EPA-450/3-74-051
SEPTEMBER 1974
                  DEVELOPMENT
   OF A SAMPLE AIR QUALITY
            MAINTENANCE PLAN
                 FOR  SAN DIEGO
    U.S. ENVIRONMENTAL PROTECTION AGENCY
       Office of Air and Waste Management
    Office of Air Quality Planning and Standards
    Research Triangle Park, North Carolina 27711

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                                             EPA-450/3-74-051
 |                      DEVELOPMENT

 |             OF  A  SAMPLE  AIR  QUALITY

 •                  MAINTENANCE  PLAN

 .                     FOR SAN DIEGO


 I

 •                             TRW, Inc.
                            One Space Park Drive
 •                      Redondo Beach, California 90278

I                           Contract No. 68-02-1385
                             Project No. 104-G

 •                EPA Project Officer:  Andrew T. Creekmore, Jr.
 1
         Prepared for

ENVIRONMENTAL PROTECTON AGENCY
I  Office of Air and Waste Management
Office of Air Quality Planning Standards
 Research Triangle Park, N. C.  27711
t
        September 1974
 I                            Ub*ARY
                              IE*1" Pr0* **•»«•* "V
                              flttXM, iie»i jirjsy 08817

 I

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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers.  Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - as supplies permit - from the Air
Pollution Technical Information Center, Environmental Protection Agency,
Research Triangle Park, North Carolina  27711; or, for a fee, from the
National Technical Information Service, 5285 Port Royal Road,  Springfield,
Virginia  22151.
This report was furnished to the Environmental Protection Agency by
TRW, Inc,  in fulfillment of Contract No. 68-02-1385.  The contents of
this report are reproduced herein as received from TRW, Inc.  The
opinions, findings, and conclusions expressed are those of the author
and not necessarily those of the Environmental Protection Agency.
Mention of  company or product names is not to be considered as an
endorsement by the Environmental Protection Agency.
                     Publication No. EPA-450/3-74-051
                                   11
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                                 PREFACE


     This report documents the results of a ten week study to develop a

sample air quality maintenance plan for San Diego.   The principal  objectives

of the study were to:

          1)  Apply EPA air quality maintenance plan guidelines
              developed through both in-house (EPA)  and contractor
              efforts;

          2)  identify and attempt to overcome problem areas
              encountered in the application of said guidelines;

          3)  provide  a basis for eventual  development of the
              air quality maintenance plan for San  Diego by the
              appropriate state and local  agencies.

     Substantial  comment has been received on the initial  draft  of this

report from EPA,  the State of California Air Resources Board, and  the local

agencies in the San Diego area including the Air Pollution Control  District

and the Comprehensive  Planning Organization.  Where  appropriate, such

comments have been incorporated into the present document.
                                     111

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                            ACKNOWLEDGEMENTS

     The following personnel  made  significant  contributions  to  the
preparation of this report:

               Kimm W.  Crawford (TRW)
               Irene Kan (DeLeuw,  Gather  and Company)
               Eugene Y. Leong, Co-Project Manager (TRW)
               William Oman  (DeLeuw,  Gather and Company)
               Ronald L. Tan (TRW)
               Ron Wada, Co-Project Manager (TRW)

     In addition, the following EPA personnel  provided  helpful  guidance
during the course of the study:

               Ted Creekmore, Project Officer  (EPA/Durham)
               David Healy,  (EPA/Region IX, San Francisco)
               Patricia S.  Port (EPA/Region IX, San Francisco)
               Andy Mank (EPA/Region  IX,  San  Francisco)
                                    IV

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                              TABLE OF CONTENTS

                                                                      Page
1.0  EXECUTIVE SUMMARY  	  1

2.0  INTRODUCTION   	  7

     2.1  Baseline Air Quality  	  7

     2.2  Baseline Emissions Inventory  	 10

     2.3  Present Government Organization for Air Quality   	 11
          Management in the San Diego Region

          2.3.1   State Level    	12

          2.3.2  County Level    	 13

          2.3.3  Regional  Level   	14

          2.3.4  Local Level	15

          2.3.5  Regional  Special  Purpose Agencies  	 15

          2.3.6  Federal Level  	 16

3.0  EMISSION INVENTORY PROJECTIONS   	 19

     3.1  Land Use and Transportation Projections	19

     3.2  EPA Promulgated  Plan for Attainment of Oxidant Standards  .  . 20

     3.3  Technical  Assumptions   	 21

          3.3.1   Reactive  Hydrocarbons and Carbon Monoxide  	 21

          3.3.2  Particulate Matter   	 30

     3.4  Inventory  Projections to 1985	37

          3.4.1   Reactive  Hydrocarbons and Carbon Monoxide  	 37

          3.4.2  Particulate Matter   	 37

          3.4.3  Oxides of Nitrogen and Sulfur Dioxide  	 46

     3.5  Comparison with  the Results of Previous Studies   	47

          3,5.1   The Rand  Study   	47

          3.5.2  The California Air Resources Board Implementation  .  .49
                 Plan

          3.5.3  The EPA Promulgated Plan for Oxidant Control  	49

          3.5.4  The Local Agency  Task Force Plan for Attainment  .  .  . 50

          3.5.5  California Air Resources Board Maintenance Area  .  .  . 50
                 Designation Study

     3.6  Anticipated Fuel Shortage Impacts   	 51

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                                                                                       I
                                                                                       I
                     TABLE OF CONTENTS  (Continued)                                    |
                                                                      Page
                                                                                       I
4.0  ATTAINMENT STRATEGIES  	  54
     4.1  Reactive Hydrocarbon Reduction Measures 	  54              I
     4.2  Particulate Matter  	  56              *
5.0  POTENTIAL MEASURES FOR MAINTENANCE OF AIR QUALITY  	  59              I
     5.1  State Level Land Use Control Measures 	  59
     5.2  Regional Level Land Use Control Measures  	  61              I
     5.3  Local Level Land Use Control Measures 	  62
     5.4  The Land Use Planning Context	64              |
     5.5  Two Candidate Approaches for Incorporating Air Quality  .  .  73              '
          Management into the San Diego Land-Use Decision-Making
          Process                                                                      I
          5.5.1  Alternative "A" AQMP Process Carried Out by CPO  .  .  74              *
          5.5.2  Alternative "B" AQMP Process Carried Out by APCD .  .  76
          5.5.3  Discussion	76
6.0  LOCAL CONSIDERATIONS IN LAND USE PLANNING	80
I
     6.1  The Delphi Panel	  81
7.0  AN AIR QUALITY MAINTENANCE PLAN FOR SAN DIEGO	97              |
     7.1  The Land Use Control Element	97
     7.2  Maintenance Requirements Beyond 1985  	  99              |
     7.3  Status of Technological Controls  	 102

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APPENDIX A -
rArrUilL/iA n
APPENDIX B -
APPENDIX C -

APPENDIX D -

APPENDIX E -

APPENDIX F -
APPENDIX G -

APPENDIX H -
APPENDIX I -

APPENDIX J -

APPENDIX K -





APPENDIX L -









LIST OF APPENDICES

^fl n Hi pnn Air Ona 1 "i "h\/ Da1"a 	

San Diego Population Data 	
NEDS Update 	

Delphi Panel Members and Results 	

Recent California Environmental and Land Use ....
Legislation
Emission Projection Modeling 	
Technical Assumption Meeting 	

Plume Computations 	
Study Contacts 	

Letter from Frank Covington to the Ad Hoc - San . . .
Diego Air Quality Task Force
1. Opinion of the State of California Attorney . . .
General Concerning APCD Indirect Source Review
Authority
2. Opinion of the State of California Fourth 	
District Court of Appeals, Western Oil and Gas
Association, et al . , v. Orange County Air
Pollution Control District, et al .
Potential Conflicts with Other Programs 	





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Page
A-l
n i
B-l
C-l

D-l

E-l

F-l
G-l

H-l
1-1

J-l

K-l

K-16



L-l








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                              LIST OF TABLES
Table                                                             Page
1-1
2-1
2-2
3-1
3-2
3-3
3-4
3-5
3-6
3-7
3-8
3-9
3-10
3-11
3-12
3-13

3-14
5-1

6-1
6-2
6-3
6-4

6-5

6-6
Suggested Maintenance Plan for San Diego 	
San Diego County Air Quality Summary 	
1972 Emission Inventory for the San Diego AQCR 	
Forecasts of Aviation Demand, San Diego Region 	
Aircraft Emission Projection 	
Exhaust Emission Factors for LDV's 	
Exhaust Deterioration Factors 	
LDV Control Measure Effectiveness Assumptions 	
1972 UMT Data 	
Projected UMT Data 	
Industrial Employment Projection Categories 	
Industrial Employment 	
Light Duty Vehicle Assumptions 	
San Diego County Emission Inventory 	
AESi Total Hydrocarbon Inventory and Projection ....
Reactive Hydrocarbon Emission Projections for the
Uncontrolled Engine Category 	
Parti cul ate Emissions 	
Land Use Control Measures for Regional Land Use Planning
and Air Quality Maintenance 	
Organization of Delphi Survey 	
Summary of Round One Results 	
Summary of Round Two Results 	
Comparison of "Best" (Round Two) and "Overall Attractive-
ness" (Round Three and Four) Rankings 	
Results of Round Four - Rankings of Implementation
Obstacles 	
Results of Rounds Four and Five - Comparison of Means
4
9
10
23
24
26
27
28
29
29
32
33
36
38
42

42
43

70
85
86
87

89

89

        and Standard Deviations for Most Important Implementa-
        tion Obstacles	    92

 6-7    Results of Round Six and Seven - Summary of Most
        Effective Control  Measures	    94

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                           LIST OF TABLES (continued)
Table                                                            Page
A-l    Federal Ambient Air Quality Standards 	   A-ll
A-2    List of Air Monitoring Stations In San Diego County .  .   A-12
A-3    Oxidant-Annual Average of Maximum Hourly Average
       for San Diego County	   A-l3
A-4    Maximum Hourly Average Oxidant Concentrations for
       San Diego County	   A-14
A-5    Carbon Monoxide-Average of Daily Maximum Hourly
       Average for San Diego County	   A-l5
A-6    Maximum Carbon Monoxide Values for San Diego County .  .   A-16
A-7    First and Second Maximum Eight Hour Averages for
       1972 Carbon Monoxide	   A-16
A-8    Suspended Particulate Concentrations in
       San Diego County	   A-l7
A-9    Maximum Suspended Particulate Concentrations	   A-17
A-10   Sulfer Dioxide Concentrations in San Diego County  . .  .   A-l8
A-ll   Nitrogen Dioxide Concentrations in San Diego County .  .   A-18
B-l    Population Projections for San Diego County  	   B-4
D-l    List of People Who Were Notified of the Delphi Panel.  .   D-3
D-2    Delphi Panel Members	   D-5
D-3    Results of San Diego Delphi Panel	   D-6
F-l    CPO Model Sequence	   F-2
F-2    Light and Heavy Duty Vehicle Emissions	   F-16

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                            LIST OF FIGURES

Figure                                                            Page

2-1   San Diego Intrastate AQCR	   8

3-1   Emission Projection for Reactive Hydrocarbons  	  40

3-2   Emission Projection for Carbon Monoxide  	  41

3-3   Projected Emissions of Participate Matter	45

5-1   Alternative One - AQMP Process Carried Out by CPO  	  75

5-2   Alternative Two - AQMP Process Carried Out by APCD   ....  77


A-l   Historical  Oxidant Trend for San Diego County  	 A-19

A-2   Seasonal Trend for Oxidant  	 A-20

A-3   Diurnal Pattern for Oxidant 	 A-22

A-4   Cumulative Frequency Distribution for Oxidant -
      Chollas Heights 	 A-23

A-5   Cumulative Frequency Distribution for Oxidant -
      Mission Valley  	 A-23

A-6   Cumulative Frequency Distribution for Oxidant -
      Chula Vista	A-24

A-7   Cumulative Frequency Distribution for Oxidant -
      El Cajon	A-24

A-8   Cumulative Frequency Distribution for Oxidant -
      Escondido . . . . ,	A-25

A-9   Cumulative Frequency Distribution for Oxidant -
      Oceanside	A-25

A-10  Cumulative Frequency Distribution for Oxidant -
      Downtown San Diego	A-26

A-ll  Carbon Monoxide Seasonal Variation, 1972   	 A-27

A-l2  Cumulative Frequency Distribution for Carbon Monoxide -
      Hourly Averages Downtown 1972 	 A-28

A-13  Cumulative Frequency Distribution for Carbon Monoxide -
      Hourly Averages Downtown 1963-1967  	 A-28

A-14  Cumulative Frequency Distribution for Suspended Particulate
      Matter (Quarterly Geometric Means)  	 A-29

A-l5  Seasonal Trend for Suspended Particulate Matter
      (Quarterly Geometric Means) 	 A-30

B-l   Population Projections for San Diego County 	 B-5

F-l   IPEF Model:   Interrelationships Between the Demographic
      and Economic Sectors  	 F-4

F-2   Illustrative Structure of "PLUM"  	 F-6

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                      LIST OF FIGURES, continued
Figure                                                            Page
F-3   General Form of Spatial Allocation Function in "PLUM" . . . . F-8
H-l   Point Source Grid Display	H-2
H-2   Grid Boundaries for the Emissions Simulator	H-3
H-3   Grid Display of Emissions from Freeway Traffic  	 H-6
L-l   San Diego Water Basin	L-ll

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                       1.0  EXECUTIVE SUMMARY


     The San Diego region has, in terms of meteorological conditions, a

high potential for the buildup of air contaminants.  Thus, despite the fact

that total pollutant emissions are lower than most of the critical air

pollution regions across the nation, the resulting pollutant concentration

levels indicate that a severe air quality problem exists.  Violations of the

National Ambient Air Quality Standards occur for oxidant, carbon monoxide

and partic-ulate matter.  Peak measurements of 0.32 ppm for oxidant (hourly

average), 19 ppm for CO (8-hour-average), and 97 MQ/M^ for particulates

(annual geometric mean) in 1972 indicate that emission reductions of 75%

for reactive hydrocarbons, 53% for carbon monoxide, and 55% for particulate

matter will be required in order to meet the national standards for air

quality.  Oxides of nitrogen and sulfur dioxide  are not a problem at

present, nor are they projected to become a problem through 1985.


     The emission inventories for reactive hydrocarbons, carbon monoxide,

and particulate matter have been projected to 1985 under the assumptions

that (a) the promulgated EPA transportation control plan will  go into effect

as scheduled (including an 11% reduction for vehicle miles travelled) and all

elements of the plan will  achieve the degree of control assumed by EPA; and

(b) the Controlled Trends  alternative of the Regional Comprehensive Plan will

be implemented, and the employment and vehicle miles traveled) (VMT)  pro-

jected to result from this alternative will actually materialize (less the

11% reduction due to the transportation control  plan).   The set of technical

assumptions concerning the air quality/emission level relationship, emission

factors, hydrocarbon reactivity factors, growth factors, and control  efficien-

cies for the various measures are considered, on the whole, to result in an

optimistic appraisal  of future air quality in San Diego.  Alternative assump-

tions may lead to significantly different conclusions.   Nevertheless, it is

felt that future air quality is not likely to be better than that portrayed

in this report.  The projections indicate the following:

            •  The primary standards  for carbon monoxide will  be
               attained by 1977 and maintained thereafter through
               1985.   Attainment by 1977 is contingent upon the
               assumed VMT reduction  actually occurring.

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          •  In the absence of controls  over and above what is  pre-
             sently contained in the final  EPA implementation plan for
             San Diego, attainment of the National  Ambient Air  Quality
             Standard for oxidant is not likely to  occur by 1985.
The sum total of the control  programs planned by EPA,  the California  Air
Resources Board, and the San Diego County Air Pollution Control  District
have been projected to fall short of attaining the  oxidant standard  in San
Diego through 1985.  Beyond 1985, the effect of the federal  new car  control
program is expected to be offset by growth  in other emission categories as
well as by growth in vehicle miles traveled.
          •  In the absence of controls  over and above what is  pre-
             sently enforced by EPA and  the San Diego  County Air
             Pollution Control District, attainment of either the
             primary or secondary National  Ambient  Air Quality  Standards
             for particulate matter is not  likely to occur in San Diego
             through 1985.
The recent tightening of APCD regulations concerning particulate matter
emissions from stationary sources, as well  as the reduction in  auto  exhaust
particulates anticipated to result from  the use of  oxidizing catalytic con-
verters, will be offset by growth in emissions from other source categories,
most notably fuel combustion.  Additional data is required to identify from
which source categories further reductions  should occur in order to  meet
the secondary standard.
          •  By 1985, emissions from sources for which little or
             no controls are presently planned will dominate the
             emission inventory for reactive hydrocarbons.
These sources include aircraft, heavy duty gasoline powered motor vehicles,
motorcycles, off-road heavy duty vehicles,  and wild fires.  Each source
category is comparable to the others in  magnitude,  and together these sources
account for 58% of the total  inventory in 1985.  Aside from a 14% contribution
from light duty vehicles, the remaining  inventory is divided into small
portions amongst other source categories.
     Additional control measures required for attainment of the oxidant
standard are contingent upon the date by which attainment must  occur.  If it
is 1977, a 100% light duty vehicle VMT reduction would be required.   By 1980,
light duty vehicle emissions which had previously dominated the inventory will
be drastically reduced, due to the federal  motor vehicle control program.

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Conversely, other emission sources which had previously accounted for only
small fractions of the inventory will have been inexorably growing in mag-
nitude.  Equity considerations as well as the technological  limitations of
deriving further reductions from source categories already under stringent
control argue in favor of attacking those sources which have not previously
been subject to comparable control programs.  Therefore, an  80% reduction in
emission from heavy duty vehicles, motorcycles, and aircraft would be
required.  This would have to be accomplished through stringent standards for
new heavy duty vehicles and motorcycles, oxidizing catalyst  retrofit programs
for those vehicles in these two categories already in use, and the institu-
tionalization of ground operating procedure modifications for both civilian
and military aircraft.  By 1985, a 60% reduction from the same three cate-
gories would be required.  In this case, the retrofit of in-use heavy duty
vehicles and motorcycles would no longer be an effective measure.
     It is anticipated that no matter what sources receive further control,
the costs of such control will be high since the more cost-effective control
options will have already been exercised.
     Additional control measures required for attainment of  the particulate
standard are contingent upon the acquisition of additional data concerning the
chemical composition of the particulate samples collected.  Such data would
serve to identify the major contributors to the high levels  measured, and hence
the appropriate control strategy.  Preliminary plume model computations suggest
that the most significant contributors to the particulate loading at El Cajon
(where the peak annual geometric mean was measured) are automobiles.  If further
data confirms this result, an appropriate control  measure would be the removal
of sulfur from gasoline.
     It should be noted that none of the attainment measures outlined are
within the jurisdiction of any of the local agencies in San  Diego.  Such
controls must be initiated by EPA and/or the State Air Resources Board.
     The fundamental problem of air quality maintenance planning is, how  can
air quality be maintained in the face of continuing urban growth and develop-
ment?  In addressing this problem, an intimate connection must be made with
the regional comprehensive plan:
          •  The regional comprehensive plan can serve as a  framework
             for designating the land use elements of the AQMP.
                                     3

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Recognizing that there are weaknesses  and inadequacies  in  regional
comprehensive planning, it is  still  felt  that the  air quality  maintenance
plan (AQMP) should be, to the  maximum  extent possible,  consistent with  the
regional  comprehensive plan.   Air quality is only  one of many  considerations
in local  and regional  objectives for directing future growth;  currently the
only vehicle for expressing these is the  comprehensive  plan.   The regional
growth policies adopted by the Board of Directors  of the Comprehensive
Planning Organization  are consistent with the goals  of  air quality  main-
tenance.   Thus, the AQMP may be considered to provide an enforcement vehicle
for those policies.
          •  The procedure by which overall  growth and  develop-
             ment may  occur without an associated  degradation  of
             air quality is through increasingly stringent con-
             trol programs concerning  both technological and
             land-use  elements.
An air quality maintenance plan consists  of two distinct yet interacting
elements - a technological or direct source control  element and a land-use
or indirect source control element.  In San Diego, the  oxidant problem is
such that technological controls must be  extended to their maximum if there
is to be any flexibility allowed in the land-use control element.  A
suggested maintenance plan is summarized  below:
          Table 1-1.  Suggested* Maintenance Plan for San Diego
      Technological  Control  Element      Land-Use  Control  Element
   •  90% control  of heavy duty
      vehicle reactive hydrocarbon
      emissions
   t  90% control  of motorcycle
      reactive hydrocarbon
      emissions
   •  90% control  of aircraft
      reactive hydrocarbon
      emissions
   Emission allocation procedure
   (SB 1543 or equivalent)
   Direct and indirect source
   review, and EIR review (CEQA)
•  Capital facility ordinances,
   development timing controls, and
   taxation policy to preserve
   undeveloped areas
    Due to the time constraints imposed upon this study,  a detailed
    examination of the feasibility and effectiveness  of these measures
    was not possible.   Hence,  they are suggested for  further study, rather
    than recommended.

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     It should be noted that the degree of control required to maintain
the air quality standards is greater than that required for attainment.
This is a direct consequence of the growth in regional  activity that is
projected to occur through 1995 under the Controlled Trends alternative.
Therefore, it is suggested that the maintenance requirements of the Clean
Air Act provide the binding constraint for air pollution control  in
San Diego.
     EPA is currently examining the feasibility of obtaining effective
control over motorcycles and aircraft.   If the stringent control  indicated
here cannot be obtained within the 1985-1995 time frame, the burden of
control will  shift to the land-use control  element of the AQMP.   Since the
land use control element is to be used to ensure that the "Controlled Trends"
policies are  adhered to, any additional  control  burden  imposed by a failure
in the technological control element will dictate that  the land use controls
must be utilized to limit growth in a fashion which goes beyond the enforce-
ment of the adopted growth management policies.   This potential  eventuality
is of tremendous significance to the future growth and  development of the
San Diego region.   The implications are  far-reaching and may lead to a
direct conflict between air quality goals,  as defined in the Clean Air Act,
and other public values.

     Three alternative institutional arrangements for administering the
preparation and implementation of an air quality maintenance plan for San
Diego have been identified.  One alternative would have the Comprehensive
Planning Organization play the lead role.  A second alternative would have
the Air Pollution Control District lead, while a third  alternative would
have CPO and the APCD share the lead through the formation of a joint
governing committee.  The principal difference between  the alternatives is
the assignment of jurisdiction for indirect source review.  As each alter-
native has its own set of problems, no recommendation is made concerning
which would be most appropriate.  What should be remembered, however, is
that no single agency in San Diego has the total expertise, experience,
and resources required for the successful planning and  implementation of
an AQMP.  Therefore, no matter what the  institutional arrangement, close
cooperation and interdependency between  agencies will be required.
                                    5

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     It is difficult to be optimistic about either the prospects for
achieving the photochemical oxidant air quality standard by 1985 or for
maintaining it thereafter.  Less of a problem, but nevertheless
significant, is the achievement and maintenance of the particulate air
quality standard.  Numerous difficulties ranging from available technology
and excessive control costs to political-institutional constraints and the
public acceptability of controls have resulted in the present dilemma.  The
problems are deep seated and unlikely to be resolved in the near term
without the concerted efforts and cooperation of all the agencies involved
in the air quality maintenance planning process.

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                        2.0   INTRODUCTION


     The San Diego  Intrastate AQCR, also known as the San Diego Air Basin,

 is  located in the southwest corner of the state and consists of the western

 two-thirds of San Diego County.  It is bounded on the east by the summit

 of  the peninsular range, on the north by Orange County, on the south and

 west by Mexico and  the Pacific Ocean, respectively.  The airshed has a

 land area of approximately 3040 square miles and, as of 1970, a population

 of  some 1.36 million people and 790,000 motor vehicles.  The population

 is  concentrated primarily in the city of San Diego and the incorporated

 areas along the coast.  Figure 2-1 illustrates the  location  and area covered

 by  the air basin.

     Air pollution  control in the region is primarily the responsibility

 of  the San Diego County APCD.  Since the airshed is contained within one

 county, no additional regional coordinating council is required for

 emissions control,  as in some of the other multi-county airsheds within

 the state.

     Overall, the data bases in San Diego are quite good.  More often than

 not, the problem is not the lack of available data but attempting to

 reconcile the differences between several different data sets.  Frequently,

 this problem is as  sensitive to the political environment as it is to

 technical judgments.

 2.1  BASELINE AIR QUALITY

     The San  Diego air quality maintenance  area  suffers  from a high  fre-

quency of occurrence of both  low level  inversions  and  low wind speed.

Accordingly,  it has  one of the highest  potentials  for  the build-up of   high

concentrations  of air pollutants in the nation.  (2-2)

     As in many areas of California,  the predominant air pollution  problem

has been photochemical  oxidants, primarily  ozone.   This  implies a  stringent

control  program of its precursors  --  reactive hydrocarbons and to  a  lesser

extent, nitrogen oxides.   Preliminary air quality  maintenance area designa-

tions by the  California Air  Resources Board(2-1)  project photochemical  oxidants,

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                                            Location  Of
                                                Basin
                                                            N
Source:  California Air Resources  Board
                 Figure 2-1.  San Diego Intrastate AQCR

                                   8

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carbon monoxide, and total suspended particles to exceed the NAAQS between

1980-85 in San Diego.  Sulfur dioxide and nitrogen dioxide are projected not

to exceed the NAAQS standards for the same time frame.  Table 2-1 presents

the 1972 reference air quality readings for San Diego as well as the

emission reductions required for each critical pollutant to meet the NAAQS.



           Table 2-1.  San Diego County Air Quality Summary
Pollutant
Oxidant
Carbon
Monoxide
Suspended
Particulate
Matter
Nitrogen
Dioxide
Sulfur
Dioxide
Current
Level
0.32 ppm
(1 hour maximum)
19 ppm
(8 hour average)
97/ug/M3
(annual geometric
mean)
.04 ppm
(annual average)
.005 ppm
(annual average)
Applicable
Standard
.08 ppm
9 ppm
60yug/M3
.05 ppm
.03 ppm
% Rollback
Required
75%
53%
55% *
0
0
  SO                 ,   <019 Ppm     s      14
  ^2                (24-hour average)     ' M

  *Assumes  an  uncontrollable  background of 30 yg/M  .  Emissions of parti-
  culate matter must be rolled  back to the secondary standard due to the
  fact  that the originally  approved state implementation plan indicated
  that  the secondary standard for particulate matter would be met in San
  Diego.


     An analysis  of the air quality  data  available  from the  Air  Pollution

Control  District,  the  California Air Resources  Board,  and the National  Air

Sampling Network  is contained in Appendix A.  This  analysis  has  led  to  the

following conclusions:

          •  Maximum values for  oxidant and carbon  monoxide
             predicted by  the Larsen statistical  analysis of
             1972  data gave no reason to  reject the observed
             0.32  ppm  peak oxidant concentration  or the 19 ppm
             8 hour CO peak concentration in  San  Diego County.
             These values  are therefore used  for  calculating
             rollback  requirements.

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          •  Oxidant  maxima  and yearly  averages  are  similar in
             magnitude  at  several  sites in  San Diego County.  This
             confirms the  regional  nature of the oxidant  problem,
             and indicates that emission reductions  are required
             on  a regional basis.

          •  Oxidant  concentrations at  all  stations  show  a  seasonal
             peak in  late  summer  in addition to  a daily peak  in the
             early afternoon.  The latter finding, together with the
             results  of the  Larsen analysis of the available  air
             quality  data, suggests that transport from other  areas is
             not a significant factor influencing high oxidant  levels
             in  San Diego  County.

          •  Carbon monoxide and  particulate matter, in contrast to
             oxidant, show seasonal  maxima  in winter rather than
             summer.  In the case of particulate matter,  this
             suggests that photochemical aerosol  is  not a signifi-
             cant problem  in San  Diego.
 2.2   BASELINE  EMISSIONS  INVENTORY

     A summary  of  the  1972 emission  inventory for San Diego County  is

 presented  in Table 2-2.

            Table 2-2.   1972  Emission  Inventory  for the  San  Diego
                         AQCR  (tons/day)
                      Reactive
                      Hydrocarbons
Source Category
Stationary Sources
Chemical
Metallurgical
Mineral
Organic Solvents
Gasoline Marketing
Fuel Combustion
Waste Disposal
Miscellaneous Stationary
   Sources
Mobile Sources
Gasoline-Powered        130.2
   Motor Vehicles
Diesels                   0.8
Uncontrolled Engines     14.8
Aircraft                  7.1
Ships  & Railroads        0.2
                         16.
                         33,
                          1.
                          1.
                          7,
   CO
   4.3
   8.0
  30.8
                                    915.

                                      4.6
                                    120.0
                                     28.2
                                      0.2
                                               NO.
 78.6
  0.2
  0.8
            30.0

             7.6
             7.1
             3.1
             0.3
                      SO.
30.4
            3.8

            0.5
            0.5
            0.6
            0.3
                  Particulate
                  Matter


                     0.3
                     0.1
                    17.9
10.9
 1.6
19.7
          7.8

          0.3
          1.9
          0.3
          0.2
Total
                        214.0
1111.1
127.7
36.1
61.0
                                     10

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     As is apparent from this table, gasoline powered motor vehicles
dominate the inventories for reactive hydrocarbons  and carbon monoxide.

