation, ordinance, or other legally
enforceable document, the necessary requirements and schedules and
timetables for compliance, and are commited to implement and enforce
the appropriate elements of the plan."
Supervisor Anthony
November 28, 1978
Page 2
The required schedules and timetables for compliance and the commit-
ments .to implement and enforce at least some elements of the plan are
embodied in the 208, RTP, and SCAG 78 reports. These documents will
not have been adopted.by January 31, 1979. Therefore, there can be no
commitment by local government to implement those measures in the AQMP
which relate to these documents.
When adopting the AQMP,'are we nonetheless commiting this basin to.the
policies. of the 208, RTP and the Development Guide? What is the
relationship between the AQMP adoption and the "other" plans? Do not
the "other" plans represent this basin's commitment as required in
Section 172(b)87) of the Clean Air Act?
Further, we cannot reasonably expect any of the cities or counties
in this basin to'adopt any portion of'the Plan until it is adopted.
As the schedule stands now; the Plan is to be -adopted by January 31,
1979 and sent forthwith -to ARB..
Thus we are forced into a situation in which a Plan will be sent
to ARB which has not received the commitment, by resolution, etc.,
of local government..
This will require us, other counties and cities, to send letter's
of commitment after the Plan is adopted and sent to ARB. The District
and SCAG would be placed in a rather uncomfortable position of having
to represent to ARB that the adopted Plan will receive the support
•of local government. A goal which may be hard in fact to achieve..
3) Implementation cost estimates are inadequate..
4) There has not been sufficient time to integrate the component parts
(208, AQMP, Housing, RTP, SCAG 78) into what is essentially a 10
year growth plan for the basin.
II. Regional Transportation Plan
1) Section 176(d) of the C1ean.Air Act requires Each department, agency,
or instrumentality of the Federal Government having authority to
conduct or support any program with air -quality related transportation
consequences shall give priority in the exercise of such authority,
-consistent with statutory requirements for allocation among States or
other jurisdictions, to the implementation of those portions of plans
'prepared under this section to achieve and maintain the national
primary ambient air quality standards. This paragraph extends.to,'but
is•not limited to, authority"exercised under the Urban Mass Transpor-
tation Act, title 23 of the United States Code; and the Housing and
Urban Development Act."
By having some transportation capital projects in the AQMP are we to
understand that these projects are therefore ascribed some higher
priority than those in the•RTP?
Supervisor Anthony • "
November 28, 1978
Page 3 . •
2) Regional Transportation, Maintenance, Development and Air Quality
Control Measures (1979-1988, Page XIII.6). "In all, the public sector
faces unfunded costs of $3.5 billion for system development and main-
tenance, and $1.4 billion for mobile source control measures. An
additional $2.3 billion in mobile source measures is assumed to be.
borne by the private sector."
The system maintenance and development costs through 1988 are projected
to be $18.4 bilion while the revenues are projected to be $15.1 billion,
a shortfall of $3.3 billi'on, This does not even include the required
$1.6 billion needed to fund the public sector transportation control
measures nor the $2.3 billion that the private sector will be tabbed for.
Unfunded through 1988
$3.5 billion - system development and maintenance
+1.4 billion - mobile source control measures
$4.9 billion - shortfall 1979-1988
+2.3 billion - direct costs to private sector
$7.2 billion r Total additional funds required 1979-1988
"Unless additional funds are generated or costs are reduced as a result
of either projected delay or withdrawal, unfunded public sector costs
will total $4.9 billion.." (page XIII.24),
Accordingly, the Plan recommends a combination of tax increases and
reallocation of currently unavailable funds to•finance both the mobile
source control measures, and transportation system development projects.;
The Plan proposes using a "Gas Tax Indexing" system within the district.
An indexed regional gasoline tax would link tax increases to some
price index e.g., wholesale, consumer, or possibly highway construction
(I do not understand that last one).
With regard to currently unavailable funds the Plan supports a "fair
share" return of highway capital funds and maximum federal contribution
for transit capital projects.
There may be problems with both of these funding recommendations which
may result in our having to drop those capital intensive projects from
the Plan.
First, we should give serious consideration to Governor' Brown's campaign
statements indicating that he will not increase taxes of any manner, -
shape or form. Presumably, this would include gas taxes. If the
Governor means what he says,' then the projected $1.6 billion from this
source cannot be counted on.
Secondly, while the "fair share" concept sounds great for those of us
in Orange and Los Angeles Counties, it probably does not sound that
great to the State and other counties when it comes to paying for those
roads used by Orange and Los Angeles Countians enroute to Las Vegas,
Supervisor Anthony
November 28, 1978
Page 4
Lake Tahoe and Mommoth. Thus,'it is reasonable'to expect strong
opposition to any move to divert additional funds to this area. Further,
the State has shown a marked propensity for holding onto State Road
Funds in an apparent attempt to slow down freeway construction.•
No matter how the additional funds are ultimately provided for, neither
the AQMP nor the ARB's SIP can commit the State Legislature to increasing
State taxes. Thus we may have to limit the Plan to those measures
for which funding is:provided for under existing law.
While the narrative for H-18 (Annual Inspection and Maintenance of -
Light -Duty Vehicles) does not recommend the use of "loaded" tests; the
Recommendations for New Legislation, Section XIII.2 of the AQNMP does.
Testing vehicles in the "loaded mode" has not been demonstrated -to be
cost effective. Further, an ARB report recommended against the use of
a "loaded mode" -test system in its program-. The "loaded mode" recom-
mendation should be deleted.
is in the RTP "baseline"?
do we agree with it?
does OCTD agree with it?'
does the Orange County Transportation Commission. agree with it?
implementation timetable provided for in the RTP realistic?
Development Guide
What is the requirement going to be, if there is one at all, for local
government to adhere to these projections?
If the LA/OMA project for the desert is not approved in 208,•what .•
does that do to our population projections - reduce or postpone them?,
What are the impacts on the AQNIP of changing the Guide at this late date?
K. Paul Raver
Senior Administrative Analyst
�a�'E° �^sky �� � N.,1:1 •/,,�'.F �( f
UNITED STATES ENVIRORN GEONTX L PROTECTION�AG F MV 3o f9�8
215 Fremont Street
San Francisco. Ca. 94105 �. �NrHONY
NOV 241978
Mr. Phillip L. Anthony
Supervisor, First District
Orange County Administration Building
P.O. Bost 687
Santa Ana CA 92701
Dear Supervisor Anthony:
We have received and reviewed'the Orange County Air Quality
Management Plan. The plan demonstrates the county's commit-
ment to comprehensive planning, both in its presentation of
innovative control strategies, and in the level of planning
expertise that it exhibits. There are, however, a few
critical issues which need to be discussed in more detail.
Transportation:
Page III of the Plan states that "The authority of local
governments to directly impact transportation sources of
pollutants is limited mainly to parking regulations and
traffic controls." This statement appears to be contradictory
to transportation strategies contained in the plan such as
encouraging higher occupancy vehicles, and implementing
staggered work hours.
Page 17 of the Plan states that "The Air Resources Board has
sole authority over mobile source and emission control
devices, including authority to require inspection/maintenance
(I/M) of these devices."
Although the State has primary responsibility for implementing
such a program, local governments have an important role to
play in I/M, by actively supporting passage of the enabling
legislation, and fostering an atmosphere of public acceptance.
The Board of Supervisors, as well as individual City Councils,
should consider adoption of resolutions advocating the I/M
program, and forwarding these resolutions to both the Southern
California Association of Governments (SCAG) and the South
Coast Air Quality Management District (SCAQMD), as designated
lead agencies for nonattainment area planning as well as to
the California State legislature.
-2-
Planning Process:
The extensive scope of the strategies described in the Plan
is commendable. However, it is not clear from discussions
on page I of the plan when legally enforceable commitments
necessary to ensure implementation, of the plan will be
secured, as required by Section 172(b)(10) of the Clean Air
Act (CAA). The Act also requires that these commitments
include an allocation of financial and manpower resources
necessary to implement the plan.
The plan mentions various intergovernmental structures which
have been used to integrate water quality and transportation
planning, with general plan development. We would like to
compliment you on your use of the these planning structures,
and would appreciate details of these communication processes.
The plan also indicates that public involvement through the
use of citizens groups, workshops, and public hearings is a
priority in Orange County. We would like to be kept advised
as to how this process operates, and how successfully it is
functioning. The plan must document the public participation
process, including a record of public comments along with
the subject and outcome of these workshops and public hearings.
If you have any questions, please do not hesitate to contact
me, or Mary Ann Grasser of my staff, at (415)556-8064.
