February 28, 2017
Dr. William Burke Chairman
South Coast Air Quality Management District Governing Board
South Coast Air Quality Management District
21865 Copley Drive
Diamond Bar, CA 91765
Dear Chairman Burke,
Inland Action urges the South Coast Air Quality Management District Governing Board to adopt the 2016 Air Quality Management Plan (AQMP) as presented by SCAQMD staff, without proposed amendments which were entered at the February meeting. Inland Action is non-profit organization of business and community leaders dedicated to community betterment in the inland Southern California region. Inland Action urges your approval of the plan, without amendments, for the following reasons:
- The 2016 Air Quality Management Plan as presented by SCAQMD staff is a strong plan developed over the past four years in an inclusionary and transparent public process which involved a broad cross section of stakeholders resulting in over 5,300 pages of documents and 200 meetings.
- After the public testimony had been closed, substantive amendments to the Plan were brought forward at the February Board meeting at the last minute, with no advance notice provided to the public and stakeholders. These proposed amendments had no prior staff analysis, and no public discussion was allowed. These significant, last minute changes to the AQMP undermine transparency and the public process.
- SCAQMD has proven over the last decade that voluntary, incentive based programs do work. Both the Carl Moyer and S.O.O.N. programs achieved significant mobile source emission reductions by providing matching funds for equipment owners to repower and replace their engines with newer, lower polluting engines, achieving emission reductions beyond what was required by existing regulations. The incentives-based framework in the Plan proposed by SCAQMD staff is the most viable approach to cleaning our air.
- The AQMP must balance both the environmental and the economic needs of the South Coast Air Basin. Trade-dependent industries account for one-third of the State’s economy and jobs, and the largest percentage of new job creation in the inland Southern California counties. Proposed amendments to MOB-01, MOB-03, and MOB-04 will greatly harm California’s competitiveness by artificially constraining the flow of goods and will kill the major economic driver in the inland counties. The goods movement sector is one of the region’s last remaining pathways to a middle-class income for many in the working class. These last-minute amendments will cause transportation providers to move facilities and their associated jobs outside of the region. These unintended consequences are especially concerning since SCAQMD staff has stated that the MOB measures are not needed to reach attainment of the Federal standards. Inclusion of the proposed amendments will harm Southern California’s competitiveness and have questionable environmental benefits.
- The proposed plan recognizes the need for emissions reductions from mobile sources, which are primarily regulated by State and federal government. Indirect source rules of any type are unnecessary and outside of the authority of AQMD to implement.
Inland Action urges the District not to implement Declining Goods Movement Facility Emissions Caps, an Indirect Source Rule, or any other restrictive facilities-based measure on goods movement facilities. Such measures could have grave unintended consequences, such as causing freight diversions, increasing environmental impacts, added operational delays, and elimination of jobs. Inland Action is committed to working with the District to achieve progress on reducing emissions in the Basin and looks forward to adoption of the 2016 AQMP without amendments on March 3.
Sincerely,
Deborah Barmack
President
cc: SCAQMD Governing Board Members
Wayne Nastri, SCAQMD Executive Officer
Clerk of the SCAQMD Governing Board