In the case of participate matter,,1 the mineral, fuel  combustion,
miscellaneous (wild fires and structural  fires), and  motor vehicle source

categories are the most significant contributors.  Projections of these

inventories to 1985 are presented in Section 3 of this report, along  with

a more detailed breakdown of the 1972 baseline inventory.


2.3  PRESENT GOVERNMENT ORGANIZATION FOR  AIR QUALITY  MANAGEMENT IN THE
     SAN DIEGO REGION (LEGAL AUTHORITY AND JURISDICTION)

          "As lawyers for the State we have had to  sue under a
          myriad'of environmental laws, and the first point we
          made was that fragmented efforts to control the
          environment through single purpose agencies are
          doomed to failure, and probably self-defeating	
          regulation of air, water,  noise and solid waste  cannot
          be dealt with effectively without land use  regulation,
          but land use regulation alone solves nothing.   California
          can no longer afford the luxury of special  purpose
          regulatory agencies, doing their own thing  to the dismay
          of the regulated, the confusion of other  agencies and the
          detriment of the State as  a whole." *

     The Federal Clean Air Act of 1970 prescribed national  ambient air

quality standards and charged the states  with implementing plans  to attain

and maintain these standards.  Section 110 of the Act gives the states

authorization to include "land use and transportation controls... necessary

to insure attainment and maintenance of these standards."

    The  present government organization for air quality management in SL.H

Diego  suffers from the common problem of institutional fragmentation.  Con-

flicts  in air quality management are particularly likely because air, being

a regional  resource, is influenced by land use, transportation, and other

planning decisions.  Development decisions are made  incrementally by  the

local  governments and without full comprehension of what  their growth is

doing  to regional air quality.  At present, air pollution controls im-

posed  at the state or regional level are  not incorporated into the land

use planning process.  Moreover, the present institutional framework for

air quality management, being singled out from land use commissions and

other  resource management institutions (e.g. Water Quality Control Boards,
*Evelle  Younger,  State Attorney, addressing the  Pacific Homebuilders
  Association in San  Francisco at the Fairmont  Hotel, June 6, 1974.

                                    11

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Coastal Commissions, etc.), does not encourage a balanced approach  to
environmentally enlightened land-use planning.
2.3.1  The State Level
     Created in 1967 under the Mulford-Carrell  Act,  the California  Air
Resources Board (ARB) is charged with managing the state's air resources.
The ARB retains the responsibility for developing and  enforcing motor
vehicle pollution control  standards.  Fifty local air  pollution control  dis-
tricts have been delegated primary responsibility for  planning and  enforce-
ment of stationary source  controls, while the ARB is to intercede only in
cases of local  nonperformance.
     The Air Resources  Board is developing a program to coordinate  air
resources management programs with land use planning throughout the
State.  In 1973, a land use planning group with expertise in land use
planning, systems analysis, meteorology, and air pollution emissions
was created.  This group will develop and evaluate methods of relating
land use and transportation planning to air quality.
     The land use planning group is developing strategies and techniques
for insuring that air quality goals will be achieved and maintained
in the longer term (10  to 20 years and longer).  The group attempts to
influence decision making so that future growth and development in  the
State of California will allow air resources management to be in harmony
with social and economic goals.
     The land use planning group works with the State  Department of
Transportation, the State Office of Planning and Research, other State
agencies, local air pollution control districts, and regional and local
planning authorities.  The group coordinates its activities with the
Federal Environmental Protection Agency.
     The Air Resources  Board also reviews environmental impact reports
(sumbitted either directly to the ARB or through the State Clearinghouse)
on construction projects which may have a significant  effect on air
quality.  ARB review provides a basis for integrating  air quality consid-
erations into decisions of other State and local agencies on power  plants,
highways, wastewater treatment projects, and other projects and develop-
ments having a potential impact on air quality.
                                    12

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2.3.2  County Level
    In San Diego, air pollution control is primarily the responsibility
of the County Air Pollution Control District (APCD), a single purpose
agency charged with regulating stationary sources of air pollution.  The
APCD is considered a county health function and is now under the County
Department of Public Health.  The APCD reports to the County Administra-
tor and the five County Supervisors.  Approximately 82 percent of San
Diego County's total land area is under the County Board of Supervisor's
jurisdictional control, and all development proposals within this area
are subject to their review.  It should be noted that the APCD's review
jurisdiction includes the entire San Diego County, a significantly larger
area than the AQCR and the AQMA which only include approximately the
western two-thirds of the county.
    The APCD has traditionally conducted permit review for 1) all new and
existing stationary air pollution sources, and 2) review of visible emis-
sions from mobile sources such as automobiles and ships.  Additionally,
the APCD submits comments to lead agencies on Environmental Impact Reports
and Environmental Impact Statements.
    Separate from the County APCD is a county-wide planning department
called the Environmental Development Agency (EDA).  This agency consists
of the Environmental Review Board (ERB), the Planning Department, the
Office of Regional Transportation and Land Use Planning and the Office
of Environmental Management (OEM).  The Office of Environmental Management
is the policy analysis arm of the Environmental Development Agency.  OEM
has no review powers on new development; the ERB is responsible for EIR
review, but ERB review comments are sent to the County Planning Commission.
                                    13

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     EDA, in addition to being under the control  of the County Supervisors,
lacks any A-95  review powers.  A-95 is  a review process by which designated
regional and state agencies may prepare  comments on all  federally funded
projects.  Title IV of the 1968 Intergovernmental  Cooperation Act (Section
401B) requires all viewpoints (national, state,  regional, and local)  to be
considered in planning federally assisted programs and projects.   Section
401c further requires that the programs  and projects be consistent with
the objectives of state, regional, and local  plans.  In April 1973, the
State of California Resources Agency incorporated review of all  EIR's
requiring federal grants or issuance of state permits into the A-95
process.
2.3.3  Regional Level
     The Comprehensive Planning Organization (CPO) is the council of
governments for the San Diego region.   Its members include the City of
San Diego, the County of San Diego, and  the twelve incorporated cities in
the County, and CalTrans, an ex-officio  member,  of the State of California.
In addition to serving as the A-95 clearinghouse,  CPO functions as an
agent of federal and state policies, procedures  and requirements.  CPO
also reviews and certifies state and federal  projects to insure compatibility
with the Regional  Comprehensive  Plan  since it is  designated by the state
as the regional transportation agency.  CPO's Board of Directors  recently
organized a special ad hoc air quality task force  to address  the  issue of impacts
the Regional Comprehensive Plan would  have on air quality.   The task  force
is composed of a policy committee and  resource panel, consisting  of elected
officials, community leaders, citizen  experts, and various local, state,
and federal agencies concerned with air  quality, transportation and land-
use controls.  The City of Tijuana, Mexico, is also an ex-officio member.

     The role of the  ad hoc air quality task force  is:  1) to coordinate  and
develop a total package of reasonable and locally acceptable air quality
plans and implementation programs; 2)  to provide a mechanism for various
community interest groups; and 3) to allow local inputs into the planning
process.  More recently, EPA Region IX has asked this policy group to
develop a concensus among the local governments on how the functions of
                                    14

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indirect source review, parking facility review, and parking management
plans can be  implemented.  (See Appendix J)  After the group makes its find
ings, EPA will officially delegate the responsibility for implementing the
aforementioned policies to a local agency.
2.3.4  Local Level
    Separate from the county and regional  government jurisdictions  are  the
thirteen separate units of local government; each of the thirteen cities
has its own council and land use decision making body.  The result is less
than optimal intra-city cooperation on issues of land use control, growth,
resource management, and air pollution.  The lack of coordinated planning
leaves each city and the county (for the unincorporated areas) free to
assign its own interpretation of "costs" which they use in their particular
equation for land use decisions ... and consequently for their air resources,

2.3.5  Regional Special Purpose Agencies
    The Local  Agency Formation Commission (LAFCO) is still  conducting
Spheres of Influence studies in the San Diego area.   The aim of their
research is to 1) identify the unincorporated hot spots in the county
where development pressures will likely necessitate their future incorpora-
tion by one of the 13 cities; 2) determine the unincorporated areas which
will demand an urban level  of municipal services.  LAFCO's operations are
hoped by some to have a major influence on future land use patterns in
the region.  By outlining annexation boundaries and permitting cities to
exercise limited regulatory  control on new development  in pre-annexation
areas, it  is hoped  that cities will have more control over the tempo and
quality of their growth.
     In actual practice, the effectiveness of LAFCO has been mixed.  In the
San Francisco Bay Area, for example, the influence LAFCO may have on future
development is entirely dependent on whether the cities in the region will
agree on the land areas in which they will provide future urban services.
This task  requires each city to outline its capital improvement program and
to  designate in its general plan where future development should occur.
                                    15

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    The inherent problems which may arise in San Diego are as follows:
     1.  Cities must reach mutual  agreement on growth so that a
         regional growth policy can begin to be formulated.  Such
         a policy will require concensus of at least 14 different
         land use agencies.
    2.   Presently there is no effective link between county
         comprehensive planning and the decision-making being
         made by the Board of Supervisors.
    3.   The land use and open space elements of the County
         General Plan must be consistent with the goals and
         objectives of LAFCO.

    Another special regional agency is the San Diego Coast Regional
Commission, which is charged with preparing a comprehensive  plan for
the preservation, protection, restoration and enhancement of the coastal
zone.
    The Commission recognizes that the problem of air pollution is
regional in nature and believes the attainment and maintenance of air
quality standards  must be approached on a regional basis.   The
Commission's primary role has been to help facilitate land use manage-
ment of the non-urbanized coastal areas; one major defeat in this effort
to date has been in the City of Oceanside where the courts denied the
Commission the  right to withhold a construction permit for an 11-story
hotel.  In the  absence of local initiation by the San Diego Coast
Regional Commission, this particular attempt to withhold a building
permit was finally taken by the State Coastal  Commission.   (See Appendix
L for further discussion of the Coastal Commission.)
2.3.6  Federal  Level
     Operating somewhat peripherally from the foregoing state, regional
and local jurisdictional structure in San Diego, is the Department of the
Navy.  Naval activities represent a significant portion of land use
activity in the region and obviously have a bearing on San Diego's future
growth.  For instance, under recent Naval directives, additional ships
were reassigned to the San Diego base.  No Environmental Impact Statement
                                   16

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was filed on this major realignment until citizen action demanded that the

Navy address questions regarding the need for possible new support facili-

ties, etc.

     The Environmental Protection Agency has not been successful  in

filing a "309 action" to the CEQ under the Clean Air Act which would require

federal activities of this nature in San Diego to comply with the National

Environmental Policy Act.   Locally, there is little demonstrated

coordination of naval activities with long range planning activities in

San Diego.  Furthermore, federal installations claim statutory exemption

from any form of state review.  Consequently, military installations,

activities and any resulting pollutant discharges are not subject to

state review.

     The aforementioned institutional  description is indicative of a

common problem.   That there is  a definite relationship between land use
and subsequent air quality is undeniable and recognized by planners at all

levels; but the task of translating desirable air quality standards into the

land use control  arena suffers  from the  fragmentation  of  jurisdictional

power for land use decision making.
                                    17

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                               REFERENCES
2-1  State of California, The Resources Agency,  Air Resources  Board,
     "Identification of Air Quality Maintenance  Areas,"  Staff  Report,
     June 13, 1974.

2-2   Holzworth,  G. C.,  "A Study of Air Pollution  Potential  for  the
      Western United States,"  Journal  of Applied Meteorology,  Vol  1,
      pages  366-382, 1962.
                                   18

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                 3.0   EMISSION INVENTORY PROJECTIONS

3.1  LAND-USE AND TRANSPORTATION PROJECTIONS
     As mentioned in Section 2, the Comprehensive Planning Organization
is responsible for regional land-use and transportation planning in San
Diego.  CPO has made projections to the year 1995 of population, employ-
ment and land-use under four alternative growth scenarios:
          •  Existing Trends
          •  Controlled Trends
          •  Radial  Corridors
          •  Multiple Centers
     The Existing Trends alternative consisted of an extrapolation of
present trends in urbanization and automobile dependence.   Under Controlled
Trends, population growth is not diminished but is channelled into specific
areas.  Higher density development is encouraged in areas  which are already
urbanized, with the  emphasis on improving bus service within individual
communities.  The Radial Corridors alternative placed heavy dependence on
a fixed rail and/or  guideway mass transit system in determining the
projected urban form.  The Multiple Centers alternative was directed toward
the development of several urban "centers" around which development would
occur.*
     The projections of population, employment, and land-use were made with
the aid of two separate computer models -- the Interactive Population and
Employment Forecasting Model (IPEF) and the Urban Development Model CUDM).
The IPEF projection  is similar to the California Department of Finance
Series D-100 projections, as shown in Appendix B.
*The CPO Board of Directors recently approved a  set of regional  development
policies which are a mixture of the Controlled Trends  and Radial  Corridors
alternatives.   The development policies are essentially Controlled  Trends
but the transit system is to be a fixed guideway system, lesser  in  extent
than that envisioned under the Radial  Corridors  alternative,  with an
extensive feeder bus network.  The CPO staff is  presently preparing a
revised set of projections for land-use, transit ridership, and  VMT under
the approved policies.

                                    19

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     The Urban Development Model  is the same as the Project!ve Land-Use
Model (PLUM) implemented in the San Francisco Bay Area.   Briefly, this
model accepts the aggregated county population and employment forecast from
IPEF, distributes these among a multitude of small sub-areas  within the
county, and computes the resulting land acreages devoted to various purposes
within each sub-area.
     Projections of traffic volumes and transit ridership are made in
conjunction with the California Department of Transportation  (CalTrans).
CalTrans utilizes the standard modeling sequence of trip generation, trip
distribution, modal split, and traffic network assignment in  order to pro-
ject these key parameters.  Aside from the normal origin-destination survey
and gravity model techniques, one of the most up-to-date and  sophisticated
mode split models is employed.
     A more detailed description of the aforementioned projection
techniques is contained in Appendix F.
3.2  THE EPA PROMULGATED PLAN FOR ATTAINMENT OF THE OXIDANT STANDARD
     On November 12, 1973, EPA published its final regulations for the
control of reactive hydrocarbon emissions necessary for attainment of the
                                                  3-1
National Ambient Air Quality Standard for oxidant.     The plan consisted
the following elements:
          •  Degreaser substitution to non-reactive solvents
          •  Control of dry cleaning operations
          •  Metal surface coating substitution to non-reactive solvents
          a  Control of petroleum marketing evaporative emissions
          0  Federal aircraft emission control program
          •  Anticipated federal  motorcycle control program
          t  Mandatory inspection and maintenance of all light duty
             vehicles
          •  The State of California VSAD retrofit for 1966-70 model
             year light duty vehicles
                                    20

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          •  VMT reduction measures resulting in an 11% reduction
             in light duty vehicle VMT

          t  Additional VMT reductions necessary to attain the
             standard

     The inclusion of the last measure indicates that EPA was aware that

the preceding set of control  measures would not be sufficient to meet the

air quality standard for oxidant by 1977.

3.3  TECHNICAL ASSUMPTIONS

     As with any projection or prediction of a future situation, certain

assumptions had to be made concerning the effectiveness of various control

measures, and the appropriateness of various emission factors and

reactivity factors for different source categories.  This section

summarizes the technical assumptions used in this study.  In the case of

reactive hydrocarbon emissions, the bulk of the assumptions were determined

at a meeting between representatives from EPA, the California Air Resources

Board, the San Diego County APCD, and other organizations, on October 15,

1973.  The minutes of that meeting are reprinted as Appendix G to this

report.

3.3.1  Reactive Hydrocarbons and Carbon Monoxide

Organic Solvents

     EPA promulgated regulations call  for an 85-100% reduction of emissions

due to metal surface coating  operations through the substitution of non-

reactive solvents.  A 100% reduction has been assumed for this source

category.  The regulations further call for a 90% reduction from dry

cleaning operations through the use of activated carbon adsorption systems,

and a 100% reduction from degreasing operations via the substitution of

non-reactive solvents for this purpose.

     The reactivity of the emissions from these sources was chosen to be

consistent with the Los Angeles APCD Rule 66 definition of reactive compounds.

Growth in emissions from this source category has been assumed to be

proportional to population growth.
                                     21

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Petroleum Marketing
     The San Diego County APCD has enacted a stringent rule for the
recovery of evaporative hydrocarbon losses due to the marketing of pet-
roleum products, most notably gasoline.  The rule calls for vapor recovery
of disposal systems that have a 90% efficiency to be installed on bulk
terminals and vehicle service facilities by the end of 1974.

     The reactivity of emissions from these sources is assumed to be 93%,
according to the latest EPA information, while growth in emissions from
this source category is assumed proportional to the growth in VMT.
Fuel Combustion
     No controls have been promulgated with regard to hydrocarbon emissions
where a 100% reactivity factor has been assumed, in accordance with the
October 15, 1973 meeting.  See Section 3.3.2 concerning growth rate
assumptions.
Diesels
     EPA emission factors were combined with the EPA-sanctioned 99%
reactivity factor for emissions in this source category.  Diesel VMT
estimates were obtained from the San Diego County APCD.  Growth in this
source category is assumed to be proportional to the growth in total VMT.
Wild Fires
     Emissions due to wild fires cannot be ignored in an emission inventory
of reactive hydrocarbons, since it is precisely during the warm summer
months that wild fires are most likely to occur.  There appears to be some
difference of opinion regarding the assumption of a 100% reactivity for
wild fire emissions.   The San Diego County APCD assumed a 100% reactivity
in their 1972 inventory, while the California Air Resources Board used a
10% reactivity in their designation of air quality maintenance areas (3-11).
However, in keeping with the policy of regarding all emissions from combus-
tion processes as being reactive (see the technical assumptions meeting,
Appendix G), the 100% reactivity has been used for this study.
                                    22

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Aircraft
     Data concerning aircraft emissions in 1972 were obtained from the San
Diego County Air Pollution Control District, where 90% reactivity has been
assumed in accordance with the October 15 meeting.  Also in accordance with
the October 15 meeting, a 30% reduction in emissions from commercial
(civilian) operations has been assumed for the 1977 and later inventories.
Projections of aircraft activity were provided by the Comprehensive Planning
Organization and are reproduced in Table 3-1.   These projections were used
to generate the aircraft inventory projection  shown in Table 3-2.
            Table 3-1.   Forecasts of Aviation Demand,
                        San Diego Region
Year
1970 (Act)
1971
1972
1973
1974
1975
1980
1985
1990
1995
2000
Air Carrier Operations
(Thousand Movements)
78
83
89
95
102
no
139
190
247
303
662
1
Military A/C Operations
(Thousand Movements)
681
721
764
809
859
910
910
910
910
910
910
Source:  Comprehensive Planning Organization
                                   23

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            Table 3-2.  Aircraft Emission Projection (Tons/Day)

Commercial
Mil itary
TOTAL
TOTAL with
30% reduction
from commercial

Commercial
Mil itary
TOTAL
TOTAL with
30% reduction
from commercial

Commercial
Mil itary
TOTAL

1972*
3.867
4.073
7.94


1972*
3.45
3.67
7.12


1972*
19.9
8.2
28.1

1973
4.10
4.31
8.41


1973
3.66
3.89
7.55


1973
21.1
8.68
29.78
THC
1974
4.39
4.58
8.97

RHC
1974
3.92
4.13
8.05

CO
1974
22.6
9.22
31.82

1975
4.74
4.85
9.59


1975
4.23
4.37
8.60


1975
24.4
9.76
34.16

1977**
5.29
4.85
10.14
8.55

1977**
4.72
4.37
9.09
7.67

1977**
27.2
9.76
36.96

1980
6.05
4.85
10.90
9.09

1980
5.37
4.37
9.74
8.13

1980
31.1
9.76
40.86

1985
8.26
4.85
13.11
10.63

1985
7.34
4.37
11.71
9.51

1985
42.5
9.76
52.26
PARTICIPATES
Commercial
Mil itary
TOTAL
1972*
.146
.209
.355
1973
.155
.221
.376
1974
.166
.235
.401
1975
.179
.249
.428
1977**
.200
.249
.449
1980
.229
.249
.478
1985
.313
.249
.562
 *Baseline emissions obtained from the San Diego County
  Air Pollution Control  District
**Linear Interpolation
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Uncontrolled Engines

     This source category consists of exempted vehicles, competition

vehicles, motorcycles, dune buggies, lawn and garden equipment, farm

equipment, and off-road heavy duty vehicles and equipment.   A recent study

by Automotive Environmental Systems, Inc. (AESI) for the California Air

Resources Board was used to estimate both baseline and projected emissions
                 (3-2)
in this category.v   '

     The EPA promulgated regulation for motorcycles calls  for a 50%

reduction from new 2-stroke motorcycles beginning in 1977  and a roughly

90% reduction from all new motorcycles (such that they comply with new

car emission standards) beginning in 1979.   If the proper  regulations are

not promulgated to ensure that such reductions will occur,  the originally

proposed ban on 2-stroke motorcycle use during daylight hours of the "smog

season" (May-October) will go into effect.   For the purposes of this study,

it has been assumed that the appropriate regulations will  be promulgated

such that the motorcycle ban will not go into effect.

Light-Duty Vehicles

     There are a number of assumptions with regard to the  projection of

light duty vehicle emissions which resulted from the October 15 meeting.

     a)  Emission factors and deterioration factors developed by the
         Rand Corporation were used instead of the more generally used
         EPA factors.  Tables 3-3 and 3-4 contain a comparison of the
         two sets of factors.  Rand emission factors are slightly
         higher than EPA's, but the Rand deterioration factors are gen-
         erally lower.  Curiously, Rand's deterioration factors are a
         function of vehicle age only, and  not model  year.

     b)  The assumed effectiveness of various LDV control  measures is
         summarized in Table 3-5.  In the case of the inspection/
         maintenance program, the control effectiveness required by
         EPA in their regulations was assumed for this study, rather than
         the effectiveness agreed to in the October 15 meeting.  All
         other reduction factors shown in Table 3-5 were selected at the
         October 15 meeting.
                                    25

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Table 3-3.  Exhaust Emission Factors for LDV's (Grams/Mile)
THC
YEAR
?. 1977
1976
1975
1974
1973
1972
1971
1970
1969
1968
1967
1966
* 1965
RAND(3-3
0.36
0.36
0.80
2.4
2.4
2.5
2.9
3.6
4.4
4.5
4.5
4.8
12.0
) ERA(3-4)
0.23 .
0.23
0.33
2.7
2.7
2.7
2.9
3.6
4.4
4.5
4.6
6.0
8.8
CO
RAND^3'3)
2.9
2.9
7.7
19.0
19.0
19.0
34.0
36.0
39.0
46.0
50.0
50.0
113.5
EPA(3-4)
1.8
1.8
2.8
19.0
19.0
19.0
34.0
36.0
39.0
46.0
50.0
51.0
87.0
                               26

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Table 3-4.  Exhaust Deterioration Factors
VEHICLE AGE
THC
Post 1974

1970-74

1969

1968

1967

1966

Pre 1966


Rand
EPA
Rand
EPA
Rand
EPA
Rand
EPA
Rand
EPA
Rand
EPA
Rand
EPA
0
1.063
1.00
1.063
1.00
1.063
1.00
1.063
1.00
1.063
1.00
1.063
1.00
1.063
1.00
1
1.149
1.14
1.149
1.05
1.149
1.10
1.149
1.12
1.149
1.07
1.149
1.14
1.149
1.00
2
1.199
1.30
1.199
1.10
1.199
1.16
1.199
1.18
1.199
1.10
1.199
1.22
1.199
1.00
3
1.229
1.44
1.229
1.13
1.229
1.18
1.229
1.21
1.229
1.12
1.229
1.25
1.229
1.00
4
1.252
1.55
1.252
1.15
1.252
1.21
1.252
1.23
1.252
1.14
1.252
1.27
1.252
1.00
5
1.266
1.67
1.266
1.17
1.266
1.23
1.266
1.26
1.266
1.15
1.266
1.29
1.266
1.00
6
1.276
1.77
1.276
1.20
1.276
1.25
1.276
1.28
1.276
1.17
1.276
1.30
1.276
1.00
7
1.284
1.88
1.284
1.22
1.284
1.28
1.284
1.30
1.284
1.18
1.284
1.32
1.284
1.00
8
1.291
1.96
1.291
1.24
1.291
1.29
1.291
1.32
1.291
1.20
1.291
1.35
1,291
1.00
i 9
1.296
2.07
1.296
1.26
1.296
1.31
1.296
1.35
1.296
1.21
1.296
1.35
1.296
1.00

CO
Post 1974

1970-74

1969

1968

1967

1966

Pre 1966


Rand
EPA
Rand
EPA
Rand
EPA
Rand
EPA
Rand
EPA
Rand
EPA
Rand
EPA
0
1.055
1.00
1.055
1.00
1.055
1.00
1.055
1.00
1.055
1.00
1.055
1.00
1.055
1.00
1
1.111
1.16
1.111
1.18
1.111
1.42
1.111
1.24
1.111
1.11
1.111
1.13
1.111
1.00
2
1.165
1.34
1.165
1.32
1.165
1.53
1.165
1.35
1.165
1.18
1.165
1.21
1.165
1.00
3
1.186
1.50
1.186
1.38
1.186
1.59
1.186
1.41
1.186
1.23
1.186
1.24
1.186
1.00
4
1.195
1.62
1.195
1.40
1.195
1.63
1.195
1.47
1.195
1.29
1.195
1.25
1.195
1.00
5
1.199
1.75
1.199
1.44
1.199
1.68
1.199
1.53
1.199
1.35
1.199
1.28
1.199
1.00
6
1.200
1.88
1.200
1.47
1.200
1.71
1.200
1.58
1.200
1.40
1.200
1.29
1.200
1.00
7
1.200
2.00
1.200
1.50
1.200
1.75
1.200
1.63
1.200
1.46
1.200
1.31
1.200
1.00
8
1.201
2.10
1.201
1.51
1.201
1.79
1.201
1.67
1.201
1.50
1.201
1.32
1.201
1.00
^9
1.201
2.22
1.201
1.56
1.201
1.82
1.201 .
1.72
1.201
1.56
1.201
1.34
1.201
1.00
                     27

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      Table 3-5.   LDV Control  Measure  Effectiveness  Assumptions
Measure RHC Reduction, % CO Reduction ,%
Inspection/Maintenance
Retrofit (1955-65 Models)
Retrofit (1966-70 Models)
Oxidizing Catalyst Retrofit
Vehicles Eligible for Catalyst Retrofit:
Model Year
1966-70
1971
1972-74
15
25
14
70

% of



12
28
10
60

Vehicles Retrofi table
60
75
95
c)  EPA speed correction factors  were used  for this  study,
    although it was agreed at the October 15  meeting that
    speed correction factors  should not be  .
-------
                       Table 3-6.   1972  VMT Data
Vehicle Category
Light duty vehicles
Heavy duty vehicles
Diesels
Motorcycles
2-stroke
4-stroke
No. of
Vehicles
714,828
55,674
6,554

4,637
26,278
Avg. Annual
Mileage
9,398
10,519
53,458

5,000
5,000
Total
Annual VMT
6,717,953,544
585,634,806
350,363,732

23,185,000
131,390,000
% of
Total
86%
7.5%
4.5%

2.0%
 Average  Total  Daily  VMT:     21,393,225
 Source:   San  Diego  County Air  Pollution  Control  District
                      Table  3-7.   Projected  VMT  Data
         Avg. Daily
Year     VMT
 1975     20.9 Million  (9.8 Street
;                       11.1 Fwy)
% HDV  Avg. Fwy
VMT    Speed

 4%      50.34
Avg.          j
Non-Fwy. Speed

  29.66
1980
1985
1990
1995
Source:

24.8
30.2
35.7
38.8 Million
CPO/CalTrans



(17.0 Street
21.8 Fwy)
Controlled Trends
4
4
4
4 50.75
1995 Projection
-
-
-
29.83

     e)  The reactivity of LDV and HDV exhaust emissions was
         assumed to be 75% in both cases.  Crankcase and
         evaporative emissions were assumed to be 95% reactive
         in both cases.