Sincerely,
i-w-%-9ohn Wise
Chief, Planning Branch
Air and Hazardous Materials Division
cc: Dave Becker, ARB
r County of Orange
DATE:December 1, 1978
TO, AOMP - City Contact Staff DEPT/DIST: EMA/Transportation Planning
FROM: Robert Bilbey
SUBJECT: Changed time for 12/7/78 Meeting
Please note the meeting of AQMP City Staff Meeting sek� -7/a8
2:00 P.M. has been changed to 9:30 A.M.: 12/7/78 due to a 208 Meeting conflict.
i
RECEIVE6�
Co-,, nrty
D..•^ ' -,.meek
U"Pt,
DECK 1978m--
CITY OF /
NEWPORT BEACH,
CALIF. (�
. • December 6, 1978
DRAFT
AIR QUALITY STAFF REPORT
AND
RECOMMENDATIONS
The draft Air Quality Maintenance Plan which we are currently reviewing
is a very comprehensive document in response to the California Lewis
Air Quality Management Act of 1976 and the Federal Clean Air Act as
amended in 1977. This Plan is undergoing its final review and comment
prior to a formal adoption early in 1979, The review period for this
draft Plan will close on December 15, 1978.
It is understood that failure to adopt and implement an Air Quality Plan
could mean a loss of much of the region's federal funds as a result of
the sanctions contained in the Clean Air Act. Dave Di Julio, Program
Manager of AQMP, indicates that in fact the sanctions might be more
severe if the region were not to submit an adopted Plan than they would
be if a Plan were adopted but not implemented. This may well be the
case, but the Staff takes little comfort in this kind of reasoning when
it comes to recommending the adoption of a Plan with too many unknowns
that may not be cleared up for some time to come.
Our City Council, as well as other governmental jurisdictions, have been
asked to approve the Plan by January 15, 1979. Approval of the draft
AQMP means that the jurisdiction:
1. Agrees to the growth forecast contained in the SCAG
Development Guide expected to be mitigated by the AQMP.
Supports the recommended measures in the Plan or recommends
substitute measures.
Agrees to schedule adoption of local implementation measures.
4. Recommends that SCAG and the district submit the Plan to
ARB and EPA.
It is recognized that the draft AQMP has been developed to meet air
quality requirements while mitigating the impacts of growth in the
region. For the economic sake of the region as well as the nation,
developing a Plan that will clean up our air on a schedule that will
not require imposition of federal sanctions required under the Clean
Air Act, is a laudible, if not necessary, goal. However, just as the
region is concerned with the loss of federal dollars through sanctions,
the region is also concerned with the cost of implementing the Plan.
The draft AQMP is perhaps the most comprehensive air quality plan developed
in the world, and it must be noted that our region has been in the business
of cleaning up air since 1940's. There are, however, some general and
specific issues that remain unanswered that cause us to have grave concern
that the City of Orange can, in fact, approve the AQMP under the terms
enumerated under the meaning of approval, as indicated above.
The Plan is composed of a list of control measures to reduce the various
air pollution elements in the basin. Asa follow-up of the staff report
dated September 22, 1978, the City Staff has evaluated each of the control
measures, and attached is a list of five categories of control measures
which the Staff is recommending that the Council transmit to SCAG as those which
the City Council can support. Thus, these lists contain the hydrocarbon,
NOX, CO, Suspended Particulates, and S02 control measures which the Staff
feels are cost effective, socially, politically, and economically acceptable,
and have a likelihood that technological improvements are achievable. We
also feel that there is adequate information in regard to impacts and cost
implementing these measures now provide.
In addition to listing the control measures, the list includes a measure
of cost effectiveness in the form of a calculation of the dollars per ton
and the anticipated 1987 reduction in tons per day; and finally, the
annualized cost of the measure.
The Council will note that there are certain measures, such, as H-23, 34
and 35, which have a high cost effectiveness but were included in the list
by the staff since we felt that they were programs which should, and are,
being carried on by local agencies. These measures are (H-23) Increased
bicycle/pedestrian facilities, (H-34 Ride/share Program, and (H-35) Traffic
Signal Synchronization.
A key area of disagreement by the Staff of measures contained in the Plan
for other than air quality reasons involve H85, H86, H87, H88 and H89, which
were said to be included because they are part of the Regional Transportation
Plan. These high capital cost projects which show little air quality improve-
ment, if included in the Plan, will reduce scarce funds needed for other
transportation projects. It is our recommendation, therefore, that they
compete for those funds on their transportation merits rather than as air
quality projects.
Furthermore, the Staff takes issue with much that is contained in the
Regional Transportation Plan, which provides much of the policy guidelines
utilized in AQMP, and recommends that the AQMP develop a measure that would
provide more transportation corridors within the areas shown to be supporting
the most growth in the region (see Addendum No. 2 attached hereto.)
-2-
H-49 - "Substitute Coatings Used in Meta-1 Parts and Products Manufacturing"
was not included on the recommended list despite the fact that there was a
high reduction in tons per day because there may be other possible negative
social and economic ramifications. The Staff evaluated the potential number
of jobs effected, number of firms which may be effected, and•the total
dollars of business done by these firms and concluded that the non -direct
costs were too high. In other words, there were too many potential job
losses, the possibility of firms being driven out of business or in to
other areas, or potential dollars of business lost to the region.
At the bottom of each list is a special list of control measures which the
Staff cannot support at this time. We support the concept, but we cannot
recommend their inclusion in the Plan at this time, due to a lack of infor-
mation regarding either the technology needed to implement them or the
socio-economic effect of the measure, or both. (Specific comments in regard
to measures not reviewed by the Staff in our report of September 22, 1978
are contained in Addendum No. 1, attached hereto.)
In the event the Council wishes to submit to SCAG a list of control measures
necessary to meet the sufficient reductions to standards which the EPA is
requiring, we have included as an attachment to this report the Summary Plan
which contains all measures so that the City Council can select other control
measures which are not included in the staff recommended list.
At the bottom of each list are the total emission reductions in tons per day
for 1987 and the total annualized costs,
Hydrocarbon
NOX
CO
S02
Suspended Particulates
Emission Reduction Required
per Staff Recommended Attainment Level Annualized
Measures (tons per day) (tons per day) Cost $
272.6 309 $326,637,900
385.5 367 49,714,200
1,724.0 1622 * Costs covered
by other
categories
of pollutants
64.4 Achieved 15,006,000
65.4
269 13,566,000
Total
(Note: The cost of attaining required emission reductions over
recommended by the Staff could approach $200,000,000 or
imately 50% more than the cost of the Staff -recommended
-3-
$404,924,100
these
approx-
measures)
0
These total emission reductions are less than the attainment levels
as required by the EPA for hydrocarbons, and TSP. However, as
indicated above, the Staff cannot support enough of the control measures
to achieve the levels required by EPA. It is, therefore, our recommen-
dation that the City council submit this list as recommended by the
Staff with deletions or additions made by the City Council to SCAG
as those measures which could be supported for inclusion in the Plan.
Other measures cannot be supported at this time without development
of additional data.
It is further recommended that-SCAG delay the call for approval by
agencies within the region until the Plan can be redrafted, with additional
supporting data on costs and technology raised by the City of Orange and
other concerned agencies, and after the Plan is resubmitted that a full
60 day review period be provided before approval is asked. Short of this,
it is recommended that SCAG ask, the Environmental Protection Agency to
reduce the required attainment level to'a figure closer to the total
emission reductions contained in the City's list of reasonable control
measures rather than continue to pursue attainment of the existing standards.
