I would like to start by commending the staff at the Environmental Protection Agency and the South Coast Air Quality Management District for their hard work. However, I think that the California Final 2007 Air Quality Management Plan and State Implementation Plan (SIP) still leaves room significant room for improvement and presents several opportunities for achieving attainment of the national air quality standard earlier than the current projected date of 2024. Both the SIP and the EPA ruling require that we vigorously explore those opportunities to their conclusion.
Specifically, I believe the SIP relies too heavily on currently unknown black box technology solutions, which make up a full 49.6% of the Nitrogen / Oxygen compound (NOx) reductions and 43% of the combined volatile organic compound (VOC) and NOx reductions. Essentially we are saying we have no idea how we are going to achieve nearly half of the required reductions.
There are practical steps we can take right now that would produce significant improvements in air quality or which should be implemented at the earliest opportunity in order to more accurately quantify the current emissions, to reduce or eliminate them.
The areas in which I believe we have opportunities to make immediate improvement are as follows:
1)Standardization of existing air quality legislation across the subject areas, namely the San Joaquin valley, South coast air basin and Coachella valley.
2)Strict enforcement of existing local and state air quality legislation.
3)Introduction of legislation to require out of state heavy diesel vehicles to meet California emissions standards or pay reasonable fines.
4)Improved identification of heavy diesel vehicles (tractor / cab units) to help members of the public who wish to report smoking vehicles.
Please see attached pdf for my full comment.
I. Scott, Azusa.
Comment from Ian Scott on FR Doc # 2011-23659
This is comment on Proposed Rule
Approval of Air Quality Implementation Plans: California; South Coast; Attainment Plan for 1997 8-hour Ozone Standard
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Attachments:
Public comment EPA-R09-OAR-2011-0622
Title:
Public comment EPA-R09-OAR-2011-0622
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