OPPOSE- U.S. EPA’s Proposed Disapproval of South Coast Contingency Measure State Implementation Plan for the 1997 Federal Ozone Standard

February 26, 2024


Ms. Ginger Vagenas
U.S. Environmental Protection Agency (EPA), Region IX
75 Hawthorne Street
San Francisco, California 94105


Subject:  Inland Action Comments on U.S. EPA’s Proposed Disapproval of South Coast Contingency Measure State Implementation Plan for the 1997 Federal Ozone Standard [Docket ID No. EPA–R09– OAR–2023–0626]


Dear Ms. Vagenas:

Inland Action is submitting comments on the United States Environmental Protection Agency’s (EPA) proposed disapproval of the South Coast Air Basin Contingency M
asure State Implementation Plan (SIP, also referred to as “Plan”) for the 1997 federal ozone standard (proposed disapproval) (89 Fed. Reg. 7320) urging approval of the Plan rather than the proposed disapproval. Inland Action is a non-profit, non-partisan corporation of public-spirited leaders who have joined together to be catalysts for the economic well-being of the Inland Empire region of California since 1962.

Each year since 2015, Inland Action has visited Washington, D.C., advocating for development of a strategy and coalition to avoid the loss of transportation funding resulting from our region’s inability to meet standards of the Federal Clean Air Act and encouraging an enhanced federal role in reducing emissions from interstate and international goods movement vessels.  During this period, the South Coast Air Quality Management District (SCAQMD) has implemented the most stringent regulations in the nation for stationary sources under its authority.  The California Air Resources Board (CARB) has adopted and is implementing cutting-edge regulations to reduce mobile and area source emissions.  California and this region have invested billions of dollars and developed policies to accelerate the development of clean transportation technology and infrastructure.  Our regional transportation agencies have implemented the most robust and best available transportation control measures.  Our regional transportation plan and Federal transportation program have been demonstrating transportation conformity to support the attainment of federal health-based air quality standards throughout the Southern California Association of Governments region. Collectively, these efforts have achieved more than this region’s share of emission reductions that are under our authority toward federal attainment. This region is fully committed to reducing air pollution and protecting public health, but we need a strong federal partnership to reach clean air goals.

Since the 1997 ozone standard, emissions under the State and regional control have declined by 70 percent, while emissions subject to EPA’s authority have only declined by 15 percent.

More significantly, over 80 percent of NOx emissions are from mobile sources, and about three-quarters of these emissions are from sources for which the EPA is responsible, such as trucks, ships, aircraft, locomotives, and similar heavy-duty engines. Therefore, it is critical that EPA plays a proactive role in taking regulatory actions, providing funding, supporting, and providing opportunities for partnerships. Disapproval of the Plan only distracts from the important work that needs to be done in cooperation with EPA.

If the disapproval is finalized as proposed, it has the potential to set in motion far-reaching consequences on critical aspects of the regional economy.  It could result in not only the loss of tens of billions of federal highway funds and/or federal approvals but also hundreds of billions in local dollars invested in significant transportation projects and delay of needed improvements.  Uncertainty over sanctions can discourage private investment, especially in transportation-related industries, further impacting the regional economy.   Highway sanctions could lead to massive layoffs of construction workers and of workers who supply a multitude of materials, equipment, and services related to construction because impacted transportation projects would not move forward. Additionally, the potential threat of loss or delay of federal funding or approval will have a negative impact on the traveling public and communities.

The Inland Empire plays a critical role as one of the largest logistics centers in the nation in providing for the transport of goods from the nation’s gateway ports to the rest of the country.  It is vital to not only the regional but the national economy.  Despite the best and most innovative actions of this region’s partners and the incredible air quality improvements, we are still threatened with highway sanctions for emissions beyond local authority.  We urge EPA’s reconsideration of the proposed disapproval and continue to encourage collaboration in meeting air quality goals rather than penalizing the region for emissions beyond our control.  We appreciate the opportunity to share our comments. We urge EPA’s support and full collaboration rather than invoking highway sanctions to penalize the region for emissions beyond its control.



Deborah Barmack, President


CC:    Senator Alex Padilla
Senator Laphonza Butler
Congress Member Ken Calvert
Congress Member Judy Chu
Congress Member Pete Aguilar
Congress Member Norma Torrez
Congress Member Mark Takano
Congress Member Jay Obernolte
Congress Member Raul Ruiz