FP: BKY:sjc
Attachments
LIST
NO. 1
RECOMMENDED
REACTIVE HYDROCARBON CONTROL MEASURES
Cost Effectiveness
Emission Reduction Annualized
Control Measure
($/ton)
(Tons/Day)
1987 Cost
H-1
Increased Air Passenger
Load Factor
Savings
0.9
Savings
H-2
Jet Aircraft Ground
Taxi Improvements
Savings
2.7
Savings
H-6
General Aviation Aircraft
Engine Emission Controls
Savings
5.6
$1,530,000
H-7
Emission Standards -New
Off -Road Heavy Duty
Non -Farm Equipment
125
5.7
$1,642,000
H-9
Maintain Leaky Valves in
Non -Refinery Industrial
Processes
975
0.5
$186,000
H-11
Electrify Railroad
Switching Yards
275
4.4
$2,100,000
H-13
Trip Reduction Program
240
11.3
$5,000,000
H-15
Emission Standards - New
Farm Equipment
750
1.9
$1,410,000
H-16
Proposed 1978 Emission
Standards - Jet Aircraft
Engines
1325
21.4
$13,440,000
H-18
Annual Inspection and
Maintenance of Light
Duty Vehicles
1200
61.7
$106,505,000
H-20
Substitute Coatings.Used
in Metal Furniture and
Fixtures Manufacturing
3440
12.3
$10,990,000
H-21
Substitute Coatings Used
In Fabrics and Paper
Products Manufacturing
230
9.3
$552,400
1 ' '�
0 0-,
Cost Effectiveness Emission Reduction Annualized
#
Control Measure
($/ton)
(Tons/Day)
1987 Cost
H-22
Emission Controls for
Lawnmowers and Garden
Equipment
750
12.7
$8,447,000
H-23
Increased Bicycle/
Pedestrian Facilities
11,300
0.5
$10,600,0W
H-24
Improved Emission
Controls for Motor
Vehicles
1,000
52.0
$84,775,000
H-25
Reduce Jet Aircraft
Queuing Delays
1,350
0.5
$1,130,000
H-26
Substitute Coatings
Used in Industrial
Maintenance
1,920
2.6
$300,000
H-28
Substitute Coatings
Used in Ship Construction
1,850
2.4
$1,111,000
H-29
Emission Controls on
Gasoline Bulk Plant
Operations
1,980
1.4
$720,000
H-30
Fugitive Emission
Controls for Random
Leaks at Refineries
Savings
8.6
Savings
H-34
Rideshare Program
4,200
6.6
$38,000,000
H-35
Traffic Signal
Synchronization
3,775
0.9
$5,040,000
H-36
Voluntary Retirement
of Old Cars
2,400
9.2
$22,525,000
H-37
Substitute Coatings
Used in Automobile
Manufacturing
3,320
8.6
$7,135,900
H-42
Emission Controls on
Metal Cleaning
Operations
300
5.6
$438,600
H-43
Substitute Coatings
Used in Printing
Operations
Savings
14.9
Savings
H-44
Substitute Materials
Used in Asphalt
Applications
(Cutback Asphalt)
860
4.3
$960,000
da
r _,�
• •
Cost Effectiveness Emission Reduction Annualized
# Control Measure ($/ton) (Tons/Day) 1987 Cost
H-45 Substitute Coatings
Used in Wood
Furniture Finishes 2,600 2.7 $1,820,000
H-47 Emission Controls for
Paint Mfg. Plants 780 1.4 $280,000
TOTAL 272.6, $326,637,900
We support the concept of the following control measures but cannot recommend
their inclusion in the plan at this time due to serious lack of information
in regard to either the technology needed to implement or the socio=economic
effect of the measure, or both.
H-19 Emission Controls for
Small Relief Valves
H-39
Substitute Coatings in
Metal Can & Coil Stock
Mfg.
H-46
Emission Controls for
Chemical MFG. Plants
H-48
Emission Controls for
Rubber Product Mfg.
Plants
H-49
Substitute Coatings for
Metal Parts and
Products
H-57
Emission Controls on
Pharmaceutical Mfg.
H-72
Improved Trucking
Efficiency
2,830 0.2 $207,000
Savings 0.4 Savings
1,970 1.4 $985,000
2,300 1.1 $920,300
800 28.3 $5,880,000
4,500 0.6 $676,000
Undetermined 4.1 Undetermined
-3-
.yr
LIST N0. 2
RECOMMENDED
OXIDES OF NITROGEN CONTROL MEASURES
Cost Effectiveness Emission Reduction Annualized
#
Control Measure
($/ton)
tons/day) 1987
Cost
N-1
Energy Conservation;
Commercial Institution &
Industrial Audits
Savings
20.9
Savings
N-2
Energy Conservation
Residential Retrofit
Savings
10.7
Savings
N-5
Alter Design of New
Residential Space Heaters
Savings
15.8
$ 7,500,000
N-6
Alter Design of New
Residential Water Heaters
Savings
3.7
$ 3,600,000
N-7
Emission Controls on
Cement Kilns
Savings
3.8
Savings
N-8
Emission Controls on
Medium & Small Steam
Generators
1200
12.3
$ 4,700,700
N-10
Emission Controls on
Industrial Boilers
1200
26.9
$ 8,546,700
N-11
Emission Controls on
Refinery Heaters
1200
49.5
$21,872,500
N-14
Emission Controls on Glass
Melting Furnaces
1200
5.9
$ 2,625,000
N-16
Emission Controls on
Stationary Internal Combustion
Engines
250
9.5
$ 870,000
H-6
General Aviation Aircraft
Engine Emission Controls
Savings
+ 3.5
H-7
Emission Standards -
New Off -Road Heavy Duty
Non -Farm Equipment'
125
28.3
H-11
Electrify Railroad
Switching Yards
275
17.7
Cost
Effectiveness
Emission Reduction
Annualized
#
Control Measure
($/ton)
(tons/day) 1987
Cost
H-13
Trip Reduction Program
240
13.7
H-15
Emission Standards -
New Farm Equipment
750
0.7
H-16
Proposed 1978 Emission
Standards - Jet Aircraft
Engines
1325
0.8
H-18
Annual Inspection and
Maintenance of Light Duty
Vehicles
1200
66.6
H-22
Emission Controls for Lawn-
mowers and Garden Equipment
750
1.2
H-23
Increased Bicyle/Pedestrian
Facilities
11300
0.4
H-24
Improved Emission Controls
for Motor Vehicles
1000
83.4
H-34
Rideshare Program
4200
8.0
H-35
Traffic Signal Synchronization
3775
+ 0.3
H-36
Voluntary Retirement of
01d Cars
2400
1.9
TOTAL
385.5 $49,714,200
* Costs for these measures are covered in the Hydrocarbon Section.
We support the concept of the following confirol measures, but cannot recommend their
inclusion in the plan at this time due to serious lack of information in regard to either
the technology needed to implement or the socio-economic effect of the measures, or
both.
H-72 Improved Trucking Efficiency Undetermined 9.7 Undetermined
I r I
•
LIST NO. 3
RECOMMENDED
CARBON MONOXIDE CONTROL MEASURES
Cost Effectiveness
Emission Reduction
Annualized
#
Control Measure
($/ton)
(tons/day) 1987
Cost
H-1
Increased Air Passenger
Load Factor
Savings
2.2
H-2
Jet Aircraft Ground Taxi
Improvements
Savings
14.2
H-6
General Aviation Aircraft
Engine Emission Controls
Savings
97.6
H-7
Emission Standards - New
Off -Road Heavy Duty
Non -Farm Equipment
125
72.6
H-11
Electrify Railroad
Switching Yards
275
72.6
H-13
Trip Reduction Program
240
92.6
H-15
Emission Standards -
New Farm Equipment
750
18.2
H-16
Proposed 1978 Emission
Standards - Jet' Aircraft
Engines
1325
29.5
H-18
Annual Inspection and
Maintenance of Light Duty
Vehicles
1200
500.0
H-22
Emission Controls for Lawn-
mowers and Garden Equipment
750
116.3
H-23
Increased Bicycle/Pedestrian
Facilities
11300
5.0
H-24
Improved Emission Controls
for Motor Vehicles
1000
561.0
H-25
Reduce Jet Aircraft
Queuing Delays
1350
2.3
Cost
Effectiveness
Emission Reduction
Annualized
#
Control Measure
($/ton)
(tons/day) 1987
Cost
H-34
Rideshare Program
4200
54.4
H-35
Traffic Signal Synchronization
3775
8.7
H-36
Voluntary Retirement of
Old Cars
2400,
76.8
TOTAL
1,724.0
* Cost for these measures are covered in the Hydrocarbon Section
We support the concept of the following control measures, but cannot recommend their
inclusion in the plan at this time due to serious lack of information in regard to either
the technology negded to implement or the socio-economic effect of the measures, or
both.
H-72 Improved Trucking Efficiency Undetermined 38.0 Undetermined
4P
P-9
H-1
H-2
H-11
H-13
H-23
H-24
H-25
H-34
LIST NO. 4
TOTAL SUSPENDED PARTICULATE CONTROL MEASURES
Cost Effectiveness Emission Reduction Annualized
Control Measure ($/ton ) (Tons/Day) 1987 Cost
Control dust emissions
from construction and
demolition projects
Increased Air Passenger
Load Factor
Jet Aircraft ground taxi
improvements
Electrify Railroad switching
yards
Trip reduction program
Increased bicycle/pedestrian
facilities
Improved emission controls
for motor vehicles
.Reduce jet aircraft queuing
delays
Rideshare program
1900
Savings
Savings
275
240
11300
1000
1350
4200
31.5
1.0
6.6
1.3
1.8
0.1
20.6
1.1
1.4
$13,566,000
Total 65.4 $13,566,000
We support the concept of the following, control measures, but cannot recommend their
inclusion in the plan at this time due to serious lack of information in regard to either
the technology needed to implement or the socio-economic effect of the measures or both.
