COMMENT LETTER NO

Edward Eckerle

Informations

• Publié par: Mofeg
• Nombre de lectures: 28
• Langue: English

Extrait

Draft 2003 AQMP – Response to Comments
COMMENT LETTER NO. 26
PORT OF LONG BEACH


Response 26-1

The District staff disagrees that the defined short-term control measures lack sufficient
detail. The District’s defined mobile source control measures describe several strategies
which provide a basis for controlling mobile sources within the Basin. Specific
implementation issues will be thoroughly evaluated during the rule development phase of
each measure. For additional discussion please refer to the response to comment #3-1.

Response 26-2

Control Measure FSS-05 proposes a mitigation fee program for federal sources which
will be paid for by U.S. EPA or federal sources and administered by the District. The
monies collected will be used by the District to implement air quality projects to achieve
fair share emission reductions from these sources. This program would be developed as
an alternative to urgently needed stringent national rules so as to achieve a fair-share
reduction commitment by federal sources to address unique local needs. The District
staff plans to add language to the control measure that clarifies how the measure will be
implemented and including what criteria will used to establish the fees and fund emission
reduction projects paid for by the fees collected. A complete description of the control
measure is provided in Appendix IV-A.

The commenter is also referred to the response for comment #13-1.

Response 26-3

In-use off-road vehicles represent a significant source of emissions in the Basin and
though the District staff agrees with the commenter that it would be preferable that
retrofit requirements on existing in-use fleets be applied statewide, due to the uncertainty
in state and federal commitments to consider such regulations, and the magnitude of the
air quality problem currently facing the Basin, the District is proposing this control
measure to achieve additional reductions where feasible. The impacts from
implementing retrofit requirements on captive off-road fleets will be thoroughly
evaluated at the time the control measure undergoes rule development.

Response 26-4

Although there are restrictions in state and federal law regarding the district’s authority to
directly regulate emissions from nonroad sources through establishing emissions
standards, the District has the authority to adopt in use restrictions on these sources. The
District can require a permit, impose a limitation on the number of hours a source can
operate and cap emissions, among other things. Therefore, it would be reasonable for the
District to establish a fee program to support the costs of in-use programs or to
26-1 Draft 2003 AQMP – Response to Comments
implement alternatives to those measures. Likewise, the District may adopt fleet rules
and impose indirect source regulations and fees, and therefore may establish fee
programs to support or substitute for those programs. See e.g. Clean Air Act Sections
110 and 209 (42 U.S.C. §7410 & 7543), 59 Fed. Reg. 31306 (1994), California Health
and Safety Code Sections 40440, 40447.5, 40716 and 40522.5.

Response 26-5

The comment references the control strategy or specific control measure from the State
and Federal Element of the draft Plan. The overall control strategy and control measures
specified in the State and Federal Element of the draft Plan have been developed by
CARB. CARB staff is more technically qualified to analyze the feasibility and cost of
these measures and provide responses to their control measures and the District staff will
be forwarding all comments on the State and Federal Element of the draft Plan to CARB
for their consideration. CARB staff will be evaluating these comments according to their
own public review process prior to their Board adoption hearing. The District has
prepared an Environmental Impact Report evaluating environmental impacts of all the
draft Plan control measures.

Response 26-6

The District staff is proposing to keep the three mobile source control measure in the Plan
due to the significant size of the black box reductions needed and short timeframe until
the Basin demonstrates attainment with federal standards. We look forward to working
with the Ports and other interested stakeholders in developing these and additional control
strategies as we implement the Plan in the coming years.

26-2 Draft 2003 AQMP – Response to Comments
COMMENT LETTER NO. 26-A
PORT OF LONG BEACH


Response 26-A-1

The comment references the control strategy or specific control measure from the State
and Federal Element of the draft Plan. The overall control strategy and control measures
specified in the State and Federal Element of the draft Plan have been developed by
CARB. CARB staff is more technically qualified to analyze the feasibility and cost of
these measures and provide responses to their control measures and the District staff will
be forwarding all comments on the State and Federal Element of the draft Plan to CARB
for their consideration. CARB staff will be evaluating these comments according to their
own public review process prior to their Board adoption hearing. The District has
prepared an Environmental Impact Report evaluating environmental impacts of all the
draft Plan control measures.




26-A-1