     No one really  knows whether  the emission reductions anticipated  to

 result from the promulgated control strategy will actually occur, or

 whether such reductions will result in a commensurate reduction  in observed

 oxidant levels.  Serious questions remain with regard to the appropriate
                                    29

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reactivity factors for such key source categories as aircraft, diesels,
wild fires, and other open burning emissions.  Likewise, the growth rate
of motorcycle registrations as well as the turnover rate of the motor-
cycle population are key to determining the effect of the anticipated
federal new motorcycle control program.  Even in the case of automobile
emission and deterioration factors (for which two sets of data were avail-
able for this study) much uncertainty remains, especially with regard to
the speed correction factors and the deterioration factors for future
model years.
    Thus, in the face of such uncertainty, working assumptions are nec-
essary  in order to provide some basis upon which to proceed in a meaning-
ful control strategy.
    The preceding assumptions are, on the whole, considered to represent
an optimistic interpretation of probable future events.  The appropriate-
ness of these assumptions as opposed to any other reasonable alternative
set remains a moot question.
3.3.2   Particulate Matter
     This  section details the assumptions and methods  used in projecting
particulate emissions in the San Diego AQCR for the year 1985.   Baseline
emissions  for 1972 were obtained from the San Diego County APCD.
Stationary Sources
     Sources reporting no emissions in 1972 are expected to continue doing
so through 1985.   For all other sources (listed below) the following
methodology was  used:
     Emission Source Category                  Assumption #
     Process losses - point sources
         1)   Chemical                               1
         2)   Food and agriculture                   1
         3)   Metallurgical                           1
        (4)   Mineral                                 1
        [5)   Organic solvent usage                  3
                                    30

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      Emission Source Category
                                                Assumption #
      Combustion  of fuels  -  area  sources
         (1)   Industrial
         (2)   Commercial
         (3)   Residential
      Combustion  of fuels  -  point sources
         (1)   Steam electric power plants
      Waste disposal  by open burning  -  area  sources
         (1)   Agricultural debris
         (2)   Forest management

      Miscellaneous area sources
                                                    2
                                                    3
                                                    3
         (1)
         (2)
         (3)
         (4)
         (5
         (6
             Wild fires
             Structural fires
             Farming operations
             Construction/demolition
             Unpaved roads
             Other
3
3
1
3
5
5
 Assumption #1
               The Comprehensive Planning Organization  (CPO) of San
               Diego County has made projections of employment in
               22 different industrial categories which are defined
               as being "basic" (Tables 3-8 and 3-9).  The percent
               change in emissions is assumed to be equal to the
               percentage change in employment of the individual
               industry from 1972 to 1985. This assumption was
               utilized because there does not appear to be any
               information available which projects industrial out-
               put and the processes in a detailed fashion.  The
               errors involved in relating emissions to employment
               include not accounting for increased automation, effi-
               ciency and ''cleaner" (in terms of emissions) processes.
               Since the emissions from this category (fuel
               combustion) are for all industries in the county,
               the percentage change in emissions is assumed equal
               to the percentage change in employment for all
               industries, which is given in the TOTAL line of
               Table 3-9.
Assumption #3: The change in emissions is assumed equal  to the
               rate of growth of population in the county.  This
               has been projected by the CPO as:
Assumption #2:
               +39.1
                         1970 -  1,357,900
                       (  1972 -  1,445,851  (linear interpolation)
                       11985 -  2,021,300
                                     31

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        Table  3.8.   Industrial  Employment  Projection  Categories

ID NUMBER                        INDUSTRY

   1                              Agriculture
   2                              Mineral Extraction
   3                              Aircraft, Ordnance,  Shipbuilding, Misc.
   4                              Food  and  Kindred  Products
   5                              Apparel
   6                              Lumber, Wood,  Furniture,  Fixtures
   7                              Paper and Allied  Projects
   8                              Chemical  and Allied  Products
   9                              Misc.  Non Durables
   10                            Stone,  Clay and Glass
   11                            Primary and Febricated  Metals
   12                            Machinery, except Electrical
   13                            Electrical Machinery
   14                            Instrument and Related  Products
   15                            Railroad  Transportation
   16                            Trucking  and Warehousing
   17                            Water Transportation
   18                            Air Trans., Pipeline, and  Trans. Service
   19                            Wholesale Trade
   20                            Federal Government
   21                            State Government
   22                            Military

Source:   The Comprehensive Planning Organization of  San  Diego
                                   32

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1
1
1
1
•
1


1

1

1
1





1

1
1



1

1
1
1

1
Table 3-9. Industrial Employment

ID NUMBER
1

2
3
4
5
6
7
8
9
10

11
12

13
14
15
16
17
18
19
20
21
22

TOTAL

Source: The




1972
15,087

561
28,447
4,091
3,758
1,438
211
1,104
714
1 ,530

2,026
5,826

10,845
801
278
2,763
388
2,951
14,217
32,338
17,985
71,330

218,689

Comprehensive Planning




1985
10,297

711
33,647
4,291
5,458
2,088
361
1,504
1,314
2,130

3,476
12,576

20,995
1,751
278
4,263
588
4,701
23,217
43,188
21,885
74,530

273,249

Organization of

33


PERCENT CHANGE
-31.7
26 7
L, \J * /
18.3
4.9
45.2
45 2

71.1
36.2
84.0
39.2
71 ft
/ 1 . u
115.9
93 6
-/ *J • \J
118.6
n
\j
54.3
51.4
59.3
63.3
33.6
21.7
4.5

24.9

San Diego




-------
Assumption #4:
 Assumption #5:
 The  San Diego County APCD has obtained fuel con-
 sumption projections from San Diego Gas and Electric
 (SDG&E) through 1983 and these projections have been
 extrapolated to 1985.  SDG&E expects a decrease in
 natural gas availability and thus a corresponding
 increase in the use of fuel oil.  These two factors
 will  result in an  increase in RHC, CO, NOX and parti -
 culate emissions.  By using EPA and SDG&E source
 test emission factors, the APCD has arrived at pro-
 jected emissions from power plants.

 No change  in emissions from 1972 to 1985 is expected
 in this category.
Mobile Sources

     Sources reporting no particulate emissions in 1972 are expected to

continue doing so through 1985.   For all  other sources (listed below), the

following methodology was used:
     Emission Source Category

     Motor vehicles - on highway, powered by

        (1)  Gasoline
        (2)  Diesel

     Uncontrolled engines

     Aircraft

     Ships and Railroads
                                    Assumption #



                                         6
                                         7

                                         8

                                         1
                                         1
Assumption #6:
The promulgated EPA oxidant control plan for the
San Diego AQCR requires retrofitting all LDV of model
years 1966-1974 capable of using gasoline of 91 RON
or less with catalytic mufflers.  Of these model
years, 60% of the 1966-1970 model years, 75% of the
1971  model year and 95% of the 1972-1974 model  years
can be retrofitted.  In addition, to meet the 1975
emission standards, automobile manufacturers have
elected to install catalytic mufflers as standard
equipment.  These facts permit the projection of
particulate emissions in 1985 by the following
method:

    (a)  The particulate emission factor for
         automobiles equipped with catalytic
         mufflers is 0.16 grams/mile while for
         automobiles not so equipped, it is 0.43
         grams/mile. (3-8)
                                    34

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                   (b)  Based on the VMT distribution of the different
                        model years (Table 3-10) and the knowledge of
                        the percent of each model year equipped with
                        catalytic mufflers, a weighted particulate
                        emission factor in 1985 can be calculated as:

                        (.984)(0.16) + (.016) (0.43) = 0.16 gm/mi


                        weighted per-    weighted per-
                        centage of VMT   centage of VMT
                        driven by        driven by
                        automobiles      automobiles not
                        equipped with    equipped with
                        catalytic        catalytic
                        mufflers         mufflers.



                   (c)  The CPO has projected the daily LDV VMT in
                        1985 to be 29 x 106 miles.  However, due to
                        the EPA promulgated VMT reduction measures,
                        the CPO-predicted VMT figure has to be
                        reduced by 11%.  Thus, the daily LDV VMT in
                        1985 is 26 x 10^ miles.

                   (d)  Thus, particulate emissions from automobiles
                        is (1.76 x 10-7 tons/mile) (26 x 106 miles)
                        = 4.6 tons/day.

Assumption #7: On the basis of the CPO/Cal  Trans projections,  (Table 3-7)
               a 44% increase in VMT is expected from 1972-1985.  It is
               assumed that diesel  vehicle VMT increases accordingly.
               This figure is assumed to mean a corresponding increase
               in emissions.

Assumption #8: On the basis of the Automotive Environmental Systems, Inc.
               projection, a 40% increase in emissions is expected from
               1972-1985. (3-2)
                                    35

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Table 3-10.  Light Duty Vehicle Assumptions
Model
Year
1985
1984
1983
1982
1981
1980
1979
1978
1977
1976
1975
1974
1973
1972
1971
1970
1969
Sources:
r
Vehicle
Distribution'
7.9%
9.9%
9.5%
9.2%
8.9%
8.5%
8.2%
7.8%
6.7%
5.4%
4.2%
2.9%
2.2%
1.7%
1.5%
1.4%
4.4%
(1) EPA (3-7)
(2) Rand Corp.
(3) Appendix G
VMT
Distribution^
13.5%
14.7%
12.0%
10.0%
9.0%
8.0%
7.5%
6.7%
5.0%
4.0%
2.5%
1.5%
0.1%
0.1%
0.9%
0.7%
0.2%
(3-3)
Percent of Model Year Vehicle
Equipped w/Catalytic Mufflers3
io~o"
100
100
100
100
100
100
100
100
100
100.
95"
95
95
75
60
60_




Standard
"~ Equipment







— Retrofitted




                        36

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3.4  INVENTORY PROJECTIONS TO 1985

3.4.1  Reactive Hydrocarbons and Carbon Monoxide

     Table 3-11 contains the baseline and projected inventories of re-

active hydrocarbons and carbon monoxide for the San Diego air quality

maintenance area.  The inventories are plotted in Figures 3-1 and 3-2.  On

the basis of the data presented, the following conclusions may be drawn:

          •  The allowable emission levels for reactive hydro-
             carbons will  not be attained by 1985 under presently
             scheduled control programs.

          t  The allowable emission level for carbon monoxide will
             be attained by 1977 and maintained through 1985 under
             the presently scheduled control program.


          e  If the allowable emission level for reactive hydro-
             carbons is to be attained by 1977 through light duty
             vehicle VMT reduction, a 90% reduction would be
             required.

          t  By 1985, the most significant source category for
             reactive hydrocarbons will be the uncontrolled
             engines category.

     A detailed accounting of light and heavy duty vehicle emissions

computations is contained in Appendix F.  Since uncontrolled engines are

projected to become a very significant portion of the 1985 inventory of

reactive hydrocarbons, a detailed breakdown of emissions in this category

are contained in Tables 3-11 and 3-12.  As may be seen from Table 3-12,

the effects of the anticipated EPA control program for new motorcycles will

not become significant until after 1985.

3.4.2  Particulate Matter

     Table 3-14 contains the present and projected inventory of particulate

matter for the San Diego Air Quality Maintenance area.

     •  There is a slight increase in partfculate emissions from 61
        tons/day in 1972 to 61.2 and 64.0 tons/day in  1977 and 1985,
        respectively.   Despite a reduction in particulate emissions
        from automobiles (because of catalytic mufflers), increases
        in power plant emissions and wild fires result in higher parti-
        culate emissions in 1977 and 1985.
                                    37

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Table 3-11.   San Diego County Emission  Inventory






      1972         1977           1980        1985
STATIONARY
SOURCES
Organic
Solvent
Surface
Coating
Dry Cleaning
Degreasing
Pesticide
Petroleum
Marketing
Area Sources
Point Sources
Combustion
of Fuels
Industrial
Commercial
Residential
Steam Electric
Waste Disposal
(burning)
Agriculture
Forest
Other
Miscellaneous
Wild Fires
Structural
Fires
RHC CO
7.6
2.8
5.4
0.9

18.0
15.2
0.6 1.0
0.2 0.5
0.4 1.0
0.6 1.8
0.1 0.3
1.8 7.6
0.1
7.0 29.5
0.1 1.3
RHC CO
1.2
0.4
-
0.8

1.8
1.5
0.66 1.1
0.25 0.6
0.49 1.2
1.9 2.8
0.09 0.26
1.8 7.6
0.12
8.1 33.9
0.11 1.5
RHC CO
1.4
0.4
-
0.72 -

2.0
1.7
0.7 1.18
0.28 0.7
0.55 1.4
2.3 3.5
0.08 0.24
1.8 7.6
0.14
8.7 36.6
0.12 1.6
RHC
1.7
0.5
-
0.6

2.3
2.1
0.75
0.33
0.65
1.8
0.07
1.8
-
9.8
0.14
CO

-
-
-

-
-
1.25
0.82
1.64
2.6
0.20
7.6
0.16
41.3
1.8
  60'7   43J   19J   49J   20'7   53'°   21«5
                      38

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      Table 3-11.  San Diego County Emission Inventory (Continued)
                   1972           1977         1980          1985
MOBILE
SOURCES
Diesel
Aircraft
Ships
Railroad
Uncontrolled
Engines
LDV
HDV
RHC
0.8
7.1
0.1
0.1
14.8
111.8
18.4
CO
4.6
28.1
0.1
0.1
120.0
775.0
140.0
RHC
0.9
7.7
0.12
0.1
16.4
30.5
12.8
CO
5.4
37.0
0.12
0.1
128.0
172.0
133.0
RHC
1.0
8.1
0.13
0.1
17.1
16.4
9.4
CO
5.8
40.9
0.13
0.1
133.0
84.0
140.0
RHC
1.2
9.5
0.15
0.1
18.7
9.0
7.0
CO
6.6
52.3
0.15
0.1
140.0
38.0
159.0
Mobile
Source Total: 153.1  1068.0  68.5  475.6   52.2  403.9   45.7  396.2
   TOTAL:     214    1111    87.6   525     72.9   457     68.2  454
Allowable
emissions     RHC       CO
(tons/day)    53.5      522
                                    39

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220-r
200 +
180 +
 160 +
 140 +
 120 +
 100 +
  804-
  60 +
  40 +
  20-
                 1-. Organic Solvent
                 2. Gasoline Marketing
                 3. Fuel Combustion
                 4. Waste Disposal (burning)
                 5. Diesels, Ships, and Railroads
                 6. Aircraft
                 7. Uncontrolled Engines
                 8. HDV
                 9. LDV


              -  -   Allowable Emissions
                 1972
1977
                                                       1980
                                      1985
           Figure  3-1.   Emission  Projection  for  Reactive  Hydrocarbons
                                          40

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1100 -r-
1000--
 900 --
 800 --
 700--
 600--
 500 --
 400 --
 300--
 200--
 100--
   0 ->-
 1 Fuel Combustion
 2 Waste Disposal  (burning)
 3 Diesels, Ships, and Railroads
 4 Aircraft
 5 Uncontrolled Engines
 6 HDV
 7 LDV

-  Allowable Emissions
                 1972

7


6


5


4
2
1977















7

6


5


4
2
1980










3

1

7


6


5


4
2
1985
              Figure  3-2.   Emission Projection for Carbon Monoxide
                                          41

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        Table 3-12,  AESi  Total  Hydrocarbon Inventory and
                     Projections  for San Diego County
Exempted Vehicles
Competition Vehicles
Motorcycles
Snowmobile, ATV's,
   Dunebuggies
Lawn & Garden Equipment
Farm Equipment
Off-Road Heavy Duty

          Total
        Table 3-13.
Exempted Vehicles
Competition Vehicles
Motorcycles
Snowmobiles, ATV's,
   Dunebuggies
Lawn and Garden Equipment
Farm Equipment
Off-Road Heavy Duty

          Sub-Total
   Anticipated reductions
   due to federal
   cycle control  program.

          Total
1980 1980 Assumed
1970 THC Growth Factor THC Reactivity
4.27
.03
4.72
.91
nt 1.92
.45
3.84
16.14
Reactive Hydrocarbon
for the Uncontrolled

1972
2.95
.02
4.92
0.80
ment 1.64
0.38
4.05
14.76
.ions
or-
iram. 0
14.8
0.32
1.35
1.79
1.48
1.34
1.19
1.33
1.37
0.04
8.45
1.35
2.57
0.54
5.11
19.43
80%
80%
90%
80%
80%
80%
99%
Emission Projections
Engines Category
RHC,
1977
1.79
.02
6.60
0.98
1.90
0.41
4.68
16.38
0
16.4
Tons/Day
1980
1.10
.03
7.61
1.08
2.06
0.43
5.06
17.37
-0.3
17.1

1985
0.90
.03
10.65
1.34
2.41
0.47
5.89
21.68
-3.0
18.7
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               Table 3-14.   Particulate Emissions  (Tons/Day)


 EMISSION  SOURCE CATEGORY
                                                       1972    1977    1985

 I.  Stationary Sources

    A.  Process losses-point sources

        (1)  Chemical           .                        0.3     0.22    0.27

        (2)  Food and agriculture                       3,7     2.2     1.7

        (3)  Metallurgical                              0.1     0.1     0.14

        (4)  Mineral                                   17i9    13-0    15>2


    B.  Combustion  of  fuels-area  sources

        (1)  Industrial                                 3.6     3.9     4.5

        (2)  Commercial                                 0.9     1.1     1.3

        (3)  Residential                                1.1     1.3     1.5


    C.  Combustion of fuels - point sources

        (1)  Steam electric power plants                5.3    10.81   10.2



    D.  Waste disposal  by open burning-area sources

        (1)  Agricultural  debris                       0.1      0.09    0.07

        (2)  Forest Management                         1.5      1.5     1.5


    E.  Miscellaneous Area Sources

        (1)  Wild  fires                                  5<9       6'8     8-3

        (2)  Structural fires                            °'4       °-5     °'6

        (3)  Farming operations                          OJ       °'09    °'07

        (4)  Construction/demolition                     °'6       °'67    °-8

        (5)  Unpaved roads                               8-7       8-7     8-7

        (6)  Other                                       °-3       0-34    0.4


TOTAL STATIONARY SOURCES                               50.5     51.3    55.3
                                    43

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       Table 3-14.  Participate Emissions (Tons/Day) (Continued)

                                                   1972     1977     1985
II.   Mobile Sources
     A.   Motor vehicles - on highway,  powered by:
         (1) Gasoline                               7.8      6.6      4.6
         (2) Diesel                                 0.3      0.34    0.4
     B.   Uncontrolled Engines                       1.9      2.2      2.7
     C.   Aircraft                                    .36      .45     .56
     D.   Ships and Railroads                        0.2      0.24    0.3
TOTAL MOBILE SOURCES                 -              10.6      9.9      8.56

TOTAL INVENTORY                                    61.1     61.2     63.9

ALLOWABLE EMISSIONS                                     27.5 tons/day
                                    44

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70 -r
60--
50--
40--
30-
20--
10--
               1972
1977
                                       1, Point Source Process Losses
                                       2. Fuel Combustion
                                       3. Miscellaneous  (wild fires, constr.)
                                       4. Gasoline Powered Motor Vehicles
                                       5. Uncontrolled Engines
                                       6. Aircraft
                                       7. Diesels, Ships,  and Railroads
                                         Allowable Emissions
1985
    Figure 3-3.   Projected Emissions of  Participate Matter
                                   45

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     As may be seen from this inventory, further reductions in parti cul ate
matter emissions are necessary in order to meet the primary air quality
standard for this pollutant.  This point will be further discussed in
Section 4.2.

3.4.3  Oxides of Nitrogen and Sulfur Dioxide
     The air quality data analyzed in Appendix A indicate that ambient
concentrations of SOg and NOX are presently below the National Ambient
Air Quality Standards.   The California Air Resources Board projects that
ambient concentrations  for both pollutants should continue to be below
the standards.  The analysis performed for the present study confirms this
result.
     The data indicates that a roughly seven-fold increase in SOg emissions
may be tolerated before the air quality standard for this pollutant is
exceeded.  Since S02 emissions are projected to increase by no more than a
factor of three by 1985, even under pessimistic assumptions concerning fuel
sulfur content, S02 is not considered to pose maintenance problems.
     In the case of oxides of nitrogen, present ambient concentrations
are much closer to the primary air quality standard for this pollutant.
However, the federal new car control  program is expected to more than
offset any growth in NOX emissions which might occur from other sources
through 1985.
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3.5  COMPARISON UITH THE RESULTS OF PREVIOUS STUDIES

     There have been five previous studies of the San Diego oxidant

problem:

          •  The California Air Resources Board Implementation Plan
             for the San Diego Air Quality Control  Region.  (3-9)

          •  A Rand Corporation study of attainment strategies for
             photochemical  oxidants.  (3-10)

          •  An EPA technical support document for the attainment
             of the oxidant air quality standard by 1977.  (3-7)

          •  A California Air Resources Board study for the designation
             of air quality maintenance areas within the state. (3-11)

          t  A local task force study of attainment strategies for
             San Diego. (3-12)

     This section is devoted to a comparison of the result  obtained here

with the results of these previous studies, and where possible to the

explanation of apparent discrepancies.

3.5.1  The Rand Study

     The Rand Corporation developed an attainment plan for  San Diego with

regard to photochemical oxidant.  The Rand study concluded  that the oxi-

dant standard could be attained and maintained through 1995 without the

necessity of a massive VMT reduction:

     "...We estimate that the nominal strategy can achieve  the
     oxidant standard in 1983 with no mileage reduction, but an
     alternative strategy ... can achieve it in 1975	"

     "Significantly, once a standard has been met,  it stays met
     through 1995.  This is true for reactive hydrocarbons  (oxidant)
     and carbon monoxide	   Since we believe the growth  rates used
     give an. upper bound on emissions,  this suggests that the near-
     term strategies we have presented should meet the National
     Primary Air Quality Standards in 1995 regardless of which trans-
     portation/land-use concept San Diego ultimately adopts."

     The "nominal strategy" referred to above consists only of the

presently mandated local, state and federal controls, excluding the EPA

promulgated plan for attainment of the oxidant standard by  1977.  The

alternative strategies consist of strict organic solvent use controls,  an
                                    47

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inspection/maintenance program,  oxidizing catalyst retrofit of 1955-74
light duty vehicles, stringent aircraft emission  control  measures  (80%
reduction), additional evaporative control  retrofit of 1955-69 light duty
vehicles, and a mileage surcharge measure to produce a nominal  (4.3%)  VMT
reduction.
     The reasons for the apparent discrepancy between the Rand result  and
the result obtained here may be summarized as follows:
          •  The Rand study used 1970 as the base year, with
             a maximum oxidant of 0.31  ppm predicted by a
             Larsen analysis of the monitoring data.
     Since the present study is based on a 1972 baseyear with an essentially
equivalent maximum oxidant measurement (0.32 ppm), the allowable emissions
are reduced from 61.5 tons/day to 53.5 tons/day.
          •  The Rand inventory did not include emissions from
             uncontrolled engines (with the exception of motor-
             cycles) as well as from wild fires and structural
             fires.
     The addition of sources to an inventory over which no control  is
anticipated increases the burden of control in other areas.
          t  The oxidizing catalyst retrofit recommended by Rand
             will not be completely implemented by EPA under its
             final promulgation.
     Rand assumed that all light duty vehicles of model year 1955-74
could and would be retrofitted with oxidizing catalysts.  The EPA  regulation
applied only to those cars which could run on 91  RON gasoline.  In addition,
the EPA regulation applied only to 1966-74 light duty vehicles.
          •  Rand assumed an 80% reduction of aircraft emissions was
             possible, largely based on the modification of ground
             operating procedures at airports.
     EPA could not include ground operating procedure modifications in its
final promulgation, since discussions with the Federal Aviation Administra-
tion were still in progress.  No agreement has been obtained to date with
regard to the feasibility of such a control measure.
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3.5.2  The California Air Resources Board Implementation Plan

     The latest proposed revision to the State of California Air Resources

Board implementation plan for the San Diego Air Basin indicated that

attainment of the oxidant standard would occur by 1980.   The ARB plan is

based on a maximum oxidant measurement of .40 ppm in 1970.   The resulting

allowable emissions level under this combination was 43  tons per day,

compared to the 53.5 tons allowed here.  The ARB's result was based on a

95% reduction in aircraft and ship emissions in addition to proposing an

oxidizing catalyst retrofit for 1966-74 light duty vehicles and 1962-74

heavy duty vehicles.  Other elements of the ARB proposal are an inspection/

maintenance program for light duty vehicles, gasoline marketing controls,

and a 20% VMT reduction due to unspecified measures.  Unfortunately, the

ARB neglected wild fires and uncontrolled engines in their inventory.

3.5.3  The EPA Promulgated Plan for Oxidant Control

     The EPA plan for San Diego has been previously  described in Section 3.2,

The difference between the projected inventory published in the Federal

Register and the projection developed for this study is  due to two main

factors:

          •  EPA neglected emissions due to uncontrolled engines
             (with the exception of motorcycles), wild fires, and
             other burning,

          •  EPA claimed roughly a 74% reduction in  motorcycle emissions,
             presumably as a result of the proposed  motorcycle ban.

     The regulation concerning motorcycles is written in an "either/or"

fashion.  It states that the motorcycle ban will not go  into effect if

EPA promulgates regulations for new motorcycles, as  described previously.

     It is felt that the probability of EPA regulating emissions from new

motorcycles is much higher than the probability of EPA banning the use of

two-stroke motorcycles during daylight hours of the  smog season.  Unfor-

tunately, stringent standards are not anticipated to apply  to new

motorcycles until 1979.
                                    49

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3.5.4  The Local Agency Task Force Plan for Attainment
     The ad hoc San Diego Air Pollution Control Task Force was established in
response to the proposed EPA transportation control  plan for the San Diego
Air Basin (issued on August 15, 1973).  The task force consisted of
representatives from the City and County governments, the Comprehensive
Planning Organization, the California Department of Transportation, the
San Diego Transit Corporation, and the San Diego Unified Port District.
     The goal  of the task force was to provide alternatives to the EPA-
proposed transportation control measures.   The preliminary study results
indicated that a modest 10 percent reduction in daily vehicle miles trav-
eled in addition to previously proposed technological controls was nec-
essary to meet the oxidant standard by 1977.  The study further indicated
that such a VMT reduction could be accomplished through measures such as
improving the road system, improving bus service, instituting a 4-day
work week, and applying various tax incentives and dis-incentive measures
to discourage auto use and encourage car pooling and bus riding.
     Unfortunately, according to preliminary documentation, this study
used 1970 as its base year, and assumed that EPA would be controlling
emissions from aircraft and ships in a fashion commensurate with reductions
anticipated for motor vehicles.  Also, emissions from uncontrolled engines
were apparently neglected.
3.5.5  The California Air Resources Board Maintenance Area Designation Study
     The ARB,  in their analysis of potential air quality maintenance areas,
has identified San Diego as having maintenance problems with regard to oxi-
dant, carbon monoxide, and particulate matter.  The present study is in
agreement with this conclusion for oxidant and particulate matter; how-
ever, three differences must be noted.

     First, the ARB used growth factors for certain industrial categories
which were based on the Bureau of Economic Analysis (U.S. Department of
Commerce) projections as presented in "Population and Economic Activity
in the United  States and Standard Metropolitan Statistical  Areas, Historical
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and Projected 1950-2020," (July 1972).  These Department of Commerce pro-

jections were based on the DOC Series C population projections which are

significantly lower than either the California Department of Finance

Series  D-100 projections or the local CPO population projections used for

this study  (see Appendix B).  Interestingly, the ARB used the Department

of Finance  D-100 projections for those source categories that were con-

sidered more closely related to population.  Further, in using the

Department  of Commerce projections, the ARB used "earnings indices" of the

various industrial categories as the measure of growth in emissions.

These indices result in significantly higher future year emissions than

the technique employed in the present study.

     Second, in the case of particulate matter, the ARB used a 1971  annual

average concentration of 88.7,ug/M3 to compute the allowable emission limit,

while in 1972 an annual  average of 97 jug/M^ was recorded.   The allowable

emission level  used in the present study is therefore lower than that used

by the ARB.

     In the case of carbon monoxide, the projections previously presented

indicate that the CO standard will  be attained by 1977 under the present

EPA control  plan, and subsequently maintained through 1985.

3.6  ANTICIPATED FUEL SHORTAGE IMPACTS

     In light of the recent shortages of petroleum-based fuels, an obvious

question is:  What would be the impact of a fuel  shortage  on the emission

projections  made and how would this affect the control  requirements?

     According  to Federal  Energy Office fuel  allocation procedures (3-13),

private automobiles and  commercial  airlines would receive  lowest priority.

The total  RHC emissions  from LDV,  aircraft and gasoline marketing in 1985

are 18.5 tons/day.   From Table 3-11, we note that a further reduction of

14.7 tons/day of reactive  hydrocarbons is required to attain the standard

in 1985.  Thus,  in order for a fuel shortage to obviate the  need for addi-

tional  controls, the shortage must  be of such  a magnitude  that 80% of both

automobile and  commercial  aircraft  activity is  stopped.  Although FEO pro-

cedures  are  not  quite  accurately reflected in  this  example,  the conclusion
                                    51

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of a more detailed analysis would not be substantially different from that
arrived at here.  No reasonable projection of possible fuel  shortages will
result in the elimination of the need for additional  control  measures to
achieve the oxidant standard in San Diego by 1985.
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                               REFERENCES
3-1     The Federal  Register,  Vol.  38,  No.  217,  "California Transportation
       Control  Plan", November 12, 1973.

3-2    Automotive Environmental Systems,  Inc.,  "Uncontrolled Vehicle
       Emissions Study",  for  the State of  California  Air  Resources
       Board, October 30, 1973.

3-3    Mikolowsky,  VI. T., "The Motor Vehicle  Emission and Cost  Model
       (MOVEC):  Model  Description and Illustrative Applications",
       The Rand Corporation,  December 1973.

3-4    U.  S.  Environmental  Protection Agency, "Compilation of Air Pollutant
       Emission Factors", AP-42, revised September 1973.

3-5    J.  Hardway,  San Diego  Gas and Electric Company, Private  Communication,
       June 1974.

3-6    M.  Ziol  and  S. Moody,  Southern California  Edison Company, Private
       Communication, May 1974.

3-7    Environmental  Protection Agency, Technical  Support Document  for
       the San  Diego  Intrastate Air Quality Control Region,  July 31,  1973.

3-8    "The Development of a  Particulate Implementation Plan for the
       Los Angeles  Region,  Report #2-Emission Inventories and Projections",
       Preliminary  Draft, TRW, Inc., June  1974.

3-9    State of California Air Resources Board,  "The  State of California
       Implementation Plan for Achieving and  Maintaining  the National
       Ambient Air  Quality Standards", January  30, 1972,  and Proposed
       Revision for San Diego, April 23, 1973.

3-10   Goeller, Bruce, et.  al., "San Diego Clean  Air  Project:  Summary
       Report", The Rand Corporation, December  1973.