P-3 Filter dust from
pharmaceutical manufacturing 2800 0.4 280,000
P-4 Filter dust from rubber
products manufacturing 2800 2.7 2,806,000
H-72 Improved trucking efficiency Undetermined 0.9 Undetermined
LIST NO. 5
RECOMMENDED
SULFUR DIOXIDE CONTROL MEASURES
Cost Effectiveness
Emission Reduction
Annualized
#
Control Measures
($/ton)
(Tons/Day)
Cost
S-1
Petroleum Coke Calcining-80%
reduction
290
17.9
$ 1,885,000
S-3
Fluid Catalytic cracking
-70% reduction
720
41.0
$10,611,000
S-4
Refinery Fuel burning
sources
1250
5.5
$ 2,510,000
Total
64.4
$15,006,000
ADDENDUM 1
The following are staff comments in regard to various control measures
contained in the Plan which were on the recommended lists. All measures
which were not included in the Staff Review of the preliminary draft
AQMP have been analyzed and are commented upon for both positive and
negative features. Those measures contained in the hydrocarbon list are
as follows:
H-4: Modified Work Schedule
This measure recommends the 4-40 Plan as well as the use of staggered
work hours. Although the Staff sees merit in staggered work hours, it
cannot recommend any plan which contains the four day -forty hour week.
We feel that the 4-40 Plan will create.great difficulties in small
offices and have a tendency to increase costs. If this measure must
be included, it should only apply to work stations with a minimum number
of employees that is sufficient to allow a 4-40 plan to work without
reducing the efficiency and effectiveness of the organization or the
work product.
H-5: Parking Management Carpool Preferential
This measure recommends reducing single occupancy parking spaces by 30%
and making these spaces available for ride -share vehicles only. It is
the Staff's feeling that this percentage is too high and will cause
difficulties for major commercial and industrial employment centers as
well as various individual parking facilities. These problems will no
doubt cause established development standards to be questioned and
create many local planning problems.
H-19: Emission Controls for Small Relief Valves
We do not disagree with the concept of this measure as the Air Quality
Management District has similar controls on larger valves already in effect
or proposed. The cost effectiveness of this measure, however, is quite
questionable and, therefore, the Staff cannot recommend At at this time.
H-28: Substitute Coating Used in Ship Construction
The general concept of this measure is probably acceptable. The Staff
does have questions in regard to how well high performance coatings will
hold up, particularly when their performance is tied to more difficult
application techniques and very costly. We do not feel that we can
recommend this measure because of the cost to the region at this time.
H-31: Substitute Coatings in Magnetic Wire Manufacturing
The cost of implementing this measure is high and the technology is still
very questionable. In terms of the economic effect an the region, this
would be a measure that cannot be recommended at this time.
H-39• Substitute Coatings Used in Metal Can and Coil Stock Manufacturing
We do not feel that our Staff is qualified to comment on the ramifications
of this measure. However, due to the fact that the technology is not yet
completely developed to implement this measure, we feel that it is premature
to recommend it for inclusion in the Plan.
H-46: Emission Controls for Chemical Manufacturing Plants
It is the Staff's opinion that this measure, if implemented, may effect
local manufacturers and because of the high cost attached to its implementation,
it is our feeling that it would hurt the industries' competitive position
with those in the same business outside our region. We, therefore, cannot
recommend this measure at this time.
H-48• Emission Controls for Rubber Products Manufacturing Plants
This measure falls within the upper range of cost effectiveness. We see
several local industries that could be affected with accompanying loss of
competitiveness, but as in several other measures, this particular control
measure does have technology available. Without information as to how
implementation of this measure would effect our region,socio -economically,
we cannot recommend it for inclusion, in the Plan at this time.
H-49• Substitute Coatings Used in Metal Parts and Products Manufacturing
This measure promises a potential big emissions reduction and the fact
that technology is available to implement this measure make it impossible
to ignore. However, although cost effectiveness of the measure is attractive,
the high cost to implement this measure would likely cause problems to this
very important segment of the region's economy. This in turn could cause
problems with out -migration of firms and the accompanying loss of jobs.
Because of this, it is our feeling that this measure should not be included
in the Plan unless additional socio-economic information is available.
H-54: Substitute Coatings Used in Automobile Refinishing
This measure probably cannot be left out of the Plan if new automobiles are
to require substitute 'coating. The repair of these automobiles as they
are damaged, will require the use of these new coatings. However, although
the technology is feasible, the cost and the labor intensive process will
no doubt cause problems to the small auto body shop. Implementation of
this measure could be very disruptive to many local jobs. Because of this,
the Staff feels additional socio-economic information must be made available
before this measure is put into the AQMP.
-2-
f-.* -a
0
H-57: Emission Controls on Pharmaceutical Manufacturing Operations
It is the Staff's opinion that the high cost of this measure for a low
reduction of emissions will adversely affect this important industry
for the region. Staff cannot recommend this measure for implementation
in the Plan without additional information on the economic consequences
to the region.
H-65• Substitute Coatings Used in the Aerospace Industry
The Staff recognizes that technology for this measure is available and the
cost to the region.for implementation is low. However, the overlying threat
of loss of a large portion of our aerospace business, if these coatings are
not acceptable to those who buy aerospace products, have tremendous socio-
economic effects. Therefore, the Staff cannot -recommend inclusion of this
measure until questions can be answered as to how disruptive to the region
implementation of the measure could be.
H-85, H-86, H-87, H-88, H-89 Will be commented on as a group
These measures involve freeway changes to support high occupancy vehicles;
the Wilshire Rail Line, the Downtown People Mover, congestion relief -freeway
widenings, transit improvements and future improvement of technological
controls. The AQMP said costs of these measures are not included because
they are part of the Regional Transportation Plan, or will be implemented
for reasons other than air quality. These high cost, high capital invest-
ment projects have little positive impact on air quality. It is our feeling
that transportation measures should compete for transportation funds based
on their merits as transportation projects, not as air quality projects.
Inclusion of these measures in the AQMP will mean a priority diversion of
funds from other regional transportation needs to these Los Angeles -oriented
projects. The Staff cannot recommend that any of these measures which are
transportation oriented, be included in the Plan.
H-90: Future Improvement of Technological Controls for Stationary Sources
is probably premature and cannot be supported as stated. The premise of this
measure is that if technology is available to clean up these sources today,
as we clean up mobil sources in the future, we will likewise be able to apply
this to stationary sources. This may be the case, but then, it may be that
mobil sources will have to take a greater burden than stationary sources for
clean air, and the region may not want to implement this kind of pre-committment
until all options are known.
-3-
r"
Staff comments on the recommended attainment list for oxides of nitrogen
control measures are as follows:
N-1: Energy Conservation Commercial Institution Industrial Audits
This is a conservation measure designed to eliminate waste without dis-
rupting traditional operations. There are costs involved that will appear
on utility bills or to implement mandatory retrofits, but these costs on
an annualized basis are estimated to be at least no more than the present
cost of the wasted energy.
N-2: Energy Conservation Residential Retrofit
Implementation of this measure will require insultation, weatherstripping,
water flow restrictors, and more efficient appliances and lighting to be
installed upon sale of residential housing units. It is estimated that
costs which will be passed through to the new buyer will be offset by
savings on future utility bills. This measure will also provide a means of
continually maintaining the quality of the housing stock available in the
region.
N-5 and N-6: Alter Design of New Residential Space Heaters and Water Heaters
These measures can be considered together inasmuch as they are low cost
conservation measures that are easily implemented and as such they should
be supported and included in.the Plan.
Are primarily industrially oriented measures which appear to be technically
feasible and relatively cost effective. The Staff, therefore, supports the
inclusion of these measures in the Air Quality Maintenance Plan.
N-13: Retardation of Fuel Injection Timing in Marine Diesel Engines
Would appear to the Staff to be self-defeating in that potential energy
wastage of scarce diesel fuel is required for very marginal air quality
emissions savings. We, therefore, cannot recommend inclusion of this,
measure in the Plan.
N-15: Energy Conservation: Solar Water Heater Program
Would appear to be the Staff to be unreasonable in light of the high cost
and the unsure technology required to implement coupled with low emissions
reduction. We, therefore, cannot recommend inclusion of this measure in
the Plan.
The remainder of the measures on this list are those which were contained on
hydrocarbon list and supported by the Staff eliminating those which we could
not recommend for the hydrocarbon list.
T I .-y
E
There are no Staff comments on the list of recommended attainment
measures for carbon monoxide control. All comments in regard to the
measures contained on this list are in the hydrocarbon list, as all of
these measures are hydrocarbon measures which have been dealt with on
List No. 1.
Staff comments on recommended control measures for total Suspended
Particulate are as follows:
P-3'• Filter Dust from Pharmaceutical Manufacturing Processes
This measure is a high cost, low air quality benefit measure that could
adversely effect the region economically. The technology is available
and we do not argue with the concept of this measure, but feel that
additional answers in regard to the socio-economic effects on the region
must be answered before this measure can be recommended for inclusion
in the AQMP.
P-4• Filtered Dust Rubber Products Manufacturing Processes
As on the above measure, this appears to be another high cost, low air
quality measure, because of the questionable adverse effects on the region.
Additional information in regard to where effected industries would be
placed on a competitive basis must be answered before this measure can be
rec ommended for inclusion in the Plan.
P-9• Control Dust Emissions from Construction and Demolition Projects
This measure is a moderately high cost effective measure that is easily
implemented. It does, however, have significant impact on particulate
reduction and, therefore, cannot be ignored. However, it must be pointed
out that implementation of the measure such as P-9 must 'be integrated
with the 208 Water Quality objectives for the region to insure that control
of dust particles on construction and demolition projects do not provide
water quality problems in terms of siltation which may run off into the
receiving waters.
It must be pointed out that the region cannot meet the TSP standards, even
if the activities of man were totally removed from the region and the air
was only effected by Mother Nature. The Santa Ana winds will raise dust
clouds from the deserts and bring them through the region, and it is assumed
that the EPA will recognize this fact and reduce the TSP, standard to require
a reduction of 43 tons in 1987 as a recognition of the fact that man cannot
control nature.
The remainder of the TSP list involves hydrocarbon measures which were
previously commented upon by the Staff.
-5-
Staff comments on the recommended measures for control of sulphur dioxide
are as follows:
S-1: Petroleum Cocalcinine - 80% .Reduction
This measure appears to be a cost effective one that can be supported if
water quality considerations are adequately addressed, and as such is
recommended by the Staff for inclusion in the Plan.
S-3: Fluid Catalytic Cracking -_ 70% Reduction
This measure is already in the process of being implemented and although
costly on an annualized basis, appears to be a cost effective measure that
is supported by the Staff for inclusion in the Plan.
S-4: Refinery Fuel Burning Sources
This is a relatively cost effective measure that can be readily implemented
and will provide a small to moderate reduction in SOX. The Staff recommends
inclusion of this measure in the Plan.
S-5: Sulphur Content in Diesel Fuel
This measure offers an attractive potentidl reduction in SOX emissions.
However, because of lack of understanding of real costs that will be
involved in implementing this measure, and significant negative impacts
of increased use of diesel fuel in the region, we are unable to support
this measure for inclusion in the.Plan at this time. If additional
information concerning the economics and energy wastage become available
to show that this is an attractive measure, it could be looked at at that
time.
S-6: Electric Powered Generating Equipment - 60% Reduction
This particular measure does not have enough supporting information available,
particularly in the area of cost to the consumer who will be paying to
implement this measure on their electric bill. Recognizing the sizeable
reduction possible through the use of this measure, the Staff feels that
this measure could be brought up for consideration and possible inclusion in
the Plan if additional socio-economic data becomes available that shows
it will not be regressive to the region.
sa
ADDENDUM 2
In the SCAG '78 Development Guide a graphic is included which shows
the areas which are going to receive the greatest amount of growth
in the period from 1976 to the year 2000. You will note on the
graphic that the areas showing the darkest -shaded color are those
which will potentially see the greatest growth. Also included is
a graphic from the Regional Transportation Plan which shows the highway
system in the region which are essentially the major transportation
corridors., A close comparison of the two graphics will show that
the majority of the regional growth will occur in areas which have
limited transportation corridors. This is particularly true of
East and Southeast Orange County, and it is the feeling of the Staff
that the lack of transportation corridors causes congestion which
in turn causes additional air pollution.
If, in fact, SCAG '78 is a growth policy containing a goal of having
people and jobs closer together to reduce trips, then it is essential
that transportation corridors be provided in areas of growth because
it is the feeling that industry and commerce necessary to support
growth can only efficiently be established if they are conveniently
available to transportation corridors.
DRAFT SCAG '78 r�
AVERAGE 1
IN TOTAL I
Y REG1011AL
197i
e
✓ENTURA \`
LOS ANGELES
N
c
6A-1
AL HIGHWAY SYSTEM
3W Constnktion
7dening
ORANGE!
Z-Z- — %—
- - SAN DIEOO COIMfY----
IMPERIAL
*I
0►,3 • •
DRAFT 208 WATER QUALITY STAFF REPORT AND RECOMMENDATION
The Draft Areawide Waste Treatment Management Plan, known as
the 208 Plan because of its preparation as a part of Section 208
of Public Law 92-500, the federal Water Pollution Control Act of
1978, has been completed by SCAG and distributed for review by
affected agencies. The City of Orange is an affected agency,i.nas-
much as the actions called for in the Plan are implementable by
local government in the form of agreement to perform certain main-
tenance practices, as well as adopt and enforce a series of
ordinances that affect the receiving water of the United States.
One of the goals of the 208 Plan is to make our'natiodswater
fishable and swimmable by 1983, while developing and implementing
a Waste Treatment and Management Plan Program so that the "point
sources" (those which originate in a specific location which have
been under control for some time through the Regional Board of Water
Quality Control in California) and "non -point sources" (those which
originate from a wide area of general usage such as run-off from a
field which contains other floatable waste materials) can be
addressed.
It is easy to understand how a document such as the 208 Draft
Plan, which is the edited version of many thousands of pages of
technical reports by several authors, can be attacked for the method
in which the Plan was structured and the verbiage used. Several
problems in regard to the Plan which trouble the staff involve the
conclusions in the form of actions which are recommended in the Plan
while seemingly ignoring the technical appendices upon which the
conclusions should have been based.
This problem, which was apparent in the Milestone Report and
caused problems in seeking approval of that document, has apparently
found its way into the final Draft Plan as well.
Under surface sanitation actions, there is a very questionable
relationship between the fact that surface water run-off is that
closely related to street -sweeping practices which ultimately affect
the receiving water quality. It appears that without defining a
clear relationship between street sweeping and receiving water quality,
it has been determined that street sweeping can remove quantities of .
certain contaminants which will ultimately affect the receiving water;
and that if a little street sweeping is good, a lot of street sweeping
will be better. This theme runs through the entire surface sanitation
section. The fact that the programs involved are very costly makes
it difficult for a community to commit to the continuation of a pro-
gram when the use of scarce local dollars might best be utilized else-
where.
r 1 • •
Many actions of the Plan do not identify effective enforcement
mechanisms. It is argued that the Plan will be enforced by monitoring
progress on a bi-annual basis, but it is unclear how any agencies who
do,not agree to the Plan, or who do agree with the Plan but do not
implement it, might be affected. .In areas where implementation of the
Plan does not provide water quality benefits, there would Appear to be
little need for agencies to feel compelled to implement the flan.
Many of the 34 actions contained in the Plan have no implementation,
and other actions are just a reporting of ongoing programs. It would
appear that the actions which were based on the policy guidance of the SCAG
Environmental Committees could be, and should be, more refined and consolidated;
and a process for reviewing the work of the continuing planning process should
be simplified, as shown by the cumbersome committee review structure utilized
in development of the Plan.
Perhaps the greatest concern at this time is, that unlike the AQMP, the
208 Plan involves the expenditure of local monies to adopt and enforce various
ordinances and to maintain many local sanitation programs. At this time,
many of the costs of implementing this Plan are unknown; and •it ha's been
determined in a study prepared by the firm of Booz-Allen and Hamilton for the
EPA that as a result of the passage of Proposition 13, local governments of
California probably do not have sufficient funding to support water quality
related programs that may come out of 208. This point should be brought
home sharply to the EPA in any local plan that is adopted; and it should
be made clear that if a local commitment to expand or implement the programs
beyond those which are on -going at a level assumed to be sufficient to
satisfy the intent of the Plan, the local implementation can only be
accomplished if the EPA will provide a funding source to support such
implementation.
In reviewing the Plan, many of the actions contained within the Plan
are regional in nature, some of which are outside the purvue of the
City of Orange and/or special districts which provide services for. the
City of Orange.
The Plan is unique, inasmuch as many areas of the region are not required
to implement various measures contained in the Plan; which the NIWA'drainage
area, of which the City of Orange is a part, is asked to implement many
measures and provide more stringent enforcement of these measures in order
to protect the sensitive ecological Inner Newport Bay area.
It is the opinion of the staff, that if the major concern in this 208
plan is to protect upper Newport Bay, a sedimentation basin at the upper
entrance would do this better than all the individual controls could do.
Sub -regional debris/siltration basins installed in the flood control
channels (like the E1 Modena basin) would also be a cost-effective solution
to much of the problem.
The review of'the Plan by the staff was concentrated on items in the
Plan specified on a list attached to a letter dated October 31, 1973 to
the Mayor.from James Wilson, President of SCAG. The City was requested
to provide comments on the Plan by December 15, 1978, by formal action
addressing the following points:
-2-
1. Does your agency or jurisdiction generally concur with
the findings, policies and actions in the draft 208
Plan?
2. If not, what changes should be made in the findings,
policies or actions to make them more acceptable?
3. Does your agency or jurisdiction generally concur
with the specific actions recommended in the draft
208 Plan for -your agency or jurisdiction?
(Note: The attached Table describes these actions.)
4. If not, what changes should be made in a specific action
recommended for your agency or jurisdiction in the draft
Plan?
The letter further indicated that the action requested by
December 15, 1978, does not constitute commitment to implement the
208 Plan. It was indicated that after a series of formal meetings,
the final Plan will be redrafted, considered for approval by the
SCAG Executive Committee, and transmitted to the City of Orange for
formal adoption and commitment to implement in the month of February.