3-11   State of California Air Resources Board,  "Identification of  Air
       Quality Maintenance Areas", Staff Report,  June 13, 1974.

3-12   San Diego Air Pollution Control Task  Force, "Cleaning Up the Air -
       Local  Transportation Control Plan for  the  San  Diego Air  Basin",
       Preliminary  Draft, October 5, 1973.

3-13   The Federal  Register,  Vol. 39, No.  10, "Petroleum  Allocation and
       Price Regulations," January 15, 1974,  page 1924.
                                    53

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                        4.0  ATTAINMENT STRATEGIES

     The emission inventory projections presented in Section 3 indicate
that the National Ambient Air Quality Standards for oxidant and par-
ticulate matter will  not be achieved under present control  programs.
This section is devoted to a discussion of additional  strategies
required to achieve the standards within the 1977-1985 time frame.
4.1  REACTIVE HYDROCARBON REDUCTION MEASURES
     In the years subsequent to the implementation of the EPA hydro-
carbon control  program, the major source categories will  be wild fires
and forest waste disposal, jet aircraft, uncontrolled engines, and
light- and heavy-duty gasoline powered motor vehicles.  Together,
these sources account for 86% of the total  reactive hydrocarbon
emissions in 1977, and 78% by 1985.
     In order to attain the standards by 1977,  100% LDV VMT reduction
would be required.  Alternatively, a strategy geared toward attainment
of the air quality standard within the 1980-85 time period should
consist of the following elements:
          •  Heavy duty vehicle inspection/maintenance, oxi-
             dizing catalyst retrofit, and new vehicle emis-
             sion standards comparable to light duty vehicle
             emission standards.
          •  Motorcycle retrofit control program requiring a
             minimum 50% reduction in emissions from pre '79
             motorcycles.
          •  Aircraft control program including modification of
             ground operating procedures, which also applies to
             the military component of the aircraft activity in the
             County.   A 60% reduction in emissions due to such a
             program is not an unreasonable expectation.
     The 1970 Clean Air Act required that within five years, a 90%  reduc-
tion in emissions of hydrocarbons, carbon monoxide, and oxides of nitrogen
from automobiles should be accomplished.  The technology for accomplishing
                                    54

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 this task was not developed at that time, and today it appears that
 the standards for hydrocarbons and carbon monoxide will be achieved,
 albeit within six years instead of five.  With this example in mind,
 anticipating a reduction of 60% from previously uncontrolled sources
 over a period of 5 to 10 years is not an unreasonable expectation,
 provided that the appropriate standard-setting procedures are initiated
 soon.
     The State Air Resources Board as of April 23, 1973, has proposed
revision to the State Implementation Plan which includes the retrofit of
1962-74 model year heavy-duty vehicles with oxidizing catalysts.
     Such a control measure is a logical "next step" in a situation where
maximum LDV controls are insufficient for attainment of the standards.
It is also prudent to gain experience in the application of such controls
before extending them to additional vehicle populations.  Heavy duty
vehicle controls should therefore be a principal  element in a strategy
to meet the standards by the 1980-85 period.
     In the case of motorcycles, new "clean" motorcycles will have begun
to enter the market during the 1980-85 time frame.  Depending on the actual
target year decided upon for attainment, retrofit program for older motor-
cycles could result in significant reductions from these sources.   Since
the technology is not currently available for accomplishing such reduc-
tions, no precise estimate of the control potential may be made.
      Aircraft controls hinge on cooperation  between EPA, the Federal
 Aviation Administration, and the military.  Assuming that such coopera-
 tion is obtained within the next few years, appropriate ground operating
 procedures should be in effect by 1980.  In addition, further control
 of jet exhaust emissions should be feasible within the 1980-85 time
 frame.
     To summarize,  a 60% reduction  from  motorcycles, heavy duty  vehicles,
and jet  aircraft would provide  for  attainment of  the allowable emissions
by 1985.  (Attainment by  1980 would  require an 80% reduction  from the  same
source categories.)   Under  such  a  control  program,  light duty vehicles
                                     55

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again become the largest single source  category,  accounting  for  almost
20% of the total inventory in 1985.   Under the  Controlled  Trends  alterna-
tive, VMT is projected to increase by almost 30%  within  the  1985-1995 time
period, while the effect of the federal  new car control  program  is  expect-
ed to become insignificant beyond 1985.   Assuming that such  reductions
do occur, the proper time frame for consideration of  maintenance  measures
should be the 1985-1995 period rather than the  1975-1985 period  originally
conceived.
4.2  PARTICULATE MATTER
     In order to assess achievement and later maintenance  of the  federal
secondary standard for suspended particulate matter (60  micrograms  per
cubic meter), a discussion of the current monitoring  stations and probable
sources of the particulate loading is necessary.  The  problem is  more
complex than is the case with other air pollutants since particulates
cover a wide range of compounds from a  wide variety of  sources.   In
addition, some of the mass of particulates may  be formed in  the  atmos-
phere from reactive gases, while another portion  consists  of "dust"
and "smoke" or relatively inert matter  from both  industrial  and  natural
sources.  Perhaps more than other air pollutants, particulate concen-
trations vary considerably in an urban  area, depending on  the proximity
of sampling to local emission sources.   Despite the uncertainties
involved, an attempt to account for the particulate loading  in San  Diego
is made below.
     The two APCD stations which monitored for  suspended particulates
during 1972 reported 79 and 97 yg/m  at downtown  San  Diego and El Cajon,
respectively.  The downtown station is  about 35 feet  from  ground level,
while at El Cajon it is only 14 feet.  Although the downtown station
is in a heavily travelled business district, major freeways  are  to  the
east and downwind of the sampling site.  At El  Cajon, however, a
major freeway runs both to the north and west of  the  station.  Lead
concentration was observed to be often  twice as high  at  El Cajon as
downtown  during  1972, further suggesting a significant automotive
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contribution to the loading at El Cajon.  The height difference makes

it difficult to assess possible local traffic contributions, although

the El Cajon station is 150 feet from the nearest street.  Both stations

tend to have higher values in the winter quarter than in summer,

suggesting a non-photochemical nature to the particulate mass.

     A line source diffusion model (see Appendix H) was applied to the

freeway (Interstate 8) near El Cajon to estimate the maximum potential

magnitude of particulates from this source which might be expected at

the monitoring station, roughly 800 meters downwind.  Assuming 100,000

vehicles per day, 2 meter/sec wind speed, and 0.43 grams of particulates

per mile per car, about 40 micrograms per cubic meter resulted.

     Since a heavy concentration of  mineral  industries  occurs  in  Mission

Valley (generally upwind of El Cajon), a point source diffusion model

was applied to the approximately 9.5 tons per day industrial and mineral

emissions in this area.  The distance between El  Cajon and the sources

would tend to minimize the error due to the non-point nature of the

emissions.  A 20 kilometer distance to El Cajon was assumed and again,

2 meter/sec wind speed.  A contribution of about 20 micrograms per

cubic meter resulted from this calculation.

     Using 30 Mg/M3 as a background (ARB), 90 /ug/M3 is the expected

concentration at El  Cajon.  These calculations are  somewhat low

compared to the observed concentration of 97 Mg/M , but the potential

magnitude of the sources is illustrated.

     Emissions of particulates from industrial  sources were to be

reduced by 33 percent by January 1, 1974, according to San Diego APCU

regulations.*  Control  of automotive emissions of particulate matter

are expected to decrease by about 15% by 1977.   The 1972 emission

inventory shows 61  tons per day total suspended particulates.   Sixty-

one tons/day and 64 tons/day are expected in 1977 and 1985 respectively,

illustrating that no overall  reduction is projected through 1985.  The
'Rule 52, San Diego APCD.
                                    57

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crudeness of the calculations reflects the lack of knowledge about the
problem but shows that further controls than are currently planned will
be necessary in order for air quality standards to be met.  With addi-
tional monitoring closer to major sources, the spatial  uncertainty of
source contributions might be resolvable.   Additionally,  composition data
at El Cajon, such as sulfate, nitrate, organics, and perhaps calcium,
would provide a more reliable identification of the sources of the parti-
culates.
      To  summarize, the plume computations indicate that neither industrial
nor motor vehicle emissions may be neglected as possible sources of the
high  particulate loading at El Cajon.  In the absence of additional
data,  it is not possible to define the proper control strategy to meet
the  standard at this location.  However, controls are scheduled to go
into  effect in both of the aforementioned categories which should
reduce  their particulate emissions significantly.
      If additional data confirms the estimates presented here, a
promising additional control which should dramatically reduce automobile
exhaust  particulate emissions is the removal of sulfur from gasoline.
By 1977  essentially all of the exhaust particulates from autos will
consist  of sulfuric acid mist due to the anticipated use of oxidizing
catalytic converters.  The removal of sulfur from gasoline should
therefore produce an almost total removal  of particulate emissions from
auto  exhaust.  In addition, it has been estimated that the cost of
removing sulfur from gasoline would be roughly  1.5 cents  per gallon,
with  a  required lead time of roughly three years.*
 *Statements of  Sun  Oil Company and Shell Oil Company presented at
  Hearings  before  the  Committee on Public Works,United States Senate,
  "Compliance with Title  II  (Auto Emission Standards) of the Clean
  Air  Act," November 5 and 6,  1973, serial number 93-H23.
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          5.0  POTENTIAL MEASURES FOR THE MAINTENANCE OF AIR QUALITY


     The central problem of air quality maintenance planning is how can

 pollutant emission levels be maintained (such that air quality standards

 are not violated) in the face of continuing urban growth?  Technological

 solutions for reducing emissions constitute one alternative; however, such

 solutions cannot be relied upon to ensure maintenance in the long term.

 In all probability, the set of currently known technological solutions

 will be exhausted by 1985, since these solutions will  have been either

 executed or no longer timely.  Other alternatives which are geared toward

 minimizing emissions by controlling the manner in which the growth occurs

 must be considered in the development of an air quality maintenance plan.

 Indeed, it is imperative that a series of maintenance  strategies be insti-

 tuted as soon as possible in order to realize maximum  effectiveness by

 the 1985-1995 time frame.  This section is devoted to  a description of

 some of these measures as well  as the context in which they might be

applied.


5.1  STATE LEVEL LAND USE CONTROL MEASURES

     Environmental  Impact Statement (California Environmental  Quality Act)

     The procedures for environmental  impact reporting, as set forth by

the California Environmental  Quality Act (1970) require that an impact

statement be prepared for all state initiated activities and all  private

actions that are sanctioned by local  governmental  police power authori-

 ties, e.g.,  issuance of a subdivision permit to a private developer.

 CEQA, however, does not provide veto power over any decision to proceed

with a project,  even if adverse effects on the environment are incurred.

     Recreational Land Regulation

     Recreational land represents a land use category  for which regula-

 tions similar to residential  zoning ordinances might be warranted in order

 to ensure development that conforms with air quality standards (or other

community goals  and objectives).


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     Taxation Policy to Preserve Non-Developed  Areas
     The concept of taxation policy for shaping future  growth  has  typically
been manifested in two methods:
     (1)  Capital gains tax on land development where the tax rate
          is inversely related to the duration of the land holding.
     (2)  Taxation of agricultural or undeveloped land based on its
          use, rather than on market value; in addition, the differ-
          ence between the tax on use and the tax on the market
          value could be deferred until the time of development.
Both of the policies are designed to .exert some braking effect on rapid
development, which, in turn has an indirect effect on air quality mainten-
ance.  They are, in effect, incentives for low-intensity land use.  The
California Williamson Act was enacted in 1965 for this purpose but its
effectiveness has been mitigated by the absence of requirements to relate
lands eligible for special tax rates to a regional land-use plan.
     Emissions Allocation Procedures
     Emissions allocation is a maintenance measure that requires  that
emissions of pollutants be limited to prescribed levels within an airshed,
air basin, AQMA, or portion thereof.  Implementation of an emission allo-
cation procedure would require:  (1) a detailed inventory of air pollution
emissions in planning sub areas of an AQMA or air basin, (2) a designa-
tion of maximum allowable emissions in each sub area to achieve and main-
tain air quality, (3) an estimation of future sub area emissions  as indi-
cated in (regional) land-use and transportation plans, (4) a land-use
and transportation plan that would not exceed prescribed limits,  (5)
adoption of measures to meet air quality standards, based on above find-
ings, and (6) usage of environmental impact reporting to determine emis-
sions of  proposed developments.
     A bill has been proposed in the California Legislature (SB 1543-
Nejedly)  which would mandate the application of this procedure in the
11 air basins of California and vest primary responsibility for allocating
emissions  levels  in basinwide coordinating councils  (BCCs).  A major weak-
ness of  emissions  allocations procedures as conceived  in this bill  is  the
inadequate  state-of-the-art  technology to  relate  a given spatial emis-
sions pattern  to  the  oxidant levels  resulting  from such a distribution.
(i.e.,  it  cannot  be demonstrated  at  the present time that one pattern
results  in  cleaner  air  than  another pattern with the  same total emissions.)
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     A-95 Review Process

     An A-95 review agency has been established on a regional basis for

the purpose of ensuring the coordination of Federal programs and projects

with State, regional and local problems.  It is designed to provide a

structure for interjurisdictional cooperation in the reviewing of local

planning decisions for compliance with regional plans.

5.2  REGIONAL LEVEL LAND USE CONTROL MEASURES

     Direct Source Review

     Direct source review procedures (like those in effect) are designed

to monitor the addition and/or modification of stationary sources which

may contribute significant amounts of pollutant emissions into the region.

These are typically administered through a permit system.

     Emission^ Density Zoning

     This measure requires that emissions of a pollutant be limited to

prescribed levels within a spatial area (e.g. pounds per acre per year

of particulates) and may be applied to existing and new sources.  One of

the purposes is to ensure that hot spots, or high concentrations of pollu-

tant emissions in a small area be avoided.

     Open Space Planning

     Open space plans are generally included as part of the general plan

and are designed to provide esthetic quality and balanced land use to the

region.  The identification of open space areas may be one means for dis-

persing the effects of air pollution by providing buffer zones.  Buffer

areas could also be used as a means to limit development around heavy

polluters, thereby reducing exposure to pollutants.  The implementation

of an open space plan would involve land purchases to maintain the open

space nature of the area.

     Regional  Water Quality Control Board (Permit Review)

     The Regional Water Quality Control Board is empowered with a permit

review system for emitters of discharge of wastewater into navigable

waters for industrial and municipal point sources.  In certain circum-

stances the permit requirements can influence the activity which generates
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the waste loading, e.g., permit review of such activities as industrial
discharge may affect the locational  decision of industrial siting.
     "3-C" Review Process
     The term, "3-C" process, comes  from the wording of the Federal  Aid
Highway Act of 1962, which requires  that all programs for Federal  Aid High-
way Projects approved after July 1,  1965 in urban areas of more than
50,000 population must be based on a continuing comprehensive transporta-
tion planning process carried on cooperatively in the state and local
communities.  As part of the planning process for these transportation
projects, which represent potential  line sources of air pollution,  an
evaluation must be made of their effects on air quality.   Specifically,
Section 109j of the Federal  Highway  Act of 1970 requires  that transporta-
tion plans and highway projects conform with the State Air Quality  Imple-
mentation Plan.
     San Diego Coast Regional Commission (General Plan)
     The San Diego Coast Regional Commission is empowered to develop a
management program for the land and  water resources of the coastal  zone.
Any applicant for a Federal  license, assistance or permit to conduct an
activity in coastal areas under their jurisdiction must be certified that
the project is consistent with the final, approved coastal management
plan, (the Commission's plan is scheduled to be submitted to the California
Legislature in 1976).
5.3  LOCAL LEVEL LAND USE CONTROL MEASURES
     Capital Facility Ordinances
     Capital facility ordinances may be formulated to require that public
facilities  (e.g. public transportation, sewer and water service, police
facilities) be adequate to support and service a proposed development.  Such
facilities must be either existing (or programmed for construction)  before
development can be approved, or the  private developer must bear the costs of
some or all of the capital facilities.  These ordinances are designed to help
the planning agency to channel growth to areas where it can be absorbed.

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     General Plan

     General plans are developed by local planning groups to guide and

direct the future growth patterns of the region.  Typically the plans

state "goals or conceptions" of directions to be followed in planning,

with no associated enforcement provisions to ensure attainment of the

plan objectives.

     Zoning Ordinances (Existing)

     Conventional zoning ordinances cover such aspects of land use as

height and bulk of buildings, lot area, open space requirements, popula-

tion and building density, use of buildings and land for trade, industry,

residence or other purposes.  Taken collectively, zoning regulations can

significantly affect long term air quality.

     Planned Unit Development (PUD)

     Planned unit developments represent communities where multi-income

residential and commercial land uses are combined in a balanced, integrated

fashion.  Large scale PUD's can be used as a strategy for improving air

quality by offering a relatively compact, balanced configuration of resi-

dential, retail and commercial structures and thus reduce the need for

auto travel.

     Capital Improvements Programming

     Capital improvements programming is the planned, scheduling of con-

struction or improvements of capital facilities such as sewers, water

treatment, schools and roads.  Taken in conjunction with the aforementioned

capital facility ordinances dealing with land capability, this can in-

fluence the direction and extent of future development and growth.

     Indirect Source Review

     Indirect source review is directed toward those sources that cause

air pollution simply by stimulating auto traffic and therefore auto emis-

sions, e.g., shopping centers, airports, and highways.   EPA regulations,

slated to be effective January 1, 1975, will enable regional or local

agencies to perform the review and grant or deny permits  to new indirect

sources on a case by case basis.   This  control  measure  is unquestionably

a far-reaching  and potentially the most effective  tool  for enforcement of
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land-use control  measures.   Although  it is  presently geared  toward pre-
vention of localized carbon monoxide  violations,  it can  be  related to a
regional oxidant strategy through the requirement of compatibility with
control strategies and air quality standards  achievement.
     Protection of Critical Environmental Areas
     Plans identifying and regulating activities  in environmentally sensi-
tive areas have been adopted in order to prevent  incompatible develop-
ment.  While air quality has not been considered  as a justification for
defining a critical environmental area, it  could  be a new application in
cases where large areas are concerned.
     Development Timing Controls
     This measure in various forms has been applied successfully in Ramapo,
New York, and conversely ruled as infringing  on the constitutional right to
travel  in Petaluma, California.  In effect, it attempts  to  curb rapid dev-
elopment by prescribing an annual quota or  permit system for development
that is in conformance with such determinants as  capacity of public faci-
lities  to service the developments.
5.4  THE LAND-USE PLANNING CONTEXT
     While land use policies are recognized to have tremendous impacts
on air quality, other variables such  as public response, the state of
the economy, energy crisis, and  political  forces impact on the ultimate
results of any land use planning policy, thus making it difficult to
define a cause and effect  relationship between the two.   Since it is not
possible to determine the  precise  contribution of  land use controls to
emissions reductions, the  effectiveness of land use control measures will
be evaluated in terms of their abilities to:
          •  reduce the need for auto travel, i.e., to reduce total
             vehicle miles of  travel
          •  limit the rate of urbanization of rural and agricultural
             lands
          •  encourage  balanced  sitings  of emission  sources.

     Land use  strategies might be  utilized to decrease  the  amount of  auto
 travel  by  locating employment  centers  close  to economically balanced

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residential areas in order to reduce home to work trip times, locating

commercial and service facilities in a central, localized fashion to

minimize the amount of shopping and other non-work trips, encouraging

a sufficient level of population density to support an operational  mass

transit system,or restricting auto-related services and conveniences, e.g.

free parking facilities.   Some pertinent land use strategies for achiev-

ing the above items are (1) zoning regulations for population and develop-

ment densities, building  and land use, (2) parking management policies

and (3) special zoning for planned unit developments.

     Limiting the rate of urbanization (the conversion of agricultural

land to urban land) serves to maintain desirable ambient air quality levels

in undeveloped areas and  prevents the kind of low-density, urban sprawl

that leads to auto dependency.

     Land use strategies  for air quality maintenance will serve to induce

future developments in environmentally desirable areas while channeling

growth away from lands which are marginal, in terms of air quality, i.e.,

open space area, agricultural areas or "saturated" areas that may exceed

standards with the additional growth.  Examples are open space plans and

capital facilities programming.

     Regulation of siting of major developments (residential and indus-

trial) serves to control  the direction and extent of urbanization as well

as controlling potential  indirect sources of increased auto traffic, e.g.

shopping centers.  In addition,  balanced siting can have the effect of

minimizing the occurence  of local air pollution "hot spots" and reducing

exposure to air pollutants.  Such measures as zoning ordinances regula-

ting land usage may be utilized for this purpose.

     Regional Approach

     Land use controls for air quality maintenance must be viewed in a

regional context for a number of reasons:

          •  the Clean Air Act requires the submission of state
             implementation plans on a regional basis

          •  the indirect land use controls are more effective if
             implemented  on a large scale; localized efforts might
             cause adverse impacts on air quality for  neighboring
             localities


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          •  air pollution is a basin-wide problem that cannot be
             effectively addressed by local  communities acting
             autonomously.
     A logical  framework for investigating the future  of the  air pollution
problem in the  San Diego Region is the Regional  Comprehensive Plan  for pro-
jected years 1975-1995,  that is being developed by the San Diego Comprehen-
sive Planning Organization.   Based on what is called the Planned Development
Policies, the Regional  Comprehensive Plan is derived from an  earlier con-
ceived alternative plan  -- the Controlled Trends Plan.  The Controlled
Trends Plan emphasizes  new development in existing urbanized  areas  and
balanced community concepts  that encourage reduced home to work auto trips.
     The policy statements for the Regional  Comprehensive Plan and  their
air quality implications are described below:
POLICY I  The Regional  Comprehensive Plan and local  plans and programs
          should be directed specifically toward development  and
          enhancement of existing urban communities  and the mainten-
          ance  and enhancement of rural communities  within the region.

     Policy I's emphasis on  limiting future grpwth,  as much as possible,
to existing urbanized areas  serves to preserve the ambient air quality
levels of rural communities.  A corollary of this policy is the encour-
agement of higher density residential development in the existing urban
areas.  Another aspect of Policy I is the requirement that new growth
should occur in a balanced fashion, making maximum usage of existing
public services and taking advantage of employment opportunities in the
urban areas.  One result of Policy I is the encouragement of  more cohe-
sive, integral  communities where employment opportunities, commercial,
educational, cultural,  recreational and health services are located in
a more concentrated fashion  and therefore facilitate the operation  of a
viable local mass transit service.  Traditionally, low density residential
developments and fragmentation of services and shopping areas have  made
successful transit service extremely difficult to achieve.
     The air quality implications of this policy can only be  predicted
in terms of the ability of a balanced, medium to high density community
to support a mass transit system and the extent to which trips by auto
are replaced by trips by transit.

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POLICY II    New employment opportunities should be located in employment
             centers developed as an integral part of both existing com-
             munities and newly developing suburban communities.  The size
             and number of the employment centers would depend on the size
             and character of the community within which they are located;
             the types of employment in each community employment center
             should be consistent with the availability and price range
             of housing in the surrounding community.

     This policy directs that employment opportunities and public services

be consistent with the character of existing urban and rural communities.

Community-scaled employment centers will be encouraged and are to be

accessible by regional and local transit services.  Major employment

centers should also be accessible by the regional transit system described

in CPO's transportation plan (below), as well as at least one of the

region's major highways.  Population-serving employment operations are

to be encouraged to locate as close as possible to the population served;

and industrial and agricultural processing operations should be sited as

close to the resource production sites as possible.

     The items in Policy II serve to maximize the opportunity to decrease

the length and number of trips by autos and trucks for work and for the

transport of goods.  The policy's impact on air quality will be determined

by the success of the regional  and local transit systems to serve the

travel needs of the working segment of the region's  population and thus

to reduce the amount of auto travel which accounts for a major portion of

the air pollution.

POLICY III   Those activities which require Regional  market or service
             areas should concentrate in employment and service centers.
             These centers should be located at the focal points of the
             Regional Transportation System.

     Under this policy, the nature of new industrial  growth should be

keyed to major employers already located at the sites.  Thus, employment

growth in Centre City San Diego will be comprised of business and govern-

mental headquarters activities and retail commercial  activities that

serve Centre City residents and visitors.  Industries that are located

on the San Diego Bay front should be limited to those requiring water-

front sites and accessibility to Port facilities; siting of new industrial
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and employment centers should be based upon the regional  transportation
system network.

     The relevant item in Policy III for air quality is the possibility

that extensive inter-city regional  traffic might arise; in addition, major

employment concentrations may lead  to traffic congestion  (a situation

leading to undesirable auto pollution levels) or to the occurrence of

"hot spots."

POLICY IV    Local  jurisdictions should use the location  of regional
             transit facilities as  a focal point for local development
             plans  for activities providing employment opportunities and
             for higher density residential development.

     by keying development to transit development, this policy serves to

encourage utilization of transit and thereby reduce dependency on the

auto mode.

     Transportation Policies for the Regional Comprehensive Plan

     As part of the regional comprehensive plan, CPO has  adopted a set

of policies to define the transportation goals of the region and to des-

cribe the elements  of a regional transit system.  These policies are

summarized below:

          •  to emphasize consistency and coordination of overall
             regional growth and development policies with regional
             and local transit services

          •  to recognize the importance of multi-modal systems to serve
             the different travel requirements of the population

          •  to recommend a transportation plan that will minimize the
             region's energy requirements and maximize improvements in
             the air quality

          •  to provide transit services to low-mobility  population
             segments, e.g., the elderly, the young

          t  to maximize opportunities for pedestrian and local feeder
             access to regional transit terminals and stations

          t  to make maximum advantage of the most advanced and proven
             automation equipment available,
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          0  to recommend that the regional transit system be an inter-
             mediate capacity, fixed guideway, transit network that
             operates on exclusive right-of-way, e.g., light rail,
             advanced technology transit

          •  to recommend an express bus network that provides high
             levels of transit services in medium level demand travel
             corridors.

     The air quality implications of the regional transportation plan is

again a function of the ability of the recommended transit systems to

satisfy the travel requirements of the region and thus reduce the need

for travel by auto along the corridors they service.

     Regional Comprehensive Plan and the AQMP

     It is seen that the general objectives of the Regional Comprehensive

Plan, as outlined by the four policy statements, are consistent with the

criteria for suitability of land use measures for air quality mainten-

ance, i.e., to reduce auto travel, to control the areal spread of urbani-

zation and to encourage balanced communities.  Many of the land use con-

trol strategies that would be required to implement elements of the

Regional Comprehensive Plan are precisely the strategies that are con-

templated for inclusion in the air quality maintenance plan (AQMP).

     Table 5-1 shows a list of candidate AQMP land use control measures

and their potential applications for implementing each of the four policies

above.  For example, capital facility ordinances which would require that

adequate public facilities exist or be programmed for construction within

a defined time period before a subdivision plan can be granted, would

serve to maintain areas designated by the regional plan to be rural.

Capital facility ordinances in conjunction with a capital improvements

program could be utilized to channel growth into existing urbanized areas

as designated by the regional  plan.

     Zoning ordinances for development intensity might be formulated to

encourage higher population and building density levels in designated

urban areas while restricting densities in rural areas.  Ordinances may

also be formulated to restrict intense development in areas that are not

served by proposed regional rapid transit, feeder transit, or by local

transit services.
                                    69

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     The four measures, emission allocation, stationary source review,

emission density zoning and indirect source review are actually indirect

land-use measures.  To the extent that the sources which they regulate

contribute to the violation of air quality standards, these measures

can effect siting decisions.  Criteria for issuing permits cannot be

based on the grounds of violation of the regional comprehensive plan be-

cause the plan is not legally binding on anyone.  Therefore, the effec-

tiveness of these four measures in implementing a regional comprehensive

plan is severely hampered.



     If the approved AQMP will be legally enforceable while the Regional

Comprehensive Plan is not  it  is preferable that  the  consequences  of

implementing the AQMP land use measures do not conflict with the regional

goals for growth and development.

     In addition, since air quality is only one of many factors that must

be considered in regional  growth and development patterns, the Compre-

hensive Plan is currently the only vehicle for developing and expressing

overall  regional  goals.   Therefore, to the extent that the Regional  Com-

prehensive Plan conforms with the requirements of State or Federal  air

quality standards, its land use policy elements can serve as the basis

for the definition of a land use strategy for the AQMP.

     Problems of Regional  Level  Planning

     The Comprehensive Plan suffers from two important deficiencies:


     (1)  the policies have not been set forth in a manner which is
          conducive to examining the effects on air quality of different
          types and degrees of land usage; CPO has not addressed the
          problem in any substantive fashion

     (2)  implementation of the Plan is incumbent upon the cooperative
          actions of the CPO member cities' and county planning agencies.
          CPO has no enforcement authority to ensure that the plan is
          properly implemented.

     In order for the Regional Comprehensive Plan to serve as a frame-

work for identifying an AQMP land use strategy and thus ensure consistency

with overall  goals for growth and development, the Regional Plan must

be evaluated for compliance with air quality standards.