(A copy of the letter and requested actions are attached hereto.)
Staff comments in regard to the specific actions requested by
the City of Orange are as follows: -
Action No. 1 -- Existin street-swee in ro rams (prior to the
passage of Proposition 13 should be continued with considera-
tion given to increasing their effectiveness and -reducing
water loads to receiving water.
The staff contends that it is planning to continue street
sweeping at its present level, which is the same as that prior
to the passage of Proposition 13. Subject to a policy decision
by the City Council to reduce this level, this program (which
currently costs the City of Orange approximately $180,000 annually)
will be maintained; and due to the fact that other benefits accrue
to the community, including the very important aesthetic benefit,
it is the staff's recommendation that this level be continued
and that the City of Orange agree with this action.
Action No. 2 -- Maintain current litter control programs. This on-
going program involves the maintenance of trash receptacles in
parks and other publicly owned facilities and properties, and
the spot clean-up of other litter which occurs as a result of
accidents, etc. This program provides much aesthetic benefit
to the community and can reduce vector contamination and other
health problems that occur where trash is allowed to accumulate.
-3-
• 1 •
The staff recommends that this program be continued at its
current level, and that the City Council agrees to Action
No. 2 contained in the Plan.
ing program effectiveness. The staff reports that currently
the City has.pre-cleaning of known catch -basins that accumulate
debris prior to the rainy season. Other catch basins in the
community are located in areas where, because of the uniqueness
of some combination of basin design and slope gradient, trash
debris,does not accumulate in the dry season,.and these basins
are kept clear with the normal flow of water which runs down
the street as a result of over -watering of lawns and other
citizen water wastage.
The staff would not support the redesign and construction of
basins which would trap debris and perhaps cause flooding
problems in areas which do not have drainage problems at the
present time.
It is estimated -that the purchase of a vacuum or,an Educator
truck would require an expenditure of approximately $65,000,
and would require additional manpower to perform catch basin
clean-up duties. The staff cannot recommend the purchase of
such a vehicle at this time.
An alternative would be the purchase of such a piece of equip-
ment on a joint -powers basis through the use of a federal
grant, with the establishment of a rental fee on an hourly or
daily basis that would provide for the amortization of the
equipment and its maintenance with the use of the equipment
by the individual jurisdiction's employees. This would reduce
the cost of increasing the program effectiveness of our storm
drain catch basin cleaning to a cost which might be reasonable
and which could be recommended to the City Council.
Therefore, the staff recommends that the City Council approve
Action No. 3 on the basis of maintaining current catch basin
inlet and storm drain cleaning programs, but withhold the
approval of increased program effectiveness if it involves
the expenditure of funds for additional equipment, and the
use of additional manpower. However, regional type debris
basins could be developed adjacent to existing major water
courses which would syphon off debris and effectively control
pollutants.
10
Action No. 4 -- Distribute homeowner's uides in new developments
containing information on erosion control and prevention of
landslides. The City Council is well aware of the problems
which have occurred on newly -developed land, particularly in
hillside areas which have been modified by the new homeowners
after purchasing the property from the developer.
The staff supports the concept of this action and hopes that
it would be effective in reducing damage which in turn could
cause the City of Orange costs through its involvement in
civil lawsuits which may result from property damage caused.
by uninformed actions of -homeowners. On the other hand, the
staff is pessimistic that this program will have tremendous
long-range impact unless some method can be determined to
ensure that the homeowner's guide is distributed to each new
owner as the homes in the sensitively graded areas are sold
and a new owner comes on the scene. Even with the fact that
this program may have more promise than actual effect, the
staff recommends that the City Council approve Action No. 4
subject to the development and printing of a proper homeowner's
guide by SCAG through a federal grant or other funding source,
and the provision of these guides to the City of Orange at no
cost.
-- Develop, adopt, and
s strinoent as the SCA
amenaea oy 141WA. ine wiry tngineer nas reviewea JGAG/N1wA
erosion, siltration, and grading control ordinance in detail
and finds that many provisions of this very technical and
specific document have merit and can be supported. However,
there are sections which are of great concern to the City
Engineer, particularly in the area of the minimum size of a
grading project which would require preliminary soils investi-
gation and field work as well as use of the soil loss report
and other technically specific portions.of this model ordinance.
He is'also concerned about the need to post bonds for all
grading projects, inasmuch as the bond itself will not provide
adequate assurance that no excessive erosion on the projects
will occur unless the bond is in the form of cash; and the
agency would be hard put to come up with the cash required to
install various erosion control devices, if it finds that the
permittQQ has not done so in the time required by the ordinance.
It is the contention of the City of Orange that enforcement
of the ordinance is a key to reducing the detrimental effects
of excessive erosion and transportation of silt -to the contami-
nated receiving waters.
The mandatory review of grading plans and pqrmits by the
California Regional Water Quality Control Board and Resource
-5-
Conservation District means delay in processing plans and
issuance of permits. The City presently sends copies of
tentative maps to the Regional Board for their comments.
Permits are not contingent upon receipt of comments by the
Regional Board. However, they do respond to the maps that
are submitted, which allows them to discuss special condi-
tions and requirements. It does not create another layer
of government to add costs and prolong project review.
The existing procedure should be continued or refined, but
the staff cannot recommend mandatory review subject to
receipt of comment by the Regional Board prior to issuance
of permits.
mix
sweeping equipment. ine zua Plan places great emphasis
on the use of vacuum -type sweepers as opposed to the mechani-
cal brush sweepers predominantly utilized by the City of
Orange. Although both types of sweepers have their good
and bad points, it is believed that a mix of both types of
equipment should be determined by each respective city
rather than by SCAG/NIWA or any other outside agency.
The difference in capital costs, maintenance and efficiency
of the two types of equipment is such that if an optimum
approach is 50-50, it is estimated it would cost the City
of Orange an additional 20% to perform its street sweeping
activities, which now cost approximately $180,000 per year.
Any directive to require the City to utilize 100% vacuum -
type sweeper would be even more costly.
It is likely that the state of the art in street sweeping
could change the 208 Plan requirements throughout the
country, requiring more and more use of the vacuum -type
equipment. Perhaps hybrid equipment may be developed that
would perform the task of street sweeping in a more efficient
manner than either of the types of machines presently being
utilized. It is the contention of the City staff that the
street sweeping program is being performed in an efficient
manner in the City of Orange at the present time.
Therefore, it follows that if the City is given the preroga-
tive of determining the optimum mix of street sweeping
equipment to be used, we would recommend accepting Action
No. 6 as contained in the 208 Plan. If, however, other
agencies determine what this mix shall be, this action can-
not be supported by the staff, and our recommendation must
be conditioned in that manner.
IN
•
Action No. 7 -- Modified street sweeping practices for optimum
efficiency. This action requires the scheduling of street
sweeping following trash pick-up and -tree -trimming operations.
To the maximum extent possible for the City of Orange street
sweeping program, this type of scheduling has been utilized,
and the staff finds no problem in recommending that the City
Council agree to Action No. 7 as it applies to the City of
Orange's current program.
-- Modify local curbs and gutter to facilitate removal
of s,, recant street pollutants. finis action makes reference
to the fact that in the City of Orange as well as other juris-
dictions in the region, street sweeping is.only performed on
streets which have curbs and gutters to collect trash debris, etc
which accumulates in the street and is blown to the side by
passing cars. Sweeping equipment utilizes.a combination of
brooms, which gather this accumulated debris in the parking
lanes and sweeps it into the hopper.
Streets without -curbs and gutters normally have some sort of
drainage ditch which accumulates the debris, which then runs
off to the receiving waters when the ditch is flowing with
sufficient water due to irrigation run-off or rains.
This act brings up the question of equity to a community such
as Orange, which has high development standards and has streets
which contain curbs and gutters for essentially 99% of its
total mileage. Areas with poor or rural development stand-
ards do not provide street sweeping, and therefore contribute
a greater load of pollutants in the form of run-off to the
receiving waters. This problem has been visually shown on
freeways, which should not be exempt from required surface
Sanitation practices commensurate with those imposed on
local agencies.
Private streets should be discouraged, so that a uniform sweep-
ing program could be maintained. Presently in this City there
are no provisions or requirements to sweep private streets.
The staff of the City of Orange would strongly support an
action which would require installation of curb and gutters
on all developed streets throughout the region, as such
action would increase street sweeping costs throughout the
the region, but would perhaps reduce total street maintenance
costs by an equal or greater amount.
Action No. 9 -- Increase enforcement of illegal dumping regulations.
The staff currently performs clean-up of illegal dumping
operations both through its weed abatement process and spe-
cialized posting and enforcement on the favorite illegal
-7-
dumping locations throughout the City. The staff believes that
the community is doing a good job in the area of illegal dumping
operations, and feels that the additional cost of enforcing
illegal dumping regulations is a cost that the City of Orange
should not bear.