                                   71

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     In particular, the Regional  Comprehensive Plan did not address the
problems of critical areas where  the policies may incur degradation of
air quality or violate standards.   These are as follows:
          t  the areas bordering  the proposed regional  transit
             network, particularly about the stations
          •  areas of proposed high density developments, e.g.,
             Centre City
          •  areas of concentrated employment, business or industrial
             centers.
     Historically, land development and growth patterns have followed
the construction of transportation lines, e.g., the Western railroads,
the national and state highway systems, and Bay Area Rapid Transit.
While working to provide maximum  accessibility on a regional scale, a
comprehensive transit network will also serve to attract considerable
development along the corridors of service and at points of access (sta-
tions).  One example of a potential critical area is the North County
area which is designated to be served by an express bus system.  The Re-
gional  Comprehensive Plan has not addressed the problem of to what extent
growth  and development will be allowed in these corridors, and what their
air quality implications will be.
     While higher residential density communities and city centers will
be better able to support a variety of services of which mass transit  is
most relevant for air quality, there is also the question of threshhold
levels  at which excessive population or employment densities may lead  to
undesirable air pollution levels.   There appears to be a tradeoff in land
use planning between preserving air quality in undeveloped areas by con-
centrating sources of air pollution and extending the boundaries of
urbanization to disperse the effects of air pollution.   A similar problem
exists  for locating new industries, factories and other employment centers.
Consideration must be extended to  the possibility of "hot spots" or con-
gested  traffic configurations which will  lead to undesirable air pollution
levels  at access points during the peak travel hours.
                                    72

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     Another obstacle to regional  level  planning is the fact that local

and county adherence to a regional  comprehensive plan is on a voluntary

basis; local general plans do not have to be consistent with the regional

plan.   Providing that an enforcing  agency is designated, the AQMP will not

suffer this problem.

     While the AQMP is legally enforceable under the Clean Air Act and

state  enabling legislation, it faces the problem of most regional planning

efforts if the tasks of AQMP development, implementation and enforcement

are carried out by separate, independently operating agencies.

5.5  TWO CANDIDATE APPROACHES FOR INCORPORATING AIR QUALITY MANAGEMENT  INTO
     THE SAN DIEGO LAND USE DECISION-MAKING PROCESS

     "CALIFORNIA has no overall  land use planning law,  but they do
     have a mess of diverse laws and agencies  often working against
    each other...The state planning office is a sham,  with only a
     few employees.   A number of land use planning bills are before
     the Legislature, none of them  comparable  to Florida's and  none
    of them with a chance to pass."*

     The approach to be taken in developing and implementing air quality

maintenance procedures into San Diego's  land-use decision-making process

must meet two constraints mandated  by the Clean Air Act.  First, the

approach should provide for a comprehensive review of any future growth

and development significantly affecting  AQMA air quality.  Second, the

State  of California Air Resources Board  is charged with the responsibility

for complying with the Clean Air Act, although the ARE can delegate some

of this responsibility to local  APCDs if it so chooses.  In cases where

the state has failed to take appropriate action, present law dictates that

the federal government must intervene.

     Except in cases where a region's resources are shared by and vital

to the public sector of a larger community, it would be presumptuous for

either the state or the federal  government to  attempt to externally im-

pose land-use controls on a given AQMA.   "Outsiders" cannot be expected

to make the trade-offs necessary to the  formulation of an AQMP tailored
*Spoken by Gov. John McCall, Oregon, in his address to the 1974 Planning
 Conservation League meeting, 8 June 1974.
                                    73

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to the unique needs and goals of the populace within a specific region.
Thus, it is appropriate that a local agency assume the responsibility for
development and implementation of the air quality maintenance plan for
San Diego.  In order to deal effectively with a regional problem like
air pollution, such an agency must have a regional perspective on the
problem and the expertise necessary to deal with it.
     Unfortunately in San Diego, as in many regions across the nation, no
single agency has both the air pollution and the land use planning exper-
tise required.  This dichotomy of skills resides between the Comprehen-
sive Planning Organization (CPO) and the County Air Pollution Control
District (APCD).  Thus, two basic alternatives are identified as possible
institutional arrangements for incorporating air quality management into
the San Diego land-use decision-making process.  It should be noted that
regardless of which institutional arrangement is eventually selected, the
lead agency must rely heavily on the other agencies in the region in order
for the maintenance plan to be truly effective.
5.5.1  Alternative "A" - AQMP Process Carried Out by CPO
     This alternative would require the ARB to recognize CPO as the lead
local  agency in charge of developing an AQMP.   The AQMP would become part
of the regional  comprehensive plan.   THE APCD would lend technical  assist-
ance in plan development; however,  CPO would assume the stronger position
in  developing  the AQMP through their role in land use and transportation
planning on matters of regional  significance.  (See Figure 5-1)
     Alternative "A"  should provide some regulatory power to CPO for en-
forcing elements of the general  plan pertaining to regional air quality
so that their plan is no longer viewed as being purely advisory.  The
intent would be to develop a combined land use/transportation plan which
contains the balance necessary for minimizing VMT while also presenting
a more unified and consolidated approach for state, regional and local
government coordination.  Most land use decisions would continue to be
made by the local, general purpose  governments; however, CPO should be
in a position to exercise limited veto authority and to review all  trans-
portation projects and new developments of regional significance by being
                                    74

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                                      ARE
                                                       •  Responsible for SIP
                                                          modifications

                                                       •  Provides overall guidance
                                                          to ensure coordination

                                                       t  Retains ultimate compliance
                                                          responsibility
                                      APCD
   /   /
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                                       I
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  \    \
                                                 \
                                                   \
                                                    \   '
                                                     \  •
                                   Responsible for  preparation
                                   of AQMP

                                   Responsible for  implementation
                                      maintenance measures
                                   (emission controls  and land
                                   use controls)

                                   Implements emission controls
                                   Indirect source  review
                              \               ^
                               »•  Parking management
        FEDERAL
        AGENCIES
   SINGLE-PURPOSE
   ORGANIZATIONS
                         CPO
                        COUNTIES, CITIES,  OTHER
                           LOCAL GOVERNMENTS
  0  Provides inputs
     upon request
•  Provides inputs
   upon request

•  Implement mresures
   upon request
                   •  Provides inputs
                      upon  request

                   •  Retire existing
                      review power
                        •  Provides inputs
                           upon request

                        •  Implement measures
                           upon request
— — — Coordination
                                            75
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vested with review of indirect sources,  parking  management and parking
facility planning, in addition to its A-95 review power.
     Representatives  from federal  military installations in the San Diego
region and the Environmental  Protection  Agency might assume a regular ex-
officio role on the CPO board so that their respective activities could
be made known further in advance.
5.5.2  Alternative "B" - AQMP Process Carried Out by the APCD
     Under this alternative the County APCD would be responsible for pre-
paration of and insuring local compliance with the San Diego AQMP.   Since
the CPO Board of Directors consists  essentially  of representatives  from
each of the incorporated cities within the County as well  as the County
itself, it seems appropriate  that CPO should fulfill the role of coordina-
tor of the planning of the land-use  control element of the AQMP.  Thus,
under this institutional arrangement the APCD avoids entering directly
into the land use planning arena while still retaining the local respon-
sibility for compliance with  the mandate of the  Clean Air Act.  (See
Figure 5-2).  CPO retains its role of planning coordinator as well  as its
other responsibilities with regard to parking management plans and  A-95
review.
5.5.3  Discussion
     The essential difference between the two organizational schemes pre-
sented lies in the delegation of the indirect source review responsibility.
Clearly, the agency that has  this responsibility holds the key to enforce-
ment of a long-term air quality maintenance plan.  On that basis, the same
agency should also logically  have the lead responsibility for the prepara-
tion of the AQMP.
     In order for alternative A to become a reality, CPO must be granted
the power of indirect source  review, either by its member governments
through a joint exercise of powers agreement, or by EPA or the State Air
Resources Board under the authority and  responsibility mandated in  the
Clean Air Act.*
*The Federal Register, Vol 39, No. 38, "Air Programs; Approval  and Promul-
gation of Implementation Plans - Review of Indirect Sources," February 25,
1974.

                                     76

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     Alternative B currently suffers from uncertainties in the legal  inter-
pretation of the nature of indirect sources.   The Attorney General  of the
State of California has written an opinion which states that local  air
pollution control districts currently have the authority to implement in-
direct source review.  Conversely, a recent court decision (State Court
of Appeals, Western Oil and Gas Association vs.  Orange County Air Pollu-
tion Control District) reaffirmed the jurisdiction of the State Air Re-
sources Board over motor vehicle emission control and in so doing raised
the question of whether indirect source review should be considered sta-
tionary or mobile source control.
     The uncertainty appears to center on the interpretation of the nature
of the powers of the APCDs.  If it is interpreted that the APCDs have
only those powers specifically designated in  the State Health and Safety
Code, then serious questions are raised as to the validity of the Attorney
General's opinion.  Conversely, if it is interpreted that the APCDs have
authority over all realms of air pollution control except those specifi-
cally pre-empted by higher authority, then it is likely that the Attorney
General's opinion would hold.  The court ruled that the APCD could not
regulate the fuel composition for automobiles since this constituted  a
control over automobile emissions which should properly be the juris-
diction of the State Air Resources Board.  The problem is that this deci-
sion may be considered to apply to indirect source review by analogy.
It is conceivable that indirect source review may be considered regula-
tion of automobile emissions, since it is precisely auto emissions which
such review procedures are designed to minimize.  The situation is further
complicated by the fact that indirect source  review may also be consid-
ered a form of land-use control — an area which has always been the
domain of local government.  (Appendix K contains copies of both the
State Attorney General's opinion and the decision of the State Court  of
Appeals.)
     If it is resolved that the APCDs do not  currently have authority to
implement indirect source review, responsibility for the delegation of
that authority would revert back to the State Air Resources Board and/or
EPA, under the mandate of the Clean Air Act.
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     It seems proper that indirect sources should be classified as sta-
tionary sources and the Attorney General's office has asked for a clari-
fication of the ruling with regard to this point.
     Assuming that the court rules in favor of APCDs on this point, there
remains but one potential drawback to alternative B.  The problem is that
the County Board of Supervisors must fulfill  a dual  role -- one role as
administrators of the unincorporated areas of the county, and another as
reviewers of the activities of the Air Pollution Control District, which
has county-wide jurisdiction.   Such a dual role could potentially lead to
a conflict of interest on such development projects  as the construction
of county roads.  This is not an insurmountable problem, although it is
one which must be recognized and dealt with openly.   It is not likely
that the Board of Supervisors would attempt to usurp the authority of
either the Air Pollution Control Officer or the Air  Pollution Control
Board.  However, if such an unwritten relationship is unacceptable, the
State Air Resources Board could serve as official review agency for county-
sponsored indirect sources in order to prevent potential conflicts of
interest.
     A third option exists apart from the two alternatives just described.
Under this option CPO and the APCD would share the indirect source review
authority through the formation of a joint governing body.  This option
is attractive from the standpoint that it ensures a  high degree of parti-
cipation on the part of both CPO and APCD.  However, should difficulties
arise either in the preparation of the plan,  the implementation or in the
relationship between the two agencies, it would be difficult to assign the
ultimate responsibility for preparation and enforcement of the AQMP to
either agency (i.e., if anything should go wrong, a  certain amount of
"finger pointing" would be inevitable).  Thus, this  third alternative is
potentially the least attractive from the standpoint of the assignment
of responsibility.
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               6.0  LOCAL CONSIDERATIONS IN LAND USE PLANNING

     The previous section has discussed a number of potential  air quality
maintenance measures, both, from the perspective of improving existing
control procedures and, in a more general sense, from the possible applica-
tion of a host of other controls.  Among the most difficult control
measures to assess in terms of their potential  applicability in San Diego
were the land use control measures; the major problems result largely
from the number of linkages required to translate a given land use decision
(or plan) into its resultant air quality impact.  To date, only a limited
amount of work has been done in this area.
     It was felt, from the inception of this study, that the selection of
land use control  measures was best accomplished by local  planners and
decision makers.   Furthermore, it was felt that any measures selected for
purposes of an AQMP could only be implemented -if they had the support and
endorsement of local  institutions and governmental  agencies.  This section
presents a discussion of local inputs concerning which land use control  measures
appear attractive and effective for use in the San Diego  region.   It is
clearly recognized that the reduction of air pollutant emissions  can be
accomplished by means other than land use control  measures.  As crucial
elements of the AQMP, for example, are maintaining vigorous controls on
stationary point sources and successfully implementing and enforcing an
aggressive transportation control plan to reduce vehicular emissions.
Implicitly, the assumption of presently available technological controls
has been made.  Although this assumption has been made, it is certainly
felt to be unrealistic and a conservative estimate of control  measure
effectiveness.  The rationale for such an assumption is more from satisfying
the legal requirements of developing a demonstrably effective AQMP than
from any technical considerations.  From a technical  perspective, it is
difficult to foresee remaining static in the availability of additional
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hardware, process modification, product changes, etc. which will reduce

industrial emissions, especially given more stringent control requirements.

Indeed, if past experience in pollution control is any indicator, it may

be that the tighter emission limits will provide the necessary impetus to

advance the current state-of-the-art control techniques.

6.1  The Delphi Panel

     There are a number of ways to solicit local inputs into a planning

process.  Traditionally, the most frequently used mechanisms are to conduct

surveys of one kind or another, hold seminars, symposia,  and conferences, or

to conduct public hearings.  Depending on the planning objectives, various

combinations of the above procedures are also used.   As mentioned, it

was decided local inputs -- city, county, regional,  and state -- were

essential  to the selection of any land use control  measures to be incorporated

into the AQMP.  The vehicle used in this study to solicit such inputs was

the Delphi technique -- a structured and controlled  questionnaire with

feedback.

     A good description of Delphi is given by Dal key:*

     "In general, the Delphi  procedures have three features:  1) anonymity,
     2) controlled feedback,  and 3) statistical group response.   Anonymity
     effected by the use of questionnaires ... is a  way of reducing the
     effect of dominant individuals.  Controlled feed-back --  conducting
     the exercise in a sequence of rounds between which a summary of the
     results of the previous  round are communicated  to the participants --
     is a  device for reducing noise.  Use of statistical  definition of the
     group response is a way  of reducing group pressure for conformity;
     at the end of the exercise there may still be a significant spread
     of individual  opinions.   Probably more important, the statistical
     group response is a device to assure that the opinion of every member
     of the group is represented in the final  response."

     In addition to and preceding the Delphi questionnaire, a series of

interviews were conducted locally and over the telephone  to gather both

base data  and agency attitudes concerning land use  control  alternatives for

air pollution control.  In part, these interviews set the stage  for con-

ducting the Delphi  questionnaire.

*Dalkey, N.C., "The Delphi Method:  An Experimental  Study for Group Opinion,"
 The RAi-ID  Corporation, RM-5888-PR, April 1969.

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     There were several reasons for selecting this procedure for gauging
local attitudes towards development of an AQMP.  It became quite apparent
that air quality was a critical issue in San Diego and that most agencies
(as well as individuals) were strongly opinionated concerning the ultimate
solution to the problem.  In this sense, then, achieving and maintaining
clean air was a controversial issue locally.  Because of this, it was felt
desirable to avoid any direct agency confrontations.   On the other hand, it
was also felt broad representation from all  sectors of the community were
needed to add credibility to the planning process.  Explicit attempts were
made to insure representation from the public and private sectors, city,
county, regional, and state agencies, business community and citizens'  groups.
As a means of accomplishing both objectives  as well as incorporating local
inputs within the time frame allowed by the  study, a  one-day (afternoon
session) Delphi questionnaire session was planned.  Appendix D contains more
detailed information on which agencies were  contacted and asked to participate,
as well as which group did actually attend.
     It should be emphasized that the results of the  questionnaire are
intended only to serve as an indicator of local thinking on potential control
measures to be implemented.  While the overall administration of the ques-
tionnaire was accomplished with no major difficulties, a number of points
need to be raised concerning the limitations involved in interpreting the
results.  While every attempt was made to seek "balanced" representation
within the group, it is virtually impossible to avoid individual view
points that the group was "stacked" with planners or governmental officials
or some other group.  Specifically, during the San Diego session, a number
of incidents occurred which may have influenced the final results:
          •  As expected, not all of the individuals  who had agreed to
             attend did in fact participate.  Consequently, the "balance"
             originally sought never materialized.
          •  A number of "experts" scheduled to participate sent rep-
             resentatives in their stead.  Since this Delphi was  structured
             to solicit "expert" opinion, it is difficult to gauge whether
             or not the level of expertise originally solicited was
             as good, better, or worse than the final group of
             participants.
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          •  Concurrent to the Delphi, two other important meetings were
             being conducted in San Diego,* which accounted for a  portion
             of the absenteeism cited above.  Since these meetings were
             scheduled after our meeting had been set up, it was essentially
             impossible to reschedule.  Of significance was the fact that
             a number of respondents who started the Delphi session were
             unable to complete it due to other commitments.  Thus, the
             mixture of the group as a whole experienced some change during
             the afternoon.

     Despite the above mentioned nuances, sufficient consensus was reached

by the group on a number of issues that it was generally felt the  exercise

was very useful.  The group initially assembled numbered twenty, with

fourteen representatives completing the full seven rounds of interrogation.

     Organizationally, the structure of the survey was aimed at addressing

three issues with regard to land use control measures:

          •  Overall  attractiveness -- From a shopping list of measures,
             the participants were asked to select the measures viewed  to
             be "most attractive" in terms of implementability, effective-
             ness,  minimum adverse socio-economic impacts and public
             acceptance.  This phase of the exercise was completed first,
             since it was felt regardless of how effective a particular
             measure  might be, if it was not implementable and acceptable,
             it would never receive serious planning consideration.

          •  Implementation obstacles -- Once it was determined which
             control  measures were viewed as the most attractive,  an
             assessment of the most critical implementation obstacles was
             solicited.  The respondents were asked to consider the relative
             importance of six potential  implementation obstacles  --
             lack of  funding, existing governmental  structure,  lack of
             enabling legislation, inadequate state-of-the-art technology,
             public acceptance, and a lack of precedences or a  hesitancy
             to be innovative.

          •  Effectiveness -- A number of specific and general  objectives
             were cited and the respondents were asked to assess (by rank
             ordering) the relative effectiveness of the control measures
             for achieving the various objectives.   Since the objectives
             dealt with the need for auto travel  and growth and develop-
             ment issues,  inferences can be drawn regarding the air
             quality  implications of these measures.

*The other meetings taking place concurrently were a County Board  of
 Supervisors meeting  to discuss indirect source review requirements  of
 EPA, and a CPO monthly board meeting.
                                   83

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Table 6-1 presents a summary of the chronological  sequencing of issues
addressed by the questionnaire.  In addition to the actual  survey form,  a
supplemental set of miscellaneous "fact sheets" were provided to each
participant.  This handout contained descriptive information on what
each of the control measures were and a summary of the air  pollution
situation, i.e., recent emission inventory and air quality  data.  The
intent of the handout was merely to provide backup information to the
respondents to assist them in their decisions.
                                   84

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     Round One was intended to eliminate from further consideration those
measures which the panel  members did not feel offered much potential  toward
the solution of realistic land use control  measures.   The summary of the
votes tallied from this round are summarized below in Table 6.2 (in order
of highest number of votes received).
                 Table 6-2.   Summary of Round One Results
            Control  Measure                                  Votes
A.  Environmental Impact Statement (CEQA)                     12
D.  SB 1543 (or Similar Regional  Development Plans)*          10
C.  Taxation Policy to Preserve Non-Development Areas*         9
F.  Direct Source Review                                       8
L.  Capital Facility Ordinances                                8
M.  General Plan                                               8
I.  Regional Water Quality Control Board (Permit Review)       7
Q.  Indirect Source Review*                                    7
S.  Development Timing Controls*                               7
P.  Capital Improvements Programming                           6

      *Potential Control Measures -- Not Currently in Use

All the remaining measures received five or less votes and were eliminated
from additional consideration.  The lack of votes was interpreted as a lack
of confidence in the measures to provide meaningful  land use controls.  This
could have been because of foreseeable Implementation obstacles, enforcement
problems, administrative costs, lack of effectiveness, high socio-economic
costs, or any number of other concerns by the panelists.
                                    86

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     The ten measures receiving the highest vote counts were carried over

to Round Two, where participants were once again asked to vote for the six

"best" measures.  The results of this round are displayed in Table 6.3
               Table 6-3.  Summary of Round Two Results


                Control Measure                              Votes

A.  Environmental Impact Statement (CEQA)                      12

L.  Capital Facility Ordinances                                12

F.  Direct Source Review                                       11

M.  General Plan                                               11

C.  Taxation Policy to Preserve Non-Developed Areas*           10

D.  SB 1543 (or Similar Regional Development Plans)*           10

P.  Captial Improvements Programming                           10

Q.  Indirect Source Review*                                    10

S.  Development Timing Controls*                               10

     * Potential Control Measures -- Not Currently  in Use


     It is interesting to note the similarity of the Round One and Two

tallies.   The only measure which did not at least receive ten votes was

"I" -- Regional Water Quality Control  Board (Permit Review).  Mainly

for logistical  purposes, it had been scheduled to more fully analyze the top

six measures only (the Delphi session was scheduled for a single afternoon

and it was felt that attempting to tabulate and feedback results on more than

six measures would be both confusing and too time consuming).  Thus, it was

necessary to have a run-off vote on the  five measures which had received

ten votes.  The purpose of the run-off was  to select two additional measures
                                    87

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to go with control  measures A, L, F, and M, which had received the highest
vote counts.  What was intended to be one run-off required three run-offs
to settle on two additional control  measures.   For purposes of this analysis,
measures "D" - SB 1543 (or Similar Regional Development Plans), and "Q"  -
Indirect Source Review - were added to the four measures cited above and
carried on the latter rounds for more detailed analysis.
     It is very clear from the closeness of the votes that a number of
other measures merit a much closer examination - e.g., C - Taxation Policy
to Preserve Non-Developed Areas, P - Capital  Improvements Programming,
and S - Development Timing Controls.  Due to  the tight time constraints,
such evaluation was not possible during the Delphi  survey; it is recommended
that any subsequent work include a closer scrutiny of these measures and
their potential applicability in San Diego.
     As a result of the first two rounds (and the three run-offs), six
measures were selected for a more extensive review.  Round Three attempted
to solicit responses on the relative attractiveness of the measures and
requested the panelists to rank order each of the measures on a number
of criteria -- potential  effectiveness for improving air quality, technical
feasibility, political-institutional feasibility, economic feasibility,  and
public acceptance.   In addition to ranking the measures on the above factors,
an overall "attractiveness" ranking was also  asked for.  This latter ranking
was used for a comparison with the votes received in Round Two.  In Round
Four, after summarizing and feeding back the  results of Round Three's
overall "attractiveness" rankings, the panel  was asked to reconsider for
the last time, the most attractive land use control measures.  Table 6.4
summarizes these results.  The rankings of overall  "attractiveness" were
based on a scale of "1" (Best) to "6" (Worst).  Therefore, the lower the
number, the more attractive the measures were in the panelists' views.
     Overall, there was good agreement among the group concerning which
measures were the best (or most attractive) for the region.  Only direct
source review which had received one less vote in Round Two was in a
different order by the end of Round  Four  and this rearrangement was
considered insignificant.

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               Table 6.4  Comparison of "Best" (Round Two)  and
                          "Overall  Attractiveness" (Round Three
                          and Four) Rankings


           Control Measures        Round Three          Round Four


     1.  A - EIS (CEQA)            3.1  + 1.9            3.2 ± 1.7

     2.  L - Cap. Fac.  Ord.        3.1  + 1.5            2.7 + 1.3

     3.  F - Dir. Source Rev.      3.0  + 1.3            2.6 + 1.4

     4.  M - General Plan          3.2  + 1.9            3.5 + 1.5

     5.  D - SB 1543 (or the like)  4.3  + 1.9            4.3 + 1.8

     6.  Q - Indir.  Source Rev.     4.4  + 1.2            4.8 + 1.3



     In addition to  a final consideration of most attractive control

measures, Round Four also inquired  about the relative ranking of imple-

mentation obstacles  likely to be encountered with each control  measure.

In this round, the six  implementation obstacles  were to be  ranked in  order

of importance for implementing a given  control measure from "most important,"

(1) to "least important" (6).  Overall, some interesting, but not unexpected,

rankings were arrived at by the group.   Four of  the six measures rated the

existing government  structure as the most important implementation obstacle

(see Table 6.5).  Conversely, five  of the measures cited lack of enabling

legislation as the least important  implementation obstacle.   This resulted

from the fact that these five measures  already had the necessary legislation

for implementation.
               Table 6.5  Results  of Round Four --  Ranking  of
                          Implementation Obstacles

         Control  Measure            Most Important        Least  Important

     F - Direct Source Review      Gov't Structure     Lack  of Enabling  Leg,

     A - EIS (CEQA)                Gov't Structure     Lack  of Enabling  Leg.

     L - Cap.  Facility Ord.         Gov't Structure     Lack  of Enabling  Leg.

     M - General  Plan              Lack of Funding     Lack  of Enabling  Leg,

     D - SB 1543  (or similar)      Gov't Structure     Lack  of Precedents

     Q - Indirect Source Review    Public Acceptance  Lack  of Enabling  Leg.


                                    89

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To be realistic at evaluating the least important  implementation  obstacles,
the five measures which have "lack of enabling legislation"  should cite  the
second least important obstacle.   This is  because the  issue  of  enabling
legislation for measures F,  A, L, M,  and Q,  is essentially  irrelevant.   In
this case, for the five measures  mentioned above, the  least  important
obstacles  would then become; lack of precedents, public  acceptance,
inadequate state-of-the-art  technology, lack of precedents,  and lack of
precedents, respectively.
     In Round Five, the participants  were  asked to reconsider their Round
Four responses in light of the group  answers for that  round.  These
responses, like all the previous  rounds, were tabulated and  the results
visually displayed for the group's consideration.  The results  for
Round Five were nearly identical  in terms  of relative  rank orderings,
showing good agreement among the  group on  the importance  of  implementation
obstacles.  In terms of achieving a more uniform group consensus,  the
reduction of the standard  deviations,  CT ,  illustrates  closer overall
agreement among the group's  respondents.  Also, of significance was the
reinforcement of positions held by the group in their  ordering  of  "most
important" obstacles.  This  can be seen by the overall lowering of the
group means for all the control measures.  Table 6.6  illustrates this by
comparing the two most important  implementation obstacles for each control
measure from Round Four and  Round Five.
     It is clear from the  results that the group felt  the present  govern-
mental structure in San Diego was the most significant impediment  to
more effective land use controls.  Of secondary importance on a number
of measures, the group felt  that  a lack of funding or  inadequate state-
of-the-art technology were the major  obstacles.
     Despite the fact that a certain  amount  of convergence of opinion did
take place between Rounds  Four and Five, certain viewpoints  persisted in
being significantly different from the group means. To accommodate this,
each of the respondents who  felt  in Round  Five that their different viewpoint
was correct was asked to give reasons for  his (or her) "extreme values."
The definition of "extreme values" was arbitrarily to  be  determined by  the
individuals with the general guidelines that probably  any answers  which

                                   90

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                   deviated more  than 2-3 units from the group means might be considered

                   to  fall into this category.  A number of individuals took this

                   opportunity to  voice their opinion.  Had time allowed, it would have been

                   helpful to summarize all the reasons posed for divergent views and to

                   feed  this information back to the group for a third round of interrogation

                   on  implementation obstacles.  A brief summary of the comments received in

                   Round  Five is  presented below without any attempt to comment extensively

                   on  them.

                   Summary of Round Five Comments

                            •  F  - Direct Source Review - Two parties did not see
                               how governmental structure could be the problem
                               since the APCD existed and was operative.  Another
                               felt that if one considered "emission control (add
                               on)," then he could understand the group's rating.

                            •  A  - Environmental Impact Statement (CEQA) - With
                               respect to the relatively high rating given for
                               inadequate state-of-the-art technology, one indi-
                               vidual felt the technology did exist and that the
                               problem with the general plan EIR's was they "have
                               not been challenged as to air quality content."
                               He felt if this was done quantitatively, there would
                               be no problem.  Another individual felt the role of
                               public acceptance was more important than indicated
                               because EIA had become very time consuming and
                               expensive "requiring other tasks to be ignored or
                               deferred."

                            •  L  - Capital Facilities Ordinances - One individual
                               felt governmental structure was overemphasized in
                               importance since it "does not appear to be difficult
                               to implement along with existing procedures."  Another
                               individual identified the problem to be not the
                               governmental structure, but the lack of implementation.
                               It was pointed out the City of San Diego had a 600-10
                               Policy, but the failure has been its successful imple-
                               mentation and other jurisdictions passing similar
                               legislation and implementing it.

                            •  M  - General Plan - Two individuals disagreed that funding
                               was a problem.  They felt the general plans have "overall
                               funding" or an "inordinate amount of funding, staff time,
                               and still is ineffective for air quality control."
                               D - SB 1543 (or Similar Regional Development Plans) - Two
                                           3T
                               most important constraint.  Their views appeared more


                                                     91
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             philosophical than specific to addressing this
             measure.  "Enabling legislation does not appear
             to be an overriding problem in California."   The
             second divergent viewpoint similarly felt "enabling
             legislation is possible on any subject in this
             state and if mandated will occur."

          •  Q - Indirect Source Review - One respondent  felt public
             acceptance was over-emphasized and that "given alterna-
             tives of effective programs, I don't believe public
             acceptance is as great a deterrent as proper inter-
             governmental coordination and funds."  Another individual
             felt the lack of enabling legislation (and more accurately,
             the proposed regulations) were more important than shown
             by the group.  He felt there was an absence  of legislation
             which would "assure enforcement -- loopholes in proposed
             indirect source legislation are apparent."

     It appeared overall that the views expressed were in part the result

of different interpretations of the questionnaire.  Others had sincere

professional differences of opinion.  Under any interpretation, however,

the point which appeared most consistent was a dissatisfaction with the

present governmental  structure for implementation of meaningful land use

control.

     The purpose of Rounds Six and Seven were to get a qualitative feeling

for the relative effectiveness of the measures at achieving a number of

objectives - reducing the need for auto travel, limiting  the rate  of

urbanization in rural areas, promoting balanced development of residential

and commercial  areas, and controlling the extent and direction of  future

growth.  In these rounds, the control measures were compared relative to

one another.  Table 6-7 summarizes the results of the two most important

measures for achieving each of the stated objectives.

     Properly implemented, all of the objectives cited would serve to

reduce or minimize air pollution emissions.  As in Rounds Four and Five,

only minor differences occurred as the result of feedback, and Round

Seven results were very similar to Round Six results.   The one change

which did take place  was under "limiting the rate of urbanization  in

rural areas," where the second most effective measure cited in Round

Seven was SB 1543 (or Similar Regional  Development Plans).  This change

made the consensus of the group unanimous as far as the top two most
                                   93

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effective measures for achieving the regional growth and development

goals.  There was unanimity among the group for the third most effective

measure as well -- capital facility ordinances.

     It is interesting to compare the results of the group's responses

from Round Seven with the Round Three category "Potential Effectiveness,"

where the group was specifically directed to judge effectiveness "from

the viewpoint of improving air quality."  In this latter case the most

effective measures were direct and indirect source review (tied for

"best") followed by SB 1543 (or Similar Regional  Development Plans).  For

improving air quality, the General Plan was rated least effective.   Thus,

there appears to be an apparent discrepancy among the group's responses

since many of the objectives in Round Seven would improve air quality.

     As in Round Five, the group was requested to submit responses  if

their veiwpoints for Round Seven were substantially different from the

Round Six group means.  A number of such responses were received.  Several

individuals felt strongly that the general  plan has not been, is not now,

and probably will  not be effective at achieving the stated objectives.

Among some of the comments received concerning the effectiveness of the

general plan were:

     "The general  plan is not an effective  tool;  there is no
     commitment to it."

     "G.P. is least effective way to reduce need  to auto
     travel.  I consider General Plans 'shaky' as they pertain
     to land use."

     "Obviously the G.P. in San Diego hasn't reduced need for
     cars... General  Plan approved calls for more growth."

     "None of the general plans have enforceable  implementation
     or phasing provisions.  Hence are and  will  be ineffective ....
     I believe the measure is a 'motherhood' type.  I maintain ....
     regional direct and indirect source control  with regional
     allocation and capital facilities control will be most
     effective."

     A possible rationale for the apparent  discrepancy noted between

Rounds Three and Seven was offered by one participant when he wrote:

     "The effectiveness criterion measured  is oriented toward
     preventing and controlling future events.  Perhaps this is
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     why the general  plan was  ranked  as  most  effective  in
     controlling future events.   For  actually maintaining
     current standards, I view direct source  control, in-
     direct source control and capital  facilities  ordinance, and
     CEQA as the most important."
     Overall, the results of Round Seven were the  most  surprising  to  the
TRW personnel working on the program.  In developing  the AQMP,  it  was
difficult to envision the general  plans  developed  in  the various
communities as the most important and effective means to control land use.
Traditionally, general  plans have served only as guidelines  to  follow in
urban development patterns, without specific  implementation and  enforcement
mechanisms associated with them to ensure development would  proceed as the
plan envisioned.
     In summary, a number of interesting insights  were  gained  from the
Delphi questionnaire.  As one might have expected, the  measures originally
selected as the most attractive were for the  most  part  already  in
existence.  This would certainly speak favorably for  the  present govern-
mental structure plus the fact that the AQMP  development  program was
never intended to "reinvent the wheel."   Of the most  important  future
controls, indirect source review and SB 1543  (or Similar Alternatives)
emerged as the most actively supported alternatives followed closely by
taxation policy to preserve non-developed areas and development timing
controls.  It is highly recommended that these controls be given much
more detailed study to assess the full range  of impacts they would have
in San Diego, including their land use and air quality  implications.   With
regard to implementation obstacles, the present governmental structure
appeared to be the most serious problem for a number of measures.
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           7.0  AN AIR QUALITY MAINTENANCE PLAN FOR SAN DIEGO


     An air quality maintenance plan may be visualized to consist of a

technological control element and a land use control  element.  As a region

grows in population, per capita consumption, and hence emissions, tech-

nological controls must become increasingly stringent in order for the

region to accommodate the growth and yet maintain air quality.  The con-

verse may also be considered to. hold -- if technological  controls cannot

alone serve to maintain air quality, land use controls must bear an in-

creasing portion of the burden as growth progresses.   Thus we see that

a very delicate balance must be maintained between the two control  ele-

ments and that this balance will  become increasingly  difficult to main-

tain as time passes.

     The previous sections have presented some local  insights into the

current planning process, strengths and weaknesses of current planning

tools, and possible future control measures.  The Delphi questionnaire

specifically addressed a number of control measures,  each of which was

assessed individually.  In reality, it will be the application of

numerous measures in a well-conceived control strategy package which

is required to be most effective in San Diego.  Ideally, such a package

would contain measures which can compliment (and reinforce) each other

rather than conflict, and which can gain sufficient support to be success-

fully implemented and enforced throughout the region.  This chapter dis-

cusses very briefly a possible control strategy approach.  Appendix L

provides an evaluation of potential conflicts of the  AQMP with other on-

going planning programs.

7.1  THE LAND-USE CONTROL ELEMENT

     Of the nineteen possible control measures suggested in the Delphi

procedure, nine emerged as the most viable land use controls for San

Diego, and are herein recommended as the basis for a  land use control

strategy.  Six of these are presently in effect in one form or another.

These measures include CEQA (and its requirement for  EIS's), taxation

policy to preserve non-developed areas (i.e., Williamson Act - see

Appendix E),  direct source review, capital facility ordinances, general
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plans, and capital improvements programming.   By and large,  no major con-
flicts exist among these programs and each was implemented for a  specific
purpose.
     The most viable measures not currently operative are: SB 1543 (or
similar plan), indirect source review, and development timing controls.
The implementation of these measures along with the vigorous application
of the six previously existing measures will  provide the San Diego AQMA
with a substantial land use/air quality management program.   SB 1543 (or
similar plan) would provide the framework or criteria for the evaluation of
both proposed development policies and individual  projects.   Direct source
review, indirect source review, and CEQA's requirement of environmental
impact statements for both public and private development projects may be
used as the principal tools for monitoring and enforcement of the control
elements of the AQMP.  Finally, capital improvements programming, capital
facility ordinances, and development timing controls can serve to reduce
the rate of growth, while taxation policies to preserve non-developed areas
can serve to discourage urban sprawl and its resulting auto  dependency.
The implementation of these latter three measures  would necessarily involve
a detailed re-examination of the working assumptions used in the  develop-
ment of the twenty year projection of the regional comprehensive  plan. Such
a re-examination should reveal the key assumptions  made and thus point  to
more specific definitions of how these measures may be applied to ensure
that what has been assumed will actually materialize.
     In strengthening the application of those measures currently in
existence for land use control and in assessing air quality, one  can
generally recommend a more explicit consideration of air quality.  A possible
reservation to this recommendation might be the duplication  of efforts at
various planning and review levels.  For example,  one could  easily foresee
an air quality planning element for local general  plans.  However, the
California Air Resources Board for several good reasons specifically did not
recommend such action (7-1):
     (1)  Legislative action in amending the California Environmental
          Quality Act (CEQA) by AB 889 in December of 1972 and the
          resulting requirement for an environmental impact report on
          elements of general plans in the Resources Agency Guidelines

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          should accomplish similar results.  The addition of another
          general plan element would not provide further gains in air
          quality than the December 1972 mandate of the Legislature
          and would prove to be a redundant process (emphasis added).

     (2)  A local air pollution element alone cannot solve the major
          problem recognized by the Legislature in SB 981  of inter-
          regional transport of pollutants, nor can it provide for
          total basin-wide development adequately harmonized with
          adopted air quality standards.

     (3)  In the last year and a half the ARB staff has been reviewing
          and evaluating environmental impact reports under the National
          Environmental Protection (sic) Act (NEPA) and CEQA.  Although
          the need is urgent, the cumulative impact on air quality of the
          emissions projected by many individual projects has not been
          possible to assess with sufficient specificity.

     It is clear that an appropriate balance is required to ensure suffi-

cient, detailed consideration of air quality impacts without undue dupli-

cation of requirements among the various regulatory and review agencies.

Also, to be avoided is a long sequential series of reviews prior to approval

of a land use decision.  A closer cooperative planning effort is required

from all the local, regional, and state officials involved.  For example,

it has been suggested by numerous parties that certain requirements of

CEQA and the California Coastal Land Environment Element are not only

redundant but that the sequence of events required of developers to obtain

a land use change is inefficient.  Current land use planning and regulatory

activities need to be strengthened, where possible, to facilitate reviews,

implementation, and enforcement; in some cases, it may be desirable to

streamline certain controls which appear unduly repetitive.

7.2  MAINTENANCE REQUIREMENTS BEYOND 1985

     The attainment strategy presented in Section 4 was considered to be

a logical  and reasonable extension of present control  technology.   Unfor-

tunately,  such a simple extension of present technology will  not be

sufficient for the longer term maintenance of air quality  in  San Diego.

Assuming that the attainment strategy is implemented and actually does

result in  attainment by 1985, one is  faced with the prospect  of another

20% increase in population  by 1995,  with an associated 30% increase in

VMT and 50%  increase in commercial/air carrier movements.   Similar growth

is expected  to occur in essentially  every source category  listed in the

emission inventory.
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     If such growth is to be accommodated,  what will  be required  is  the
maximum extension of present technology as  well  as  the vigorous enforcement
of the land use control  measures  identified in the  preceding  discussion.
For the purposes of the  present discussion, maximum control will  be  defined
as 90% control  over sources not currently under such control.  These sources
include motorcycles, heavy duty vehicles, off-road  heavy-duty vehicles,  and
aircraft (both  commercial and military).   Maximum control  by  1985 will  result
in reactive hydrocarbon  emissions of approximately  42 tons/day.   If  a 25%
overall growth  factor is assumed  for the  entire emission inventory by 1995,
the resulting emissions  will be 53 tons/day (thus matching the allowable
emissions limit previously defined by the rollback  procedure).
     The recommended maintenance  strategy is summarized in Table  7-1.

            Table 7-1.  Recommended Maintenance Strategy
     Technological Control Element       Land-Use Control  Element
  •  90% reduction in heavy duty       t  Emission allocation  procedure
     vehicle emissions                   (SB 1543 or equivalent)
  •  90% reduction in motorcycle       •  Direct and indirect  source
     emissions                            review as  well as EIR review
                                         (CEQA)
  •  90% reduction in aircraft        t  Capital facility ordinances and
     emissions                            development timing controls
                                      •  Taxation policy to preserve
                                         undeveloped areas

     The procedures and timing used for attempting  to implement  a control
measure are as  important, if not more so, than the  mere identification of
which measures  should be included in an overall control strategy.  While
it is felt the measures suggested in this section comprise the nucleus for
a very comprehensive, meaningful, and effective control strategy  program,
it is highly recommended that a more detailed evaluation be made  of specific
implementation procedures and identification of implementation obstances.

     Now consider  this:  Suppose  it is later discovered that the maximum
control sought is  not possible (a very likely prospect).  In this
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situation the burden of control becomes shifted to the land-use control
element of the maintenance plan.  Since it has already been assumed that
the land use controls would be applied in order to assure that the CPO
Controlled Trends projection will actually occur as envisioned, any failure
to attain the maximum control originally hoped for will force the applica-
tion of land use controls to reduce VMT even further than that envisioned
in the Regional Comprehensive Plan.  The ramifications of this result are
of tremendous significance to the future growth and development of the
San Diego region.  In order to enforce the requirements of the maintenance
of air quality, it may very well be necessary to enforce land use controls
to limit growth in San Diego in a fashion which goes beyond what has been
endorsed in the Regional Comprehensive Plan.  The magnitude of this depar-
ture will  depend heavily upon the magnitude of the gap between maximum
control and the control efficiency actually achieved.
     The preceding discussion serves to highlight the fundamental difference
between a regional comprehensive plan and an air quality maintenance plan.
A regional comprehensive plan is formulated to balance a multitude of goals
and desires whereas an AQMP is formulated to satisfy a single purpose.  A
regional comprehensive plan is intended to be flexible, responding to the
changing needs of the populace, while an air quality maintenance plan is
inflexible in the insistence that air quality standards not be violated in
the process.
     In a general sense, these two plans are not necessarily at odds with
one another,  and indeed, they may be formulated to reinforce each other.
In the case of San Diego, the key element required for such a happy marriage
is technology.  If the technology can be developed to control key sources,
then all is well.  If the technology fails to materialize as fully as
required, then the plans must diverge from each other and the public values
which underlie each of the plans must be re-examined in order to resolve
the conflict.
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7.3  STATUS OF TECHNOLOGICAL CONTROLS
     Since the achievement of substantial  reductions  in reactive hydro-
carbon emissions from certain key source categories  is  a crucial  determinant
of the eventual  form of the air quality maintenance  plan,  an  evaluation  of
the present status of control in those areas  is  warranted.
     In the area of motorcycle control, EPA is  currently investigating  the
nature and feasibility of control of these sources  (7-1).   Basically, two
distinct levels  of control  are contemplated with each level applying to  a
different time frame.   In the short term (1977-1980), reductions  on the
order of 50% from new motorcycles are anticipated through  the use of engine
and carburetor system modifications (port timing, location, and  size, and
better air/fuel  mixture  control).   In the long  term (1980 and beyond),
reductions such  that all  new motorcycles meet the same  emission  standards
as light-duty vehicles are anticipated to be  accomplished  through the use
of oxidizing catalysts and/or thermal converters. Such control  would
constitute roughly a 90% reduction  in new motorcycle  emissions.   Further,
preliminary studies (7-2) indicate  that motorcycles  undergo a rapid turn-
over in their population relative to the turnover rate  for automobiles.
If this result is verified, it means that the control of new  motorcycles
should provide rapid results.  EPA  is anticipating the  promulgation of
emission regulations for new motorcycles by the  end  of  this year.
     In the area of aircraft control, EPA has studied the  problem and
had concluded that substantial reductions in  emissions  may be achieved
through the modification of ground  operating  procedures (aircraft taxi
and idle mode operations).(7-3)  Unfortunately,  there are  apparently
serious problems with regard to FAA safety regulations  which  must be
overcome before.such modifications  are allowed.   Meanwhile, the  intro-
duction of newer, "cleaner" engines into the  total aircraft mix  will result
in moderate (-30%) reductions from this source  category.   With  regard  to
control of military aircraft operating procedures, there has  apparently
been no serious  attempt made to discuss the problem  with appropriate
military representatives.
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     Finally, in the area of heavy duty vehicle control,  the State Air

Resources Board has issued regulations concerning control of HDV emissions

beginning with the 1975 model  year.   The projections  made in Section 3 of

this report indicate that substantial  reductions will  occur by 1985.

However, for the purposes of satisfying maintenance requirements,  additional

control  is necessary.   As mentioned previously, the ARE has proposed that

heavy duty vehicles be retrofitted with oxidizing catalysts in San Diego.

It seems logical that  emissions from new HDVs should  be controlled in an

equally  stringent fashion.
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                                REFERENCES

7-1  Personal  communication with Bill  Oliver,  EPA Mobile Source Control
     Division, Ann Arbor,  Michigan,  August  8,  1974.

7-2  Personal  communication with Ron Mueller,  EPA Region IX, San Francisco,
     August 8, 1974.

7-3  Jones, et al., "The Federal Aircraft Emission Control Program's
     Standards and Their Basis," Air Pollution Control Association Journal,
     Vol.  24., No. 1,  page 23,  January 1974.
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APPENDICES

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                 APPENDIX A-SAN DIEGO AIR QUALITY DATA


A-l  INTRODUCTION

     The air quality data for San Diego County are used to establish a

baseline for air pollutants covered by the Federal Air Quality standards.

(See Table A-l for Air Quality Standards).  The presentation of data is

designed to assess the accuracy of 1972 as a base-year and to relate ob-

served data to standards so that a rollback factor can be assigned for each

pollutant.  A simple mathematical model is used to estimate expected air

pollutant values.  Historical comparisons are made to check for long term

trends, and seasonal and daily variations are presented where appropriate.

     Data used in this section were obtained from the San Diego County APCD,

the California Air Resources Board, and the National  Air Sampling Network.

Table A-2 lists the addresses of monitoring stations  used in this study.

The pollutants will be discussed in the order of importance relative to air

quality standards.  No attempt is made to assess the  accuracy of monitoring

data.

     The monitoring stations listed in Table A-2 is situated so as

to be representative of population exposure to air pollutants in San Diego

County.     The area just north of metropolitan San Diego is less well covered

than the rest of the county.  Also, maximum carbon monoxide concentrations

may not be measured by the current network, nor can pollutant transport from

the Los Angeles basin be accurately assessed.  It will be shown later in this

appendix that the worst offending pollutant, oxidant, reaches similar maximum

values at several stations in the county.
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A.2  OXIDANT
     Oxidant data were assembled in three different ways to examine trends
over time.  First, Table A-3 and Figure A-l  show the annual  averages of
daily maximum hourly averages for stations in San Diego County which have
measured oxidant since 1963.  In can be seen that the trend since the early
1960's has been to somewhat lower oxidant values.   1972 appears not to be
out of line with this trend.  Also, there is a moderate difference in
oxidant values at various stations in 1972,  with extremes in the annual
average of daily maximum hourly averages which are .05 ppm at downtown San
Diego and .08 ppm at Oceanside.
     Second, Figure A-2 shows the seasonal variation of oxidant for years
in which data were available.  All stations  showed October to be the month
with the highest average of daily maximum hourly averages in the 1963 to
1967 period, with a smaller peak occurring in February.   In more recent
years, however, the main peak has shifted to the spring season, with a
slightly lower peak in September.  The reason for this change is not clear
at this time.
     Third, the daily fluxuation in oxidant  was investigated in order to
                                                        A-2
assess possible transport phenomena.  It has been shown,    for instance,
that daily oxidant peaks may occur as late as 10 P.M. in areas downwind of
the Los Angeles air basin.  Figure A-3 shows oxidant values by hour of the
day averaged over the psak oxidant month for the stations in San Diego
County.  It appears that all stations in San Diego County have a daily
oxidant maximum between noon and 3 P.M., with summer peaks occurring some-
what earlier in the day than winter peaks.  Transport is apparently not a
significant factor influencing the time of oxidant peak.  This should not
necessarily be interpreted to mean that pollutants are not transported to
sites in San Diego County from elsewhere.  Rather, the proper interpreta-
tion should be that oxidant is formed in place on a daily cycle at these
stations.
     Oxidant values for a given station were treated in a manner described
later in this appendix and were found to be approximately log-normally
distributed over time.  Cumulative frequency distributions for oxidant were
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used to estimate expected maximum hourly values (Figures A-4 to A-10).
Table A-4 compares the observed historical  maximum oxidant readings in  San
Diego County with these calculated values.   Predicted and observed values
agree fairly well except at Escondido (where a partial  year's data was
used to construct the cumulative frequency  plot) and at El Cajon.   Compared
to historical yearly maximum values, however, the predicted values are  not
out of line and suggest that about 0.30 ppm would be the expected  maximum
to be observed in San Diego County.   A previous study has indicated 0.31  ppm
as an expected oxidant maximum for San Diego County using a similar model of
the available data.      The observed maximum of 0.32 ppm at El  Cajon  in 1972  is
thus in line with predicted maxima and should therefore, be used to calculate
the required emission reduction to meet the federal  oxidant standard.   As
shown in Table 1, a 75% rollback will be necessary.   As was noted  previously,
stations in the county are not tremendously varied in average oxidant values.
The same appears true for maximum oxidant values, supporting the suggestion
that rollback be applied equally throughout the county.
A.3  CARBON MONOXIDE
     Carbon Monoxide data were available during 1972 for stations  at
El Cajon and in downtown San Diego.   Table  A-5 showing the average of
daily maximum hourly averages for several years, indicates that CO levels
have not changed dramatically since  1963 (1973 may be an exception).  The
seasonal  pattern, depicted in Figure A-ll,  illustrates that winter is the
high CO season (November to February).  As  with overall average CC levels,
the seasonal pattern appears not to  have changed significantly since 1963.
Unlike oxidant, CO does not show a strong diurnal  pattern in San Diego.
     Tables A-6 and A-7 show the hourly maximum and  8 hour maximum average,
respectively, for several years.  Using a Larsen model  (Section A.7)  and  the
1972 hourly and daily average CO distributions (Figure A-12), an
approximate 8 hour distribution was  constructed.   The predicted 8  hour
maximum is about 20 ppm for 1972, compared  to 19 ppm actually observed.
The 8 hour distribution also predicts that  3.5% of the CO values would  be
                                                                          A-3
greater than 9 ppm on an 8 hour moving average, compared to 4.7% observed.
It appears that the approximate distribution is fairly consistent  with
                                   A-3

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observed data.  As explained in more detail  later,  the 8 hour maximum is
the value upon which rollback will  have to be calculated if both the hourly
and 8 hour standards are to be met.
A.4  SUSPENDED PARTICULATE MATTER  (Hi-Volume Sampling)
     Data from three stations in San Diego County are listed in  Tables A-8
and A-9.  The highest annual geometric mean  for 1972 was reported at
El Cajor, 97 micrograms per cubic meter.   The distribution of suspended
particulate values (Figure A-14) is  such that a proportional  rollback of
the geometric mean to the standard of 75 ^g/M  would also roll  back the
maximum value (288jgg/M3) to below 260yug/M  .  The NASN and APCD stations
in downtown San Diego are currently very near to or are meeting  the
standards.
     Figure A-15 illustrates that suspended  particulate matter,  like CO,
tends to be highest in winter.  This suggests that the aerosol  upon heavy
loading is probably non-photochemical in nature.  Since the Hi-Volume
method is based on a 24 hour average sample, diurnal patterns cannot be
discerned.
A.5  NITROGEN DIOXIDE
     N02 levels in San Diego County are currently below the Federal
Standard of .05 ppm (annual average) by 25 to 60 percent as shown in
Table A-ll.  Although NOg levels are not as  far below standards  as those
of S02, reductions in emissions may be expected as automobiles come under
1102 control so that it is not anticipated that standards will be exceeded
in the near future.
A.6  SULFUR DIOXIDE
     S02 levels in San Diego County are currently below the Federal
Standards for both hourly and daily averages, as well as the yearly
average.  Table A-10 indicates that S02 levels must increase by almost
a power of ten in order to exceed the yearly average standard.  The
24-hour standard could allow nearly a sevenfold increase in S02 emissions.
This magnitude of increase is not expected in the near future.  The read-
ings are included in this appendix since tKere may be concern over possible
high sulfur fuel use in the future and its impact on S02 levels.

                                    A-4

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A.7  A LOG-NORMAL MODEL FOR AIR POLLUTANT DATAn

     Many air pollutants can be described as log-normally distributed over

a year's period.  A plot of frequency of occurance vs. concentration often

shows a distribution weighted at the high end.  When the log of concentration

is used in such a plot, the distribution approximates a normal or Gausian

curve.  Two parameters are needed to define such a distribution; Mg, the

geometric mean, and Sq, the geometric standard deviation.  These are

defined as follows:
                        1/N
        M
                 N
                n
                  = exp
1
N
IN
<£ i
c,=l
- c, )
                             (1)
=  exp
                                   C1
in M
                                                    1/2
(2)
where c. is the concentration of the individual  measurements.
     Air pollutant data can be handled in a graphical  fashion using the

log-normal assumption.  Plots of observed pollutant values vs.  cummulative

frequency are made on log-probability paper (see Figures A-4 -  A-10).   The

equation for the best fit line drawn through the points is:
               or
                       In c. = In M  + zln S

                                     zi
                                                          (3)



                                                          (4)
where z is the number of standard deviations that c.  occurs  from the

geometric mean.   One standard deviation would occur at 84% (or 16%).

M  is then estimated from c.  at 50%.   It follows that:
           In
              or
                          "84%
              Sg "
                               = In M  + (1)  In S
                                     50%
                                    A-5
                             (5)
                             (6)

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     The maximum expected va1ue*is calculated as follows.   If N measure-
ments are made per year, a z value for (1-1/N) in percent  is taken from a
normal error table.  Then:
                       C    = M  S     -
                        max    g  g

Alternatively, C    may be read from the log-probability graph at (1-1/N)%.
                mQ X
     The log-normal  model  may also be used to estimate the number or percent
of days which a pollutant  is expected to exceed a standard.   The percent may
be read directly from a log-normal plot or calculated from equation (4)
using c. as the concentration to be exceeded.  M  and S  are known so that
a  z value can be calculated, followed by obtaining the percent from a
normal  error table.
A. 8  RELATIONSHIP OF LOG-NORMAL DATA TO AIR QUALITY STANDARDS
     A log-normal model of air pollutant data may be related to ambient  air
standards with a few simplifying assumptions.  First, it is assumed that
emissions are approximately constant during the year so that variations  in
air pollutant levels are primarily due to meteorology.  Further, anthro-
pogenic contributions to air pollution are predominant.  Finally, the nature
of the particular pollutant does not change as emissions are reduced (i.e.
composition changes due to slower reaction kinetics, or the relative
contribution of dust to total particulate matter).  It follows that emission
reduction will be accompanied by a proportional reduction in the geometric
(and arithmetic) mean and that the geometric deviation will  be essentially
unchanged.  On the other hand, a change in meteorology could change both
the geometric mean and standard deviation.  If S  remains unchanged as
emissions are reduced, equation 4 can be applied to the "lower" geometric
mean to estimate the percent of the time which a given standard might be
exceeded.
     The above model has been applied to air pollutant data in San Diego
County and found to approximate actual distributions for oxidant, carbon
monoxide, and suspended particulate matter.  Some of the details of
relating the model to standards are given in the examples below.
*
  Interpreted to mean "that value  to be exceeded once per year."
                                   A-6

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A.8.1  Oxidant

     Under the log-normal model, the geometric mean is proportional to

emissions (in this case precursors or emissions, assumed to be reactive

hydrocarbons).  The oxidant standard expresses only a  maximum concentration

not to be exceeded.*  Intuitively, one would assume that rollback proportional

to the ratio of the observed maximum concentration to  the standard would be

required.  The model confirms this intuition by assuming that the geometric

standard deviation does not change with emissions reduction.   Equation (8)

then shows that C    values are proportional to the geometric means.   It is
                 II id A
not necessary to construct cumulative frequency distributions except  to see

if observed maximum values are approximately consistent  with  the  rest of the

data.   A distribution is useful, however,  in estimating  oxidant reduction

accompanying emission reduction.  For instance:

A.8.2  Escondido 1972

     Hourly maximum = 0.32 ppm   (observed)

     Geometric mean = 0.037 ppm

     Geometric std. dev. = 1.65 ppm

     Federal 1 hour std. = .08 ppm

     Suppose oxidant forming hydrocarbons  are reduced  by 50%, resulting in

a new oxidant distribution with M  = .0185 and S  unchanged at 1.65.   Using

c. = .08 ppm in equation 4 and solving for z yields 2.94.  This corresponds

to 0.36%, or 31 of possible 8760 hours during the year would be expected to

exceed the standard of  .08 ppm.  Over 12%  of the hourly averages  would be

expected to exceed standards with the original 1972 distribution  of oxidant

values.  This illustrates the non-linear nature of emission reduction-air

quality relationship.

A.8.3  Carbon Monoxide

     The federal standards for CO are based on two averaging times, 35 ppm

for one hour and 9 ppm for an 8 hour average.  If the  one hour standard

were to be met, a proportional reduction similar to that described for

oxidant would be necessary.  The 8 hour standard must  be approached some-

what differently.   If a distribution of 8  hour averages is not readily

available, it may be estimated according to the method of Larsen.  Briefly,

*
  Or to be exceeded  once per year, depending on  interpretation.