It therefore cannot recommend approval •of this Action by the
City Council, unless it can be understood that the program in
effect in the City of Orange as it is currently constituted is
sufficient to meet the needs and intent of this Action.
The City of'Orange was not requested to approve an action to
implement specific subregional actions for containment and
clean-up of hazardous substance spills (as described in the
non -point source waste management plan). The staff sees
great benefit to the receiving waters in this kind of action,
and the Fire Department has reviewed the sub -regional plan
and approves it. Therefore, the staff recommends the City
Council approve this Action.
It has been previously stated by the staff that many areas of
the Plan could stand strengthening, additional justifications, and
more cost data. Recognizing the fact that this planning product
might go forward even with the general call for a rewrite and extended
review period, the staff feels that the City Council might consider
making the following response, subject to two key conditions, as
follows:
1. That any additional costs incurred by the City of Orange
to implement the Plan be funded by the EPA, including
the cost of staff time to participate in the various
water quality review committees, advisory panels, and
other required meetings, and that
The City Attorney make a finding that the City of Orange
contains an area of approximately 21 square miles, of
which only 10% is now or will be in the immediate future
drained to the Newport Bay drainage area contained in the
NIWA plan. Therefore, the City of Orange would agree
to approve and implement the actions as conditioned in
the staff review for that portion of the City of Orange
which is contained in the NIWA drainage area, and re-
serves the right to voluntarily implement the NIWA
specific actions throughout the remainder of the City of
Orange at our own discretion, but certainly at a level
commensurate with the regional 208 Water Quality Plan
requirements.
In specific response to President James Wilson's request, the
City Council:
E:19
1. Generally concurs with the findings contained in the 208
Plan as well as many of the policies and actions.
2. The City of Orange would like to point out its unique
status of being partially (but only to a small extent)
within the NIWA drainage area, and to a greater extent
in the overall Orange County area, and would like to
emphasize the need for recognition of that fact.
In addition, the City of Orange would recommend that
SCAG attempt to consolidate policies and actions to
more closely match the -findings contained in the techni-
cal appendices of the Plan and eliminate actions which
currently have no implementation recommendations, even
if the broad policies remain in the Plan.
3. Indicate that the City of Orange would agree to Actions
2, 4, and 8; would agree to Actions 1, 3, 5, 6, and 7
as conditioned in the staff comments; and would not agree
to implement Action No. 9 if it meant increasing the
existing program in the City of Orange.
All the specific changes required to suppose this recommenda-
tion are contained in the individual action review.
Respectfully submitted,
Frank V. Page
Urban Affairs Committee
FVP:MMc
•
THE ORANGE COUNTY AQMP
COORDINATING COMMITTEE
Thursday, January 11, 1979
2:00 P.M.
COUNTY TRANSPORTATION BUILDING
1020 North Broadway
Santa Ana, California
AGENDA
1. Call to order
2. Approval of minutes of meetings of September 21, September 28,
November 2, and November 30, 1978.
3. Regional AQMP - Status Report
4. Other Business
5. Adjournment to Thursday, February 8, 1979 at 2:00 P.M. at the
County Transportation Building.
RECEIVED
JAN 8 1979 No -
Mayor
City of Newport
Beach
REMINDER • REMINDER RE N D E R REMINDER 1
MEMORANDUM
r
TO: Los Angeles, Orange and Riverside Counties' AQMP Coordinating Committees
FROM: Jack Green
RE: Rescheduling of Meetings
DATE: January 17, 1979
The meetings of the coordinating committees, scheduled for January 18 and 19,
have been cancelled. The Air Quality Management District Board has not
completed its deliberations on the AQMP. The -next meeting of the Board is
scheduled for Friday, January 19th.• A conflict resolution committee has
been set up to resolve issues between the SCAG Executive Committee and the-
AQMD Board. Among those to be considered are the deletion of some trans-
portation measures from the AQMP.
Because of scheduling problems . with both the SCAG Executive Committee
and the AQMD Board meeting on January 25 and 26, and February 1 and 2, the
following revised coordinating committee schedule has been set. The same
agenda will apply.
FEBRUARY 8, 1979
Riverside County Coordinating Committee will meet at 10:00 AM, same location,
but in Room 13 in the basement.
Orange •County Coordinating Committee wi•11 meet at 2:00 PM, same location.
FEBRUARY 9, 1979
Los Angeles County Coordinating Committee will meet at 10:00 AM, same location.
If further clarification is necessary, call 385-1000, extension 379, after
January 22, 1979.
NOTE: CHANGE OF ROOM FOR RIVERSIDE MEETING.
RECEIVED'
FEB 519790►
Mayor
City of Newport
Beach
r�
0
MEMORANDUM
TO: Los Angeles, Orange and Riverside Counties' AQMP Coordinating Committees
FROM: Jack Green
RE: Rescheduling of Meetings
DATE: January 17, 1979
The meetings of the coordinating committees, scheduled for January 18 and 19,
have been cancelled. The Air Quality Management District Board has not
completed its deliberations on the AQMP. The next meeting of the Board is
scheduled for Friday, January 19th. A conflict resolution committee has
been set up to resolve issues between the SCAG Executive Committee and the
AQMD Board. Among those to be considered are the deletion of some trans-
portation measures from the AQMP.
Because of schedulAng problems . with both the SCAG Executive Committee
and the AQMD Board meeting on January 25 and 26, and February 1 and 2, the
following revised coordinating committee schedule has been set. The same
agenda will apply.
FEBRUARY 8, 1979
Riverside County Coordinating Committee will meet at 10:00 AM, same location.
Orange County Coordinating Committee will meet at 2:00 PM, same location.
FEBRUARY 9, 1979
Los Angeles County Coordinating Committee will meet at 10:00 AM, same location.
If further clarification is necessary, call 385-1000, extension 379, after
January 22, 1979.
f D �e/ A/tyD
men meat t
a wA� OP
1979� 2
0,44rja ACfli l
h
RECEIVED �
JAN 2 219794w
Ma�xr
�m�yff{7
moo
DAILY PILOT - November 9, 1978
-- -- —1
Newport's Mayor
Stirring Fublic
On Air Quality
Paul Ryckoff, Newport Beach's mayor, concedes that
ayair
quality is a difficult subject to get people interested in, but ss it
will be especially impbrtanCin the coming months.
That's because a Southern California -wide Air Quality
Management Program is being developed that's full of what be
sees as potential problems for small citiesand digtridts,as well -as
individual taxpayers.
RYCKOFF, THE UNOFFICIAI. AIR quality expert on the
Newport Beach City Council, has had to wade through two four -
inch thick documents that contained the plan.
It's been mandated by state and federal regulations and is be-
ing put together by the Southern California Association of Govern-
ments
As Ryckoff sees it, there are two major weaknesses with the
plan:
— It doesn't discuss air pollution caused by fossil fuel,burning
power plants.
— It doesn't discuss where the money hundreds of millions
of dollars — is coming from to pay for the steps that will be re-
quired of government. ,
"THEY'RE TALKING ABOUT THINGS LIKE controlling
emission from lawn mowers," he said. "And yet they don't even
mention the nitrous oxides that come out of power plants.
"Do you know that the little Huntington Beach plant that
(Southern California) Edison has produced 20 tone of NOX a day?
Twenty tons a day and they don't even discuss it."
Ryckoff describes the plan as "A Barid-Aid approach" to solv-
ing what is a monumental problem.
"It's frustrating as hell to have politics interfering with the
solution to a problem," Ryckoff added.
THE SCHEDULE FOR adoption of the AQMP, as it's called,
closes public comment Dec. 15 with SCAG and the air quality con-
trol district to adopt it by'Jan. 31. Implementation would begin im-
mediately.
In the meantime, Ryckoff is trying to work up intere§t in the
plan and the process on the part of, local residents and,busi-
nessmen as well as other governmental agencies.
On Nov. 17, SCAG will host .a workshop on the plan at the
N Newport Harbor -Costa Mesa Board of Realtors office, 401 N.
Newport Blvd., from 10 a.m. to 1 p.m.
(over)
rem
Wars
H, tW e�et cop«i it�he�ca of lr
the not pun
angle � daSet Who oRBycloff a comembolrtl� iM An may '
•"fray a" theft ate correct: ' be AMof tko IGAd aft
atemhen woNdas oa t s�j an. ••but I think mhos are saeect. Thiey
can't prove d "I a tint and they cant prow h'm wtend "
WMT RTChM!'!' WOM LM& TO lee is a hot of PW*e W
teteet in the plan and in what be no as its weatnaNs, evocially
the provhdaw teietin{ w ta0wet aclUttes.
Given the podulaW produeed lb p�sets, he says
he bebeves the aulme wpoyu�d chose onelm Wit . it they were
awaAnd hoe wantw risk posed
the ant of Indivldwl hues by re
�imandates dealing Wage as aayAn and taws
,1 ...
DAILY PILOT - November 10, 1978
Warning
Of Flood,
Detailed
Unless federal agencies
winit the cleaning of the San
iego Creek flood control chan-
d, Irvine Ranch Water District
ficials said Thursday., this
District Manager William
Hurst told' directors of the
Newport -Irvine Waste Manage-
ment Planning Agency the dis-
aster would knock the plant out
of commission for six months to
a year.
The consequences would be
that raw sewage, pumped at the
rate of eight cubic feet per
second, would have to be dis•
charged untreated into the San
Diego Creek and Newport Bay'
to existing
cy weather
The impact of such discharge,
Hurst said at the Newport Beach.
meeting, would be "clearly dis-
astrous to the bay environment
and the local economy."
Costs to IRWD customers
would be $3 million to $6 million,
he said. "We anticipate that
costs to existing and new busi-
nesses and property owners and
builders in Newport And Irvine a
could substantially exceed this
• The problem is sedimentation
and vegetationintheflood control
channel.
Orange County Flood Control
began clearing the creek in July
of 1917 but was stopped a month
later by the U.S. Department of
Fish and Wildlife.
The reason was that an Army
Corps of Engineers permit re-
quired for the work was
C withheld because of a ruling that
a cleanup would destroy in-
d pnous vegetation.
Of-v rrticiilai :eum rltto-thwl
federal agencies were willow
l trees growing in the bottom of
the channel, and wildlife that
would be displaced by clearing
work.
Since that time, more than a
year ago, vegetation has been
allowed to grow unmolested in i
the channel.
i district staff presented officials, ott
(gee FLOOD, Page A2)
MOO 04 ARN W.
tQ tber2 Qaly recegtly, that an
amount of rainfall that
statistically occurs every 30
the district's
M Michelson Driveo ars would ewagee Pant in
A gp-year flood, the report j
warned; "Could resutt ir, very
severe health, safety, environ-
mental and economic proll'•
lems."
IRWD officialfi.wentbefore the
Orange County Board of,
Supervisors with the bad news
last week and supervisors. ape
proved a $550r.000 project to,
restore the capacity of the Chan
n@l'; wbjchQrigina4y was; built to 1
handle a,1*year flood,
The, work still can't kegin�
howelter, without the, federal: '
NXWA— directors voted Tbors,
iv to invite renresentatives
ton to the
a compron
vy u,ginnu. ,
The meeting is scheduled for i
Nov. 3Q at 3 pm., at Newport
BeachCityllall: �
Meantime, anf IRWD
spokesman said that evQn, is.
suance of thepermits; won't re•
move the flooding threat.
"Even if we get the permit
right now," the spokesman said,
.it would be six weeks at the.
Very •earliest before we, could,
statt e • . up —right in the
midd�eaaainyseasoo." _ 1
The dus rigt is taking
alternative steps nowto.b4i * ,C
{ protective berms around the i
Michelsonplant. 1
DAILY PILOT - November 1, 1978
Saw Diego Heariag�
Offshore Lease'
Plan Blasted
SAN DIEGO (AP) — Oppo-
pents of a federal plan to lease
tracts off the Southern
California coast for oil and gas
drilling have raised the specter
of serious economic and environ-
mental damage.
Mayor Pete Wilson, two con-
gressmen, a state assemblyman
and others presented a strong
front Tuesday.
They spoke in opposition to a
new federal oil lease sale during
the first of a two-day hearing
sponsored by the U.S. Depart-
meot of the Interior.
W%a people of�this Pation have
tla.to gain, either in revenue
odrow the loam sale, or dw slight
amount of oil that can be re-
asonably be expected to bel
found," WIsonsaid.
"But the people of San Diego
and Southern California have too
much to lose from that explora-
Wilson and most of the other -
opposition speakers, including,
Reps. Lionel Van Deerlin, D-,i
Calif., and Clair Burgener, R-
Calif., and Assemblyman Larry
Kapiloff, D-San Diego, urged de-
letion of 26 near -shore tracts
from the lease sale.
Wilson said an oil spill could
spell doom for the city's tourism
�dustry, which brings in $1
billion a year.
The government proposes to
lease 1.1 million acres of the j
ocean floor on the outer con-,
tinental shelf for oil and gas
drilling.
The lease sale would include
217 tracts. The 26 near -shore
tracts are six to 18 miles off the
San Diego coast.
Opposition arguments were
countered by oil industry
representatives and others who
said fears of an ecological dis-
aster were unfounded and that
the nation needs gas and oil that
might be found off the Southern
California coast.
"If lease sales don't take place,
the oil situation will be
worse five years from now,"
said Phil Verleger, general',
counsel for the Western Oil and
Gas Association.
Oil firm representatives said
the United States spends about
$50 billion a year on imported oil
and said the opportunity to lease
` offshore lands and drill i
ploratory wells is important to
the nation's nergy future
extensive military activities in
Southern California waters.
He cited Navy training ex.
ercises, submarine movements
and torpedo tests now being con•
ducted off Encinitas.
State Controller Ken Cory,
chairman of the State Lands
Commission, told the hearing
chaired by Administrative Law
Judge William Hammett that
the federal bidding system for
oil leases4s "ludicrous."
He said it benefits large oil
companies and ties up oil re-
serves the state should he able
to keep. And he said federal oil
pricing policies make it cheaper
to import oil than produce it
domestically
THE NEWPORT ENSIGN - November 2, 1978
�®ntr®l ND.Togra
A• $20 million county wide; flood•_ '-which'empties• into the'ocean r
control program for this.fiscal :.„ ;alongside the,Santa Ana River, ,
year, was laid before.the Board;of I . inouth in Newport Beach„ is, •plan -
Supervisors Wednesday, by Diiec-, nedna' :; '•;
for H. George Osborrie.of theEn And a,$750,OOOsemoval'job to'
., ..•--....,....O
Osborne, �who•also is the coup: ,
.ty`s•chief,flood control engfueer,
" said that,$13.8'million'may be -'=
spent on 15 projects deemed of-.'
top.p;fority :and he harided,in.a
list.of• eight other'"supplemental" '
projectw*Eich would; cost an; es-
timated $6.3 million.:.''-•'.' .' ' :,'
Onlyone of them, a series of
drop structures on`the Santa Ana
River designed to slow, its flood ,
flow, is -underway: It will cost an
estimated $2 million when all, four
of- then' are finished. _ . • •:1 • .-, '
- The-iivei will be tar&`ied.for $5
million-woith'of work -to line its
levees wfth ooncrete,.to,speed•the
flowsin>tfine•of high, water; and;':
$l.mfllion.to remove sediment •••
built up in fts bed and'so dimf "-
ishing.fts•floodwater cafrying.cap-
acity-s ;
A,$250,000 job'of it moving
sediment -from the, Greenville- ,
Banriingflood control channel;'-
• - ',}: .. „• ,.:,,,
Creek•so it wont wash into Upppr
Newport Bay, •also is•planned.; I
°' Among other major projects are
_
those'caliing' for` lining• Fullerton•"
Creek;;$1 million;,the.Harbor-,
Edingerstorrli drain, $1'inillien; j
and the Hyland Avenue ,storm
drain, costing•ari-estimated $1'.4
million. .
Of the eight supplemental pioj-
ects,proposed.ff,sufficient funds'-
are avaflable„ the mok'costly' ,
would be.a $1.2-million contract'
on the Ocean•,View'channel;
Huntington Beach.
Work on,the Richfield channel'
imnorth Orange County'and on -
the Anaheim -Barber Citychannel
would cost,$P.Fmillfgn each, it`
"was estimated: ;
Other -projects are in Westmin=`
ster, Fullerton; Placentia, the air-' ,
port, Gaiderr Grove, El Modena,
West Anaheim and Los -Alamitos -
Seal Beach, area.
DAILY PILOT - October 27, 1978
U.S. DEPARTMENT 00 THE INTERIOR
to
aUKAU-0 1,"D MANAQOWXT_
I
00E SALE No.s7
Trod MNMlenr �N
EUREKA
..r..rw
MENDOCINO t
SITES SELECTED FOR INTENSIVE ENVIRONMENTAL STUDY
Black Areas Indicate Possible Offshore Leasing Tracts
►. 243 Tracts Picked
For Impact Study
The U.S. Department of the Interior has announced that 243 `
tracts totaling 1.3 million acres off Central and Northern
California have been selected for intensive environmental study as
possible sites for offshore oil land gas drilling leases.
The Outer Continental Shelf leases would be issued in
February,18g2, if they receive approval
The tracts are clustered in five basins: Eel River Basin off
Eureka; Point Arena Basin off Mendocino County; Bodega Basin
off Sonoma and Merin counties; Santa Cruz Basin north of Mon-
terey Bay, and the Santa Maria Basin off northern Santa Barbara
County and San Luis Obispo County.
The sites are among those requested by oil companies. The
leases have been strongly opposed by environmentalists citing'the
unsightly aspects of the offshore oil rigs and the threat of spills.