                                   A-7

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this method assumes that maximum values are   proportional  to averaging
time raised to an exponent.   Alternatively, the 8 hour distribution  can be
estimated from other time average distributions which are available.   For
this report, one hour and 24 hour distributions were available for  1972
(Fig. A-12).  Interpolating between these distributions,  C  „ is estimated at
                                                          max
99.9% (the second highest 8 hour average).   Both techniques yielded  about
20 ppm as an 8 hour expected maximum value for downtown San Diego in 1972.
     Although both the one hour and the 8 hour standards  for CO are
exceeded in downtown San Diego in 1972, emission reduction would have to be
based on the 8 hour level rather than the one hour level  since the  former
requires a greater rollback.
A.8.4  Suspended Particulate Matter
     The federal standard involves both an annual geometric mean and a
daily maximum value.  Under the log-normal  model, this standard would
define a hypothetical distribution having an annual  geometric mean  of 75
micrograms per cubic meter and a geometric standard  deviation of 1.68
(calculated assuming C    to be 260 and that sampling is  done on a  5 day
                      IMuX
cycle).
     A station with an observed S  less than 1.68 would simultaneously meet
                                 3
both standards by a reduction of the geometric mean.  Applying equation (7)
to El Cajon suspended particulate distribution, for  instance:
A.8.5  El Cajon, 1972

                M  = 97   S  * 1.56  Cmav =288   z  = 2.45 for 70 samples/year
                 g         g          max
     Since C    = M  S z, a reduction of M  from 97  to 75 (23%) would change
            max    99                   9
Cmax to 223'     .
                        Cmax=75 0.56)2'45 = 233
                                     o
Thus the maximum standard of 260 M/M  would also be met.
     If a station has an S  greater than 1.68, a rollback would have to be
based on C    rather than M  in order for both standards  to be met.
                                   A-8

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|                        If natural  background in this example were, say, 30 micrograms
                     per cubic meter, A~7 percent rollback from anthropogenic sources would
I                   be 33% rather than 23%.   The higher the assumed background,  the more
                     severe the reduction from man taade sources.  Cmnv and $„ remain
                                                                  max      y
•                   uneffected by this assumption unless the nature of suspended par-
                     ticulates changes.
•                  A. 8. 6   Sulfur Dioxide
                         The  federal standards for SCL  involve both  an annual average
•                  (.03 ppm) and a maximum 24 hour average  (.14 ppm).  These two standards
•                  would define a "hypothetical" log-normal distribution of daily  average
                    values.   A "z" value for  (1-1/365) would be taken from statistical
•                  tables and the arithmetic mean (m) converted to  its geometric counter-
                    part by solving equations 8 & 9,
•                                    M = m         2
                                       9  exp (.OSln'-S  )                             (8)
I
•

•                  of actual daily average SOp concentration is constructed for a given
^H
                         After calculation of the hypothetical M  and S  , a distribution
                    station and the actual M  and S  calculated.  If the actual S  is less
                                            *?      3                             y
                    than the hypothetical S  then a reduction of the geometric mean to the
                    standard will be accornpanyed by a corresponding reduction of the maximum
                    expected value to below the standard.   If S  is greater than the
I                    hypothetical, then rollback reduction would have to be based on C
                                                                                     max
                    as with suspended particulates.  Equations 7 & 8 are only soluble by
•                  approximation methods and this procedure is omitted here since sulfur
                    dioxide level are well  below the standards in San Diego County.  It
                                                       A-9

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is pointed out, however, that the geometric and arithmetic means are
proportional under the log-normal model  and that either may be used to
calculate rollback since S  is assumed to be unchanged with reduced
emissions (See Eq. 8).
     If a 24 hour distribution is not available, it may be constructed
from hourly data as discussed under .carbon monoxide.  Application of the
24 hour maximum or the yearly average to rollback would be dictated by
the hypothetical S  value compared to the observed value.  (The
suspended particulate standards present an analagous situation).
A.3.7  Nitrogen Dioxide
     The federal standard for NCL sets a limit on the yearly average.
In this case, a distribution of values need not be constructed.
If HO 2 is assumed, however, to be log-normally distributed, equation 8
shows that geometric and arithmetic means are proportional (S  remains
constant).  Rollback can then be calculated using the arithmetic mean.
Implicit is the assumption that hydrocarbons and not oxides of nitrogen
are limiting in the formation of oxidant.
                                   A-lO

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Table A-l.   Federal Ambient Air Quality Standards

Pollutant
Photochemical
Oxidants
(Corrected for NC>2)
Carbon Monoxide


Nitrogen Dioxide

Sulfur Dioxide



Suspended Particulate
Matter

Averaging
Time
1 hour
12 hours
8 hours
1 hour
Annual Average
1 hour
Annual Average
24 hours
3 hours
1 hour
Annual Geo-
metric Mean
24 hours
Federaf S
Primary
1 60 H9/m3
(0 08 ppm'

10 rng/m3
(9 ppm)
40 mg/m3
(35jjpm)
100 ug/m3
(0 05 ppmi
	
80 ug/m 3
(-03 ppm)
365 ug/m^
(0 14 ppm)
	
_._
75 ug/m3
260 ug/m3
ra^dorch
Secondary
Same a
Primary
S'ondord
Some as
Primary
Standard
Same as
Primary
Standard
	
60 ug/m 3
(0,02 ppm;
260 ug/m3
(0,10 ppmj
1300 ug/m3
(Q 5 ppmj
„_-
60 ug/m3
i 50 uq/rr>3
                     A-ll

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               Table A-2.  List of Air Monitoring Stations in
                           San Diego County
         Station


Mission Valley


El Cajon
Escondido - Fire Station
Oceanside
San Diego
     Address
110 E. Lexington
Chula Vista - Fire Station     100 E. J. Street
100 S. Cleveland
1111 Island Avenue
San Diego - Public Library     8th and E. St.
San Diego - Chollas Heights    581 Ryan Road
  Site Code
3703 Camino Del Rio     056820005 101
052220002 101
                        051360001 101
100 E. Valley Pkwy.     052460001 101
055320003 101
056800004 101
                        056800001 A01
                        056800005 101
                                   A-12

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                                      A-21

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                                        A-22

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                                 REFERENCES
A-l.  "Air Quality Monitoring Station Siting Study for the San Diego
      County Air Pollution Control District," Pacific Environmental
      Services, Inc., March, 1974.

A-2.  TRW, Inc., "Air Quality Implementation Plan Development for
      Critical California Regions: Summary Report," Transportation
      & Environmental Operations of TRW, Inc., Report for EPA.

A-3.  California Air Resources Board, Quarterly Report,  December,
      1972.

A-4.  Larsen, R. I., "A Mathematical  Model for Relating  Air Quality
      Measurements to Air Quality Standards," U.  S. Environmental
      Protection Agency, Pub #AP-89,  November, 1971.

A-5.  Larsen, R. I. et al., "A Method for Calculating Precursor
      Reduction Needed to Achieve an  Oxidant Air Quality Standard,
      EPA Preliminary Draft, August,  1972.

A-6.  Goeller, Bruce, et al., San Diego Clean Air Project Summary
      Report R-1362-SD, Rand Corp., Santa Monica, California,
      December, 1973.

A-7.  "Proposed Amendments to State of California Implementation
      Plan for Achieving and Maintaining National Ambient Air
      Quality Standards," California  Air Resources Board Support
      Document, June 13, 1974.
                                    A-31

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                   APPENDIX  B-SAN DIEGO POPULATION  DATA

     The population data base is of primary importance in air quality
planning.  This is particularly true in areas of rapid population
growth such as San Diego is currently experiencing.  Three estimates
of population growth for San Diego County are presented in Table B-l.
The estimate chosen for use in this report is that of the San Diego
Comprehensive Planning Organization (CPO) which projects an approximate
2.3% annual growth, with some leveling off toward the year 2000.  A
brief discussion of the three projections and reasons for the choice of
CPO estimate is given below.
     The Bureau of Economic Analysis of the U.S. Department of Commerce
(DOC) has made copulation projections for Standard Metropolitan Statistical
             P I
Areas (SMSA).     For San Diego, the SMSA is equivalent to the county area.
The "C"  or middle series natural population increase, i.e. births minus
deaths,  is shown in Figure B-l.   Migration is estimated for SMSA's by
assuming that economic opportunity is the determining factor.  In areas
with a large number of retired persons, such as San Diego, this population
segment is included separately in the calculations.  Other assumptions
include a trend toward geographic homogeneity in employment and other social
and economic variables, along with continued per capita income growth  and
per man  hour output resulting from technological progress.  Also, possible
catastrophic events (such as war, ecological disaster, etc.) are not
considered.  The fertility rate  nationally is assumed to approach 2,787/1000
women in the year 2000 under series "C" projections.   San Diego County
shows an expected overall growth rate of 1.59% annually, compared to the
national  average growth rate of  1.36%.
     The population research unit of the California Department of Finance
(DOF) makes population estimates and projections for cities and counties
in the state, mainly for purposes of tax revenue distribution (i.e.,
              R ?
gasoline tax).      Six different population estimation techniques are  used,
with the "certified" estimate being an average of the six.  Three of these
methods  add migration to natural increases, using changes in school
enrollment by age group to gauge migration.  Empirical equations are
extrapolated to obtain population projections for a given area.   A
fourth method uses historical  ratios of various indices  between the

                                    B-l

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county and the state.   Variables which are included are births,  deaths,
school enrollment, employment, income taxes, and auto and voter  registration,
Again, empirical  relations are extrapolated to obtain future population
estimates.  A fifth technique uses residential electric customers as a
guide to changes  in occupied housing units.  Combining this data with
"average" household size and estimates of persons not in housing units,
area populations  are calculated.  In the sixth and last method,  separate
estimates of population of age groups are summed to a total population.
Examples of estimating methods for different age brackets are school
enrollment (for ages 5-7) and social security recipients (for ages 65
and over).  The six separate estimates by counties are averaged  to yield
a final  result.  Although several  series of projections are made using
                                                                     B-4
different fertility and migration rates into the state, Series  D-100
(including a constant 97,400 military population), was chosen as a mid-
range and most probable projection.   Also shown is Series E-0, which
assumes  a fertility rate of 2.11 births/woman and no migration into the
state through the year 2000.
     The San Diego County CPO has developed the Cohort Survival  Method
                                 R— *3
for estimating future population.  "    Briefly, the method divides the
population into 5-year age groups, advancing each group by five  year
intervals (corrected for survival  rate).  Adding birth and death figures
yields the total  natural change in population.  Migration estimates
related  to employment are then added to each age group.  Finally,
forecasts of retirement migration to San Diego County are made and added
to the total.  The resulting population forecase is given for five year
periods.
     Graph B-l shows that a range of 6% and 17% difference occurs between
estimates from the three sources for the years 1975 and 2000 respectively.
Note that all sources use 1970 census population for San Diego County.
The contrast between the mid-range DOC and the state and county  estimates
is particularly large.  Detailed calculations behind the estimates were
not investigated, but it seems likely that the DOC projections are less
"fine tuned" to local factors than the other projections.  Note that even
the "no migration" series E-0 of DOC is higher than the federal  estimate.
For this reason and the fact that the CPO and D-100 series projections are
close together, emphasis in this report will be placed on  CPO estimates.

                                    B-2

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The relatively rapid growth rate for San Diego County compared to the

nation as a whole (2.3% annual  v. 1.36%) indicates that the County will

double in population between 1970 and 2000.

     As with all  estimates of future population, the CPO projection is

likely to be more accurate for the near term than the longer term.

It is also necessary to point out the inability to accurately forecast

effects of changing economic and social  factors which might dramatically

change absolute population and its distribution (i.e., energy related

constraints on transportation).   For the time frame of this report,

however,  differences in population projections will  not have a dramatic

effect on measures required to maintain  air  quality.
                                   B-3

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        Table  B-l.   Population  Projections  for  San  Diego  County
                    (in  Millions  of  Persons)
SOURCE
U.S. Dept.
of Commerce
series C
California
State Dept.
of Finance
E-0
D-100
San Diego
Comprehen-
sive Plann-
ing Organ-
ization
1970

T
1.3581


•j
1.3581
1.3581



i
1.3581
1975


1.475




1.573




1.544
1980


1.596



1.650
1.801




1.744
1985


1.741




2.022




2.021
1990


1.901



1.955
2.242




2.287
1995


N/A




2.450




2.450
2000


2.186



2.11
2.654




2.552
1   1970 Census Data for San Diego County
                                   B-4

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1.0
                                                              1995
2000
      Figure  B-1.   Population Projections for  San  Diego  County
                                 B-5

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                                 REFERENCES
B-l.  "Population and Economic Activity in the United States and Standard
      Metropolitan Statistical Areas",  U.S.  Environmental  Protection
      Agency, July, 1972.

B-2.  "California Population, 1971",  California State Dept.  of Finance,
      May, 1972.

B-3.  "Technical  Users Manual for Interactive Population/Employment
      Forecasting Model" San Diego County Comprehensive Planning
      Organization, June,  1972.

B-4.  "Provisional  Projections of California  Counties  to 2000,"  Population
      Research Unit,  California State Department of  Finance,  Report 74P-1,
      January 10, 1974.
                                    B-6

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                       APPENDIX  C   -   NEDS  Update



     The National Emissions Data System (NEDS) was conceived to be an

extremely detailed emissions inventory of each air quality control

region (AQCR) which would provide information concerning stationary

sources emitting greater than 100 tons per year of any pollutant.  Among

the data included in the NEDS for a given source would be:

     •  a description by Standard Industrial Code (SIC) and
        Source Classification Code  (SCC).

     •  magnitude of emissions in tons/year.

     •  frequency and duration of operation in terms of
        hours/day, days/week and months/year.

     •  type of control equipment and their estimated
        efficiencies.

     •  location by Universal Transverse Mercator (UTM)
        zone and coordinates (see C-l, C-2, C-3 and C-4
        for a detailed description of the UTM system).

     a1!  data would be stored in computers to facilitate rapid retrieval.

The inventories could be updated from year to year such that trends

may be extrapolated.

     The purpose of this task was to update the most current NEDS (1970)

inventory for the San Diego AQCR to the year 1972.   Unfortunately, the

1970 NEDS inventory was in many aspects useless for this task.   In the

first place, roughly only 20% of the reportable sources (those with

emissions of greater than 100 tons/year of any pollutant) in 1970 had

been coded  (c-5).  Secondly, many of the sources reported in 1970 had

either (a)  changed ownerships and thus names (b)  moved to a new location

or (c) emitted less than 100 tons/year in  1972 and thus had to be

eliminated.   Thirdly, many new reportable  sources appeared in 1972.   For

all practical purposes, the 1970 NEDS  inventory was not utilized at all.

The data  used in compiling a 1972 inventory in the NEDS format was

obtained  from the San Diego County APCD.   Only point sources were in-

cluded in the inventory (the NEDS inventory is devised to include both

point and area stationary sources).

     Because of time and manpower constraints, all  the information normally

reported  for a source was not included.
                                   C-l

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Specifically, information recorded in this task were:
     •  State, county, AQCR and plant ID number codes.
     •  City code (when available), UTM zone, UTM coordinates,
        establishment name and address, personal  contact at the
        source (when available) and ownership (local,  state or
        federal  government, private, utility).
     •  Point ID number, year of record, SIC code, IPP  process
        code (when applicable), stack data (when applicable and
        available).
     •  Boiler design capacity (when applicable and available).
     •  Emission estimates and estimation method (when  available).
     •  SCC code, fuel process operating and maximum design rate
        (when applicable and available), comments, source and
        confidentiality codes.

     For the purposes of the project, three additional  sets of  information
not normally required by the NEDS inventory were reported:
     t  State plane  coordinates of the location of the  source
        (see C-2 for an explanation of this coordinate  system).
     t  Percent  of total hydrocarbons emitted (if any)  which
        are reactive.
     t  Point sources emitting between 1 and 100 tons/year of any
        pollutant.  This was done because where stationary source
        control  programs are in effect in an area, a majority of the
        sources  will emit less than 100 tons/year.  If  these sources
        were omitted from the inventory, a substantial  quantity of
        pollutants would remain unreported.
     Two difficulties were encountered in compiling the NEDS inventory.
The primary difficulty involved locating the sources on a U.S.  Geological
Survey Map  for  UTM coordinates and San Diego County Cartographic Service
Maps for state plane coordinates.  Often times, the addresses were  vague,
imprecise or gave a post office box number.  This difficulty was resolved
by conversations with Louthen of the San Diego County APCD (C-7), who is
familiar with the location of all the sources in question.   The second
problem involved the coding of a source which emitted only one  ton/year of
a pollutant, but had three or more boilers producing this pollutant.
The NEDS instructions are that every boiler is coded as a new source, and
if one figure is reported for all the boilers, the emissions are pro-
portioned according to the size of the boilers.  In the case of three or
more boilers of equal size emitting a total of one ton/year, each boiler
emits less than  0.33 tons/year.  Because of round-off problems, all
                                    C-2

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sources emitting less than 0.5 tons/year are automaticcly assigned zero

emissions.   Thus,  the three or more boilers  would be excluded  from the

inventory.   The decision was made to forego  the NEDS instructions  in

this situation and to code all  the boilers as  one single source.
                             REFERENCES
     C-l  Grids and Grid Reference.  Department of the Army.
          Washington, D.C. Publication No. TM5-241-1, June, 1967.

     C-2  Deetz, C.H. and Adams, D.S., Elements of Map Projection,
          U.S. Department of Commerce.  Washington, D.C., Spec.
          Publication No. 68, 1945.

     C-3  Universal Transverse Mercator Grid, U.S. Department of the
          Army, Washington, D.C., Publication No.  TM5-241-8,  July,
          1968.

     C-4  Universal Transverse Mercator Grid, Zone to Zone Trans-
          formation Tables, U.S. Department of the Army, Washington
          D.C., Publication No. TM5-241-2, June, 1957.

     C-5  San Diego APCD, private communication, May, 1974.

     C-6  Guide for Compiling a Comprehensive Emission Inventory
          (revised).  EPA, Office of Air and Water Programs,
          Office of Air Quality Planning and Standards, Research
          Triangle Park, North Carolina, March, 1973
 •                    C-7  W. Louthen, San Diego County APCD, private communication,
                           May, 1974.
                                  C-3

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                 APPENDIX D - DELPHI PANEL MEMBERS AND RESULTS


     As part of the effort to create a pilot air quality maintenance plan

(AQMP) for San Diego, a Delphi Panel session was held on June 10, 1974, in

San Diego, to obtain local "expert" opinions of candidate land use

measures for air quality maintenance.   Approximately two weeks before the

session, invitations to attend were extended to twenty eight members of

various local city and county planning agencies, business groups, various

regional planning agencies and others.   The criteria for selecting panel

members were:

     1)  Knowledge of the issues in land use decisions or air quality.

     2)  Represented an agency or government arm that had a  policy making
         or policy-influencing role in land use matters, e.g. the
         Air Resources Board.

     3)  Represented business or citizen interests that would be
         affected by any of the major  land use control measures.

     4)  Represented companies or agencies which would play  a role
         (directly or indirectly) in the successful  implementation
         of an AQMP, e.g. San Diego Transit Company.

The composition of the panel  by no means purports to be completely

representative of all the interest  groups in San Diego.

     Twenty-five persons agreed to participate and were sent letters of

confirmation one week before  the session (see Table D-l). Of these,

fifteen actually attended the panel session, five sent representatives  or

more qualified persons and the remaining were unable to attend due to

conflicts in scheduling.  In  addition,  during the course of  the session,

five members left to attend to other previously scheduled commitments

resulting in fourteen persons who were  able to participate in all the rounds

of the questionnaire survey.   The list of attendees is shown in Table D-2.

     The Delphi Panel was scheduled for 1:00 pm in the conference room

facilities of the Comprehensive Planning Organization.  The  session ran

approximately three and one-half hours  with breaks between rounds (except

for the first two) during which the previous round's results were

tabulated for presentation in the next  round.  A total of seven rounds

were utilized in the Delphi questionnaire to judge overall attractiveness,

implementability and effectiveness of  candidate control measures.

                                    D-l

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     Following Table D-2 is the actual  Delphi  questionnaire which was
used and the results of the session (Table D-3).
                                   D-2

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              Table D.I - List of People Who were Notified
                          of the Delphi Panel
Mr. Michael Bedaux
Planning Director
704 Third Street
Oceanside, California  92054

Mr. Richard Brown
County Board of Supervisors
1600 Pacific Highway
Room 335
San Diego, California  92101

Mr. Grant Burns
Director of Planning
Planning Department
8130 Allison Street
La Mesa, California

Mr. Darrell Daugherty
Planning Director
100 Valley Street
Escondido, California  92025

Mr. William Dotson
Department of Transportation
P.O. Box 8146
San Diego, California  92138

Mr. Thomas E. Firle
Environmental Management Coordinator
San Diego Unified Port District
3165 Pacific Highway
San Diego, California  92112

Mr. James Goff
Planning Director
City Administration Building
Community Concourse
San Diego, California  92101

Lee Grissom
Chamber of Commerce, San Diego
233 "A" Street
Suite 300
San Diego, California
Mr. Scott Harvey
Legislative Director
Building Contractor's
P.O. Box 20006
San Diego, California
                 Mr. Daniel Gorfain
                 Assistant Director & Chief Planner
                 6154 Mission Gorge Road
                 Suite 220
                 San Diego, California  92120

                 Stuart Shaffer
                 Comprehensive Planning Organization
                 Suite 524
                 1200 Third Avenue
                 San Diego, California  92101

                 Mr. Evan Jones
                 Ace Auto Parks,
                 1111 Seventh Avenue
                 San Diego, California  92101

                 Mr. Art Letter
                 Comprehensive Planning Organization
                 Suite 524
                 1200 Third Avenue
                 San Diego, California  92101

                 Mr, Daniel Lieberman
                 Air Resources Board
                 1709 Eleventh Street
                 Sacramento, California  95814

                 Mr. Herman Rosenthal
                 Director, Land Use Programs,
                 County Administration Center
                 1600 Pacific Highwat
                 Mail Station 201
                 San Diego, California  92101

                 Ms. Cordelia Ridenour
                 Assistant Director, City of
                 San Diego Environmental
                 Quality Department
                 202 C. Street EQD 7-A
                 San Diego, California  92101

                 Mr. Norman Schell
                 San Diego Air Pollution Control  Dist.
                 1600 Pacific Highway
                 San Diego, California  92101
Association

 92120
                                   D-3

-------
Mr. Edward Schmidt
Executive Officer
Local Agency Formation Commission
Room 456
1600 Pacific Highwat
San Diego, California  92101

Mr. Richard Sommerville
San Diego Air Pollution Control Dist.
1600 Pacific Highway
San Diego, California  92101

Mr. Roger Snobel
San Diego Transit Company
100 Sixteenth Street
San Diego, California  92101

Mr. Larry Taylor
Office of Environmental Management
1600 Pacific Highway
San Diego, California  92101

Mr. Virgil Henson
Director of Bulling and Planning
207 Highland Avenue
El Cajon, California  92020

Mr. Alan Williams
San Diego Branch - WESTNAVFACENGCOM
1220 Pacific Highway
Attention:  92 EP
San Diego, California  92132

Mr. Frazier Armbruster
San Diego Chamber of Commerce
704 3rd Street
San Diego, California

Mr. Herm Rosenthal
San Diego County
1600 Pacific Highwat
San Diego, California  92101

Michael Madigan
Mayor's Office
San Diego, California
                                    D-4

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                 Table D.2  - Delphi Panel Members
NAME

James T. Cheshire

Virgil R. Henson

Daniel Lieberman

Evan V. Jones

Roger Snoble

W. Alan Williams


Frazier Armbruster

Michel A. Bedaux

Max Schmidt

Steve Sachs


Tomas E. Firle


Herm Rosenthal


Mike Madigan

P. L. Hinshaw

Norman Schell
Rich Sommerville

Cordelia Ridenour


Susan D. Schlosser

Daniel Gorfain


Richard Brown
ADDRESS

CALTRANS - San Diego

Planning Department, City of El Cajon

Air Resources Board, Sacramento

Ace Auto Parks Inc., San Diego

San Diego Transit Company, San Diego

Naval Facility Engineering Commission,
San Diego

San Diego Chamber of Commerce

Planning Department, City of Oceanside

Planning Department, City of San Diego

Comprehensive Planning Organization,
San Diego

San Diego Unified Port District,
San Diego

San Diego County, 1600 Pacific Hwy.,
San Diego  92101

Mayor's Office, San Diego

Mayor's Office, San Diego

Air Pollution Control District, County of
San Diego

Environmental Quality Department, City
of San Diego

Local Agency Formation Commission

San Diego Coast Regional Commission


San Diego County Board of Supervisors
                                    D-5

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                                APPENDIX E


        RECENT CALIFORNIA ENVIRONMENTAL AND LAND USE LEGISLATION


     This appendix reviews pertinent State legislation (existing and

pending) that have potential  impact on air quality by virtue of the

fact that they contain land use control measures.  Land use control

has traditionally been a function of cities and counties through state

enabling legislation under the state police powers to protect the public

health, safety and general welfare of its citizens.   The new trend,

however, is to move away from local control and place more of the land

use policy development at the regional and even state levels.  Nat-

urally, this trend has met with resistance from local governments who

desire to retain their jurisdictional  controls and from a Congress.

that hesitates to enter an area of control  that is traditionally local.

A number of land use bills are currently pending in the California

Legislature that propose innovative and new approaches for air quality

maintenance and land use control  but do not have very promising

prospects of being passed during the current session.  This may be due

to the recent Congressional  defeat on a procedural motion of a major

piece of national land use legislation sponsored by Udall that would

have given financial assistance for state planning efforts.  The fact

that 1974 is an election year and other national  political  developments

have also served to make the passage of controversial bills very

difficult this year.  In the following review, only significant

pieces of legislation that might impact on regional  air quality are

included.


ENACTED LEGISLATION

     The following bills have already been enacted and enjoy varying

degrees of success.   Their common problem has been the lack of

initiative of state and local  agencies to apply the spirit of the

legislations.
                                   E-l

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LAND CONSERVATION ACT - WILLIAMSON (1965)
     This bill  was designed to alleviate pressures  for conversion of
agricultural  lands and to preserve open space by providing preferential
tax assessment based upon the productive value of the land.   It has
not succeeded and faces a number of problems in achieving its objectives.
Under this act, private landowners can contract agricultural  and other
lands to be restricted to open space and so enjoy reduced taxes.  The
state pays a  subvention to local  government for a portion of  the foregone
property taxes.  The program established by this act does not serve a
local or regional land use purpose because it leaves the initiative
with the landowner to provide his land for open space.

SUBDIVISION MAP ACT AMENDMENT - MCCARTHY (1970)
     This amendment to the Subdivision Map Act attempted to relate the
planning, zoning and subdivision processes by requiring that
          i)   after 1973, cities and counties could not
              approve a tentative or final  subdivision map
              inconsistent with their general plans;
         ii)   after 1973, local zoning ordinances and variances must
              conform to the general  plan;
        iii)   beginning in 1973, it became illegal  for local  and
              county municipalities to amend their general plans
              more than three times a year.

McATEER-PETRIS ACT AMENDMENT (1969)
     This act established the Bay Conservation and Development
Commission (BCDC) as a permanent state agency to regulate and plan for
the lands bordering the San Francisco Bay.
                                   E-2

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CALIFORNIA COASTAL ZONE ACT (1972)
     This act established the California Coastal Zone Commissions and
empowered them with a development permit system for virtually all con-
struction or changes within a 1000 yard band along the shoreline.  A
California Coastal Zone Plan is also being developed under the Act
and will be presented to the California Legislature in 1976.

AB 1575  - WARREN  (1973)
     Effective in 1975, this bill creates a five-man Energy, Resources
Conservation and  Development Commission which will monitor and review
proposed sitings  of power plants of over fifty megawatts.  The Commission
is empowered to enforce the rules and regulations of local agencies
concerning sitings and imposes regulations where none exist.  It has
pre-emptive authority through the review process which is performed at
an early stage in the decision process.  The Commission will also
arbitrate between the utility company and local agencies where non-
compliance occurs.  It has no pre-emptive powers in matters that concern
air and water quality.

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)  (1970)
     Enacted in 1970 and enhanced through subsequent Supreme Court
rulings (see below), this act established procedural  requirements for
environmental  impact reporting.

AB 889 (1972)
     This bill  was passed subsequent to a Supreme Court ruling and
extends CEQA's  application by requiring that local  governments prepare
environmental  impact reports  on  projects over which they  have permit
review power.
 Friends of Mammoth vs.  Mono  County (1972)
2Ibid.

                                   E-3

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 SB  981  (1972)
      This  bill directed the Air Resource Board (ARB), in consultation
 with  the Office of  Planning and Research and the Office of Inter-
 governmental Management,  to prepare a report on the proposed guidelines
 for the preparation of an air  pollution control in city and county
 general plans.
      In response  to this  bill, ARB initiated a study  of proposed
 guidelines for preparation of an  air pollution element  in city and
 county  plans which  is the basis for SB1543, now pending in the California
 legislature (see  below).

PENDING  LEGISLATION  (CURRENT  SESSION)
     The following bills,  now pending,  represent attempts  to  reconcile
air quality with  general  plans  at  the  regional  and  local levels,  create
a regulatory commission  for land  use,  establish a  program  for defining
environmentally critical  areas, consolidate multi-jurisdictional,  multi-
functional  agencies  and  improve existing legislation.  The  status  of
each bill  as of June 18  is indicated  in parentheses.

SB 1543  -  NEJEDLY (Senate Committee on  Local Government)
     This  bill  requires  the ARB to:
     0  establish allowable emission  limits for each  pollutant
     0  provide emission  factors which  relate  quantity and  type
        of pollutants to  land use  and  transportation  plans
     0  monitor the  general plans  and  environmental  impact  reports
        of non-major air  basins of the  State

     In  San Diego, the Comprehensive  Planning  Organization  (CPO)  would
be required to:
     0  determine that the regional transportation  plan  is  consistent
        with the  allocation emissions  and to ensure  that the  finally
        adopted'plan is  in conformance  with allocations  emissions
     0  adopt emissions  limits  stating  the  quality  of  pollutants  in
        each pollutant category  in subdivisions of  the air  basin
        which were established  for emissions allocation  purposes
     0  review environmental  impact reports for projects with
        potential  air quality impacts
     0  review city  and  county  general  regional  land  use and  trans-
        portation plans  for conformance with the emissions  limits
        allocated to the  basin  subdivisions
                                  E-4

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     Cities and Counties shall:

     0  determine that air pollution emissions directly or indirectly

        generated by the land use and transportation aspects of their

        plans do not violate allowable emissions levels

     0  provide for a review procedure of air pollution emissions

        of proposed projects


     Air pollution control districts shall:

     0  review their orders, rules and regulations to conform with

        the allocations of emissions limits

     0  exercise permit reviews to monitor projects which have impact

        on air quality


AB 2978 - PRIOLO (Assembly Ways and Means Committee)

     This bill would create a State Land Use Commission and Depart-

ment of Land Use Management, and requires local  public agencies to

nominate areas of critical state concern.  The State Land Use

Commission is designed to

     i)  facilitate, coordinate and monitor state and local  land use

         programs, expenditure of state funds and federal  grants-in-

         aid projects

    ii)  prepare a policies report which shall  be a comprehensive

         state land use policy report to be subject to review every

         two years

     The Department of Land Use Management shall

     i)  analyze and report state policies for land use goals, EIR's

         state actions detrimental  to the land use goals

    ii)  study economic effects of land use policies

   iii)  monitor expenditures and state and local  programs for

         regulation of critical  areas
                                   E-5

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     By January 1976, the Commission is required to submit a California
Report on Areas of Critical  Concern, delineating those areas which
contain important agricultural, historical, cultural, or aesthetic
values.  Subsequently, the Commission is required to submit a set of
development guidelines for the critical areas and insure that local
plans and ordinances conform with the guidelines.

AB 2040 - KNOX (Senate Local Government Committee)
     This bill would create a Regional  Planning Agency for the S.F.  Bay
Area that would exercise veto power over individual local  governments'
actions that do not conform with the Agency's Plan.  It would act as
the umbrella agency to oversee the Metropolitan Transportation Commission
and Bay Area Sewer Services Agency.

AB 1254 - BERMAN (Senate Finance Committee)
     This bill would create governing body for an area of critical
concern, the Santa Monica Mountains.  A set of development guidelines
for the area would regulate land use.

SB 1556 - BIDDLE (In Senate for Vote)
     This bill would establish a South Coast Air Pollution Control
District, similar to the Bay Area Pollution Control District, that has
jurisdiction over the entire South Coast air basin.  In addition, it
would require that board members of the Air Resources Board be appointed
to fixed four year terms on a full time basis and can serve only if they
are confirmed by the Legislature.  Several similar bills have been
introduced in previous sessions and have been unsuccessful in gaining
passage.
                                   E-6

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AB 3421 - Z'BERG (Assembly Ways and Means Committee)

     This bill is based on a study of the organization of state-level

environmental resources control board with land use and other powers,

which was directed by Assembly Concurrent Resolution, November 16, 1973

Session.

     This bill would create an independent State Environmental Resources

Board and nine Regional Environmental Resources Boards with responsi-

bility and authority for development and implementation of a comp-

rehensive state land use plan and for comprehensive control  of air,

water, solid waste, pesticide, nuclear radiation and noise pollution.

The Board would also be charged with the development and implementation

of a statewide comprehensive transportation plan.

     The Act also provides for public involvement by creating a permanent

Citizens Environmental  Protection Council to advise the State Board on

its policies and programs.


AB 2850 - DUNLAP (Passed Assembly, in Senate)

     This is an amendment to the Williamson Act which requires that

lands eligible for special tax considerations under the Williamson Act

already be designated in the local general  plan.  It serves  to ensure

some degree of consistency between the Williamson Act and local  plans.
AB 2852 - DUNLAP (Assembly Committee for Revenue and Taxation)

     This bill provides for phased development in the local plan by

requiring that such lands scheduled for development in the subsequent

ten years be designated in the plan.  Such lands would then be eligible

for tax deferment privileges under the Williamson Act.  The objective

of the Bill  is to discourage leapfrog development.


AB 2853 - DUNLAP (Passed Assembly, in Senate)

     This bill revises and simplifies the formula for subvention

payments under the Williamson Act.  It gives priority to fringes of

urban areas.
                                   E-7

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AB 2854 - DUNLAP (Assembly Committee for Revenue and Taxation)
     This act serves to simplify the procedures for applying for a
Williamson contract and reduces the open space easement (period of
time before development occurs) from twenty to ten years for
eligibility for a contract.

AB 2856 - DUNLAP (Assembly Committee for Revenue and Taxation)
     This bill  establishes state environmental contract program whereby,
if a Williamson Act contract is denied,  and the land is demonstrated
to be in an area of critical state concern, the State Resources Agency
may grant a contract for fifteen years.

AB 2859 - DUNLAP (Passed Assembly, in Senate Committee on Local
                  Government)
     This bill  requires that when the Local Agency Formation Commissions
(LAFCO) draw up their spheres of influence, they must consider  the
existence of agricultural  and open space lands.  In approving annex-
ations, LAFCO's should place priority on preserving agricultural land
usage.
                                  E-8

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                               APPENDIX F

                      EMISSION PROJECTION MODELING



     The projection of pollutant emissions in San Diego is the culmina-

tion of a series of projections made by the Comprehensive Planning Organi-

zation in conjunction with the California Department of Transportation.

This appendix is devoted to a description of the models and procedures

employed in this process.

F.I  THE  CPO MODELING SYSTEM

     The CPO is using a series of computer forecasting models in order

to project and distribute the population, employment, transportation and

land use characteristics for each of the Regional Development Alternatives

to the year 1995.  Each model requires a series of policy assumptions as

"input."   The overall model sequence is shown on Table F--1.

InteractiveJ^opulation/Employment Forecasting Model  (IPEF)

     The Interactive Population/Employment Forecasting Model  (IPEF), is

a regional growth model designed to simulate the regional population and

employment growth process under different assumptions and policies.  It

considers such factors as mortality rates, birth rates, the effects of

the military population, the influence of industrial growth,  the impact

of retired people migrating to the region and the unemployment rate.  The

outputs or products of the IPEF model  are regionwide forecasts of popula-

tion and employment at five-year intervals for up to 30-40 years into

the future.   These products are used as inputs to the Urban Development

Model.
     Birth and Death Rates	
     Rates of Industrial  Growth*
     Retirement Migration	
     Military Migration	
     Unemployment Rate	
     U.S.  Growth Rate	
           -—Regional  Population
               (by age and sex)
IPEF     	Regional  Employment
               (by industry)
                                   F-l

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     The IPEF model is a synthesis of two widely used techniques:  the
cohort-survival method of population forecasting and an econometric ap-
proach to employment forecasting.  Traditionally, these methods have been
employed independent of each other, with the cohort-survival method con-
sidering such things as birth rates, death rates, and historical migra-
tion patterns, and the econometric model deriving employment forecasts
from past trends, national and state growth patterns, and interindustry
relationships.  Within the IPEF model framework these two techniques are
combined so that the linkages between the demographic and economic sectors
are explicit.
     The population-employment linkages are in two directions and account
for (1) the impact of employment opportunities on population migration,
and (2) the alternate effect of changes in the level of population on
population-serving employment.
     Figure F-l below, illustrates the relationship between the demo-
graphic and economic sectors explicit in the model framework.  The economic
sector is divided into two components:  basic and population-serving.
The "basic" component is assumed to be a function of the region's compara-
tive advantage (as reflected in historical trends) and the growth of
external (i.e., national) markets, and is, therefore, independent of both
the population-serving component of the economic sector and the demo-
graphic sector.  The "population-serving" component is assumed to respond
to changes in both the basic economic sector (as changes in basic employ-
ment alter the demand for business-serving activities) and the demographic
sector (as changes in population alter the demand for household-serving
activities).
     The demographic sector can also be divided into two components:  an
"autonomous"  component consisting of births, deaths, retirement migration,
and military  migration, and a "dependent" component consisting of employ-
ment related  migration.  Births and deaths are calculated by applying
age-specific  fertility and survival rates to the base period population.
Retirement and military migration are determined outside the model  frame-
work and are  supplied as inputs to the model.   The employment related
                                   F-3

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            DEMOGRAPHIC SECTOR
                Employment
                 Related
                 Migration
                                                ECONOMIC SECTOR
        Figure F-l.   IPEF Model: Interrelationships Between the
                     Demographic and Economic Sectors
migration component is a function of changes in total employment which,
in turn, is the sum of changes in basic and population-serving employment.
This linkage is shown in Figure F-l by the diagonal and horizontal arrows
running from the economic sector to the employment related migration
component of the demographic sector.
     The "two headed" horizontal arrow between employment related migra-
tion and population serving employment reflects the reciprocal impulses
existing between the demographic and economic sectors.  Autonomous changes
in the demographic sector through births, deaths, retirement migration
or military migration, or autonomous changes in the basic employment
sector will have a multiplier effect on population serving employment,
brought about through changes in employment related migration.  The
multiplier effect results from the secondary impulses that migration  has
on population-serving employment as the migrants produce or withdraw
demands for population serving activities.
                                   F-4

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The Urban Development Model (UDH)

     The land-use model employed by CPO is a version of the Projective

Land-Use Model (PLUM) originally developed for the San Francisco Bay Area

Transportation Study Commission.

     PLUM is designed to yield projections of the future small-area (i.e.,

zone level) distribution of population, employment and land-use within

an urban area based upon information on the distribution of these char-

acteristics in some base-year, coupled with a series of simple and intui-

tively appealing allocation algorithms.

     These algorithms are based upon two fundamental concepts.  The first

of these relates to a distinction between "basic" and "population-

serving" employment, and the second employs the notion of a spatial

"allocation function."



     "Population-serving" employment is that for which a local market or

service area may be identified based upon the location of the households

which it is intended to serve.  Typical examples might include retail

stores, schools, and the bulk of local government activities.  "Basic"

employment includes all other employment activities - that is, all that

employment whose location is relatively less dependent upon the precise

location of households within the urban region but rather on other factors

such as proximity to transportation facilities, space availability,

agglomeration economics, etc.  Typical example of this latter category

might be major industrial activities, regional service activities, etc.

     "Basic" employment is located exogenously prior to the operation of

PLUM.  A series of three spatial allocation functions are then used to

distribute the remaining "population-serving" employment and households

around these "basic" employment centers.  This process proceeds in three

steps, as illustrated in Figure F-2.

    (1)  An initial set of households associated with jerscns
         employed in "basic" employment activities are distri-
         buted with respect to the exogenously specified locations
         of "basic" employment;
                                   F-5

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  EXOGENOUS
 LOCATION OF
   "BASIC"
  EMPLOYMENT
        I
     SPATIAL
  DISTRIBUTION OF
"BASIC EMPLOYMENT"
   HOUSEHOLDS
        I
     CAPACITY
      CHECKS
    I     '    '
    LLJ.
   DISTRIBUTION OF
    "POPULATION-
      SERVING
     EMPLOYMENT"
      LL
     THRESHOLD
       CHECKS
                                     I
     SPATIAL
  DISTRIBUTION OF
"POPULATION-SERVING
   EMPLOYMENT"
   HOUSEHOLDS
 Figure F-2.  Illustrative Structure of "PLUM
                    F-6

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     (2)  "Population-serving" employment is then distributed
          with respect both to this initial  distribution of
          households and to the previously specified locations
          of "basic" employment; and
     (3)  Finally, a second set of households associated with
          persons employed in "population-serving" employment
          activities are distributed around those latter employ-
          ment locations.
     The allocations in each case are based upon simplistic descriptions
of the spatial  relationships between the activities involved, based pri-
marily on existing, base-year trip-making behavior and transportation
networks.  Three separate sets of allocation functions are developed for
"work-to-home"  (steps #1 and #3 above), for "home-to-shop" (step #2) and
for "work-to-shop" (step #2).  Each function takes the general form
illustrated in  Figure F-3.  In tiie case of the "work-to-home" function,
for example, the ordinate represents the probability of a worker locating
his residence at a given time (or distance)  from his work place.  These
functions are calibrated in part from inter-zonal  travel-time matrices
derived from conventional transportation network analysis and in part
from considerations of each zone's potential "attractiveness" as a loca-
tion for the activity being distributed.  In the case of population, for
example, this "attractiveness" is represented in terms of the residential
capacity of the available vacant land.
     For any given year, the model iterates  to a single,  equilibrium
solution, based upon the achievement of balance between the initial  ex-
ogenously specified location of basic employment and the resultant distri-
bution of population-serving employment and  the set of households assoc-
iated with both employment categories.   These allocations are subject to
a set of constraints, including an upperbound capacity constraint for
households within each district, a minimum threshold constraint for the
size of population-serving employment and a  set of land-consumption con-
straints reflecting the manner in which vacant land is consumed by
development.  The result is a final, internally-consistent set of small-
area projections of employment, population and land use by small-area
for a given target year.  For purposes of forecasting over a series of
                                   F-7

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time intervals the model  is applied recursively,  with the outputs fur

each forecast-year serving as the base for the next set of forecasts.

     Specifically, the output of the San Diego version of PLUM (UDM)

includes 22 different data items concerning population, housing,  employ-

ment and land use for each of 663 geographic traffic assignment zones.

It is this data which will be used to evaluate the ability of the various
Regional Development Alternatives to achieve Regional Goals and Objectives

These specific items are listed in the following  table:

                Urban Development Model  Output Categories

                 1.  Occupied housing units
                 2.  Single family housing units
                 3.  Multiple family housing units
                 4.  Total population
                 5.  Household population
                 6.  Group quarters population
                 7.  Employees at place  of residence
                 8.  Total employment
                 9.  Basic employment
                10.  Retail employment
                11.  Business service employment
                12.  Retail service employment
                13.  Education-related employment
                14.  Other employment
                15.  Households by income category
                16.  Average housing value
                17.  Total acreage
                18.  Net residential acreage
                19.  Acreage used for basic employment
                20.  Acreage used for local serving employment
                21.  Acreage used for streets and highways
                22.  Vacant land

Transportation Models

     CPO is using a series of four transportation models to test, or

evaluate, alternative regional transportation systems for the region.

These four models are:

                 1.  Trip Generation Model
                 2.  Trip Distribution Model
                 3.  Mode Split Model
                 4.  Trip Assignment Model
                                   F-9

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     Trip Generation Model.  Trip generation is the process of relating
the number of trips to characteristics of land use.  In other words, it
forms a tie between land use activity and travel.
     It determines the number of trips which will  start or end in a parti-
cular traffic assignment zone based on the demographic and land use char-
acteristics of that zone.  It does not connect the trip ends to form
trips as we normally think of them - this is done  by the trip distribu-
tion model.
     The desired end product of a trip generation  analysis is an accurate
estimate of the number of trip beginnings and endings in each of the
traffic assignment zones within the San Diego region.
Population	
Single family housing
    units 	
Income	:>
Total employment 	
Retail employment	
Service employment
                                 Trip
                                 Generation
                                 Model
•Person  Trips

•Attraction by trip
     purpose
        Trip generation
            rates
     Trip Distribution Model.   Trip distribution is the process by which
trips originating in one traffic assignment zone are distributed to other
zones in the study area.  Whereas the generation model identifies only
the number of trips beginning and ending at any location, the distribu-
tion model identifies where the trips are coming from or going to.
Several  types of transportation distribution models have been built.  The
most widely used is the gravity model, which is used in the San Diego
Transportation Model.
     The gravity model loosely parallels Newton's gravitational law.  It
is based upon the assumption that all trips starting from a zone are
attracted by the various generators and this attraction is in direct
proportion to the size of the attraction and in inverse proportion to
the spatial separations between them.  The measure of the spatial separa-
tion is the zone to zone travel time as expressed in the network.
                                  F-10

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          Zone to Zone
          Travel  Time
          Person trips	
          Attraction by trip
             purpose 	
Trip
Distribution
Model
   Zone-to-Zone
-> Person trips by
      type
      Mode  Split  Model.   The  mode  split  model  forecasts  the  distribution

 of total trips among  the available  modes  of  transportation.   A unique

 mode  split is forecast  for each traffic assignment  zone.  The model  incor-

 porates  the  characteristics  of both the transportation  system and  the

 user.  Transportation characteristics include  fares,  travel  time,  wait

 time  and convenience.   User  characteristics  include income  and spatial

 distribution (location).  The purpose of  the  trip is  also considered in

 determining  the  proportion of total  trips between any two places that

 would patronize  a particular mode.
      Income of trip make|
Zone-to-zone person
ur i pb oy type
Network-Zone-to-zone
travel time by mode

Mode
Split
Model
>

\

•-•^
*r
                                             Zone-to-zone vehicle trips

                                             Zone-to-zone transit trips
     Trip Assignment Model.  Trip assignment is the process of routing

the trips to specific linkages of a transportation system (freeway,

arterial, transit).  Trip assignments to the transportation network are

made based on the assumption that people will choose the fastest avail-

able route to their destination.  Separate assignments are made for each

mode based on the mode split output percentages.
                                   F-ll

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     Transit Network
     Zone-to-zone 	-  .   .      t 	-^Transit link volumes
     transit trips       ^  2 51?          "Transit point volumes
     Zone-to-zone 	    , Accinnmpnt     -»Highway link volumes
     vehicle trips          M^li             Vehicle turning movements
     Highway Network
     Plan Evaluation Model
     The evaluation of the  Regional  Development Alternatives policies
requires two types of computer operated activity:   Data Aggregation and
Evaluation.
     The first task is to identify the most pertinent data coming from
the UDM and the transportation models and to aggregate this data at the
geographic levels which will  be used in Regional  Plan Evaluation -- the
cities of the Region, the coastal  area, or for socio-economic areas.
     In the second operation, the  evaluation of Plan impacts, certain
data items are used to measure how well each of the Regional Development
Alternatives meets the Regional Goals and Objectives.  Criteria have
been developed based on the Regional  Goals.  Using data forecast by UDM
and the transportation models, the plan evaluation model will measure
the degree to which each Regional  Development Alternative achieves
regional goals and objectives, producing a "goal  achievement score" for
each alternative.
F.2  EMISSIONS MODELING
     The projection of stationary  source emissions on the basis of the
employment projections generated during the CPO modeling process has  been
outlined in Section 3 of this report.  Motor vehicle emissions may be
projected on the basis of the output of the traffic modeling sequence,
which results in estimates  of projected vehicle miles travelled (VMT).
                                  F-12

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                      The calculation of light and heavy duty vehicle exhaust emission
                  factors for carbon monoxide, hydrocarbons and oxides of nitrogen can be
                  expressed mathematically as:

                                             n+1
                                    6np  =   X    cip'diPn'min-sip
                                             i+n-12
                 where
                           e    =  emission factor in grams per vehicle mile for
                            -np
                                   calendar year n and pollutant p,
                            c.j   =  the 1975 federal test procedure (C-2) emission
                             p     rate pollutant p (grams/mile) for the 1th model
                                   year, at low mileage,

                            d.   =  r,he controlled vehicle pollutant p emission
                             P     deterioration factor for the ith model year at
                                   calendar year n,

                            m-   =  the weighted annual travel of the ith model year
                                   during calendar year n.  (The determination of
                                   this variable involves the use of the vehicle
                                   model year distribution),

                            s.   =  the weighted speed adjustment factor for exhaust
                             p     emission for pollutant p for the i;th_ model year
                                   vehicles.

                       In addition to exhaust emission factors, the calculation of hydro-
                 carbon gasoline motor vehicle emissions involves evaporative and crankcase
                 hydrocarbon emission rates.  Evaporation and crankcase emissions are
                 determined using:

                                             n+1
                                             v~^
                                      fn  =  >      h-  . m. .,
                                             / ^      i    i n
                                            i-n-12
                                                    F-13

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where,
       fn  =


       hi  '
       m
        in
the combined evaporative and crankcase hydro-
carbon emission factor for calendar year n,

the combined evaporative and crankcase emission
rate for the ith model year,

the weighted dimucil  travel of the i^h_ model year
during calendar year n.
              A light-duty vehicle is defined as any motor vehicle
              either designated primarily for transportation of
              property and rated at 6,000 pounds GVW (gross vehicle
              weight) or less, or designated primarily for trans-
              portation of persons and having a capacity of
              12 persons or less.  A heavy-duty vehicle is any
              vehicle which exceeds the above specifications.

              The deterioration factor (d) is the ratio of the
              pollutant p exhaust emission factor at x miles to
              the pollutant p exhaust emission factor at 4,000
              miles.  The factors used are obtained from the
              Environmental Protection Agency.

              The weighfed annual mileaae factor (m) is
              determined by the following formula:
                     m.
                      in
                 vi
                                    Di
                           i+n-12
where,
       Vi
       Di
=  fraction of total  vehicles in use with age
   (determined from vehicle registration data
   region in question) .

=  average miles driven  by a vehicle of age i
                                           i (in years)
                                           for the
                                  F-14

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          t  The weighted speed adjustment factor(s) enables the
             calculation of a region-wide emission factor that takes
             into account variation in average route speed.  This
             variable is calculated usina:
                          .
                          im
where,

          s.   =  the weighted speed adjustment factor for exhaust
                  emission of pollutant p for the ith_ model  year,
                  during calendar year m

          f-   =  the fraction of the total  annual  vehicle miles
           J      traveled at speed j during the calendar year m

          v.   =  the vehicular average speed correction factor for
           J      average speed j.


     Having computed the emission factors,  the final  step is  to multiply

the emission factor by the vehicle  miles traveled (VMT)  to derive total

motor vehicle emissions.  Table F-2 summarizes the  results of these  cal-

culations for San Diego.
                                   F-15

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Table F-2.  Light and Heavy Duty Vehicle Emissions
            (Tons/Day)
                              RHC         CO
1972
Fwy
City
LDV Total
Fwy
City
HDV Total
1977
Fwy
City
LDV Total
Fwy
City
HDV Total
1980
Fwy
City
LDV Total
Fwy
City
HDV Total
1985
Fwy
City
LDV total
Fwy
City
HDV Total

LDV
LDV

HDV
HDV


LDV
LDV

HDV
HDV


LDV
LDV

HDV
HDV


LDV
LDV

HDV
HDV


53.10
58.73
111.83
8.49
9.88
18.37

15.13
15.37
30.50
61.20
6.69
12.81

8.13
8.22
16.35
4.38
5.12
9.44

4.53
4.47
9.00
3.20
3.78
6.98

341.05
434.08
775.13
61.38
78.13
139.51

76.77
95.46
172.23
59.26
73.68
132.94

37.66
46.32
83.98
62.57
76.95
139.52

17.20
20.84
38.04
72.09
87.36
159.45
TOTAL                        15.98     197.49
                      F-16

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•                                              APPENDIX G
•                                     TECHNICAL ASSUMPTION MEETING
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                  COUNTY OF SAN DIEGO
                  INTER-DEPARTMENTAL CORRESPONDENCE
                                                         DAI r ,
                                                                iiohr
 TO:         Participants of the October 15,  1973 Meeting
            on Technical Assumption

 FROM:      Iforman E. Schell


SUBJECT:    Minutes of the Meeting
The purpose of this meeting was to establish a single set of technical
acnunrptions that vill be used to revise the 1972 emission inventory,
prepare projections and evaluate proposed control strategies.   To  this
end vc consider it successful.

Enclosed are the minutes of the meeting and a list of persons  attending.
Please note that motorcycles, heavy duty diesel and off-road vehicle
emissions were not discussed during the course of the meeting.   As a
result, ve plan to use the best available data to calculate  emissions
from these sources.
                                          Norman E.  Scheil
                                Deputy Air Pollution Control Officer
NES:RSo:ba
                                    G-l

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                PARTICIPANTS
Universal Oil Products
Jack Gochel (Consultant)
Roy Heimbrock
Dave Robson

ENVIRONMENTAL PROTECTION AGENCY
Ron Mueller

AIR RESOURCES BOARD
Harmon Wong-Woo
Terry Maguire
Howard Linnard

County Office of Environmental Management
Larry Taylor
Merrill Hayden
Michael Sloop

Comprehensive Planning Organization
Steve Sacks

City of San Diego Environmental Quality Department
James Gleason

San Diego Air Pollution Control District
Normaji Schell
John Farnsworth
Andy Segal
Mark Evetovich
R. J. Soramerville

Personal Interest
Dr. Steigerwald
                     G-2

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                  EASE YEAR ATID MAXIMUM OXIDAWT READING



The participants agreed to use 1972 as the base year and 0.32 as the
maximum oxidant reading.


                           PETROLEUM MARKETING

Evaporation Emission Factors:   It was observed that emission factors
published by EPA in AP-~^2 was of insufficient detail to reasonably
estimate evaporative amissions from jet and dieseJ fuels during storage
end handling.  In addition there was no information concerning residual
fuel oil.


It vas agreed to use a new interim EPA data set, provided by the APJ3
Representative, to calculate emissions fro:n petroleum storage jmd handling.
Ko new information on residual fuel oil vas obtained.


Reactivity of; Petroleum Vapors:  The principle point of discussion revolved
around whether (?i or C5 and above hydrocarbons should be considered reactive.


There was no resolution of this question.   As a result, it was agreed to
evaluate the emission inventory using both the 66% (AKB) and >O/? (EPA)
reactivity factors for petroleum vapors (gasoline, jet fuel, diesel. etc.).
It should be noted that these factors do not represent a range per se,
rather a choice as to the reactivity of C^ or C5 and above hydrocarbons.


The ARB and EPA Representatives agreed to discuss this matter further and
attempt to arrive at some mutually acceptable factor.
                             ORGANIC SOLVENTS



THC Emissions Factors:  The APCD used detailed THC emission factors obtained
"from the Los Angeles APCD because AP-^2 did not have comparable detail.


It was agreed that the Los Angeles APCD emission factors should be used.
                  APCD presented RHC emissions based upon the legal and
chemical definition of Rule 66.  In addition a calculation was done based
upon the composition of the solvents using Cp (ARB data) and above hydro-
carbons as reactive.


It was agreed that the calculation based upon the composition of the solvents
and assuming C5 and above hydrocarbons as reactive was the most representative
evaluation methodology and. should be used.
                                 AIRCRAFT
                APCD calculated aircraft emissions based upon local. LTD data
and using EPA emission factors as published in AP-^2.   There vas some dis-
cussion concerning the information on the number and kind of engines by
aircraft type.
                                    6-3

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It was agreed to contact TRW, an EPA contractor, for more information
concerning aircraft engine information.  However, since there were no
good information sources identified at the meeting, it was agreed to use
the existing data until new information was made available or obtained.

Reactivity Factors:  At the present time the ARB considers 50$ of aircraft
emissions to be reactive while EPA considers 90$ of "the emissions reactive.

There was no resolution of the question.  As a result, it was agreed to
evaluate the emission inventory using both the 50$ and 90$ reactivity factors.

Control Effectivenes_s:  The ARB has been assuming the EPA would control
aircraft emissions by 95$ by 1977.  However, EPA has maintained a 30%
reduction can be expected.

It was agreed to use the EPA 30$ control figure.


                   FUEL COMBUSTION (STATIONARY SOURCES)


Reactivity Factors:  The APCD assumed the emissions will be 100$ reactive.
The ensuing discussion revealed that some authorities consider these emissions
to exhibit low reactivity.  However, it was the consensus that hydrocarbons
resulting from any combustion process should be considered reactive.

It was the consensus of opinion, since this is a small source in terms of
the total inventory, that a conservative estimate should be made; hence,
the 100$ reactivity factor will continue to be used.

Turbine Emissions:   The APCD was unable to find eraission data on turbines.
The following discussion revealed that, apparently there is no other
information on this subject other than the RAND Corp. estimates.

The consensus was to use the RAND Corp. emission factors for turbine
operations.
                        LIGHT DUTY MOTOR VEHICLES


Vehicle Distribution:  There were three distributions discussed,  ARB.  EPA.,
and RAND Corp.  It was determined that the EPA distribution was a smoothed
ARB distribution while the RAND Corp.  had used national data.

It was agreed the EPA vehicle distribution as a function of model year
was the most appropriate.

Annual VMT Distribution:   There were three distributions discussed.  ARB.  EPA.
and RAHD Corp.  All of these distributions average out to around 7 to 8
thousand miles per vehicle annually.  Transportation authorities claim
the average should be around 10 thousand miles annually.

Since each of the mileage distributions share the same inadequacy, it was
decided to xise the RAND Corp. distributions since it was already imbedded
in the model.  However, it was agreed to proportion the results to reflect
the 10 thousand mile average annual mileage.


                                    G-4

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 Low Mileage  Emission Factors:  There were two  sets  of  cmr.nion  factors
 di'fJcrucsedT ]']PA find  KAUlT Corp.  The  consensus of  opinion vas  the EPA emission
 factors,  as  published in AP-^2, were too low for pre-66 vehicles.   The
 RA1ID Corp. has modified the  EPA data to reflect  extensive ARB surveillance
 data.   This  adjustment,  among  other things, raised  the emissions for pre-66
 vehicles.


 It  vas  agreed to use the RAND  Corp. emission factors since they most
 closely represent the opinion  of the participants.


 Degradation  Curve:   There vas  little discussion  on  this subject.


 It  vas  agreed to use the RAND  Corp. degradation  curve  vhich  is  based on
 ARB surveillance data.


 Fxhaust_Jjas_Reactivity:   The ARB considers exhaust  hydrocarbons to be 75$
 reactive.  EPA considers these emissions to be 77$  reactive.


 It  was  agreed to consider automotive exhaust hydrocarbons to be 75'^  reactive.


 Speed Correction Factors:  There was much discussion about the  appropriateness
 of  using the  AP-^42  speed correction factors.  These curves are  based upon
 limited data.


 It  vas  agreed that  speed correction factors would not  be used.   This will
 avoid presenting an  optimistic estimate based upon  limited data.  In addition,
 it  vas  observed that increased flow rates (speed) should be considered as
 a short term  effect  inasmuch as these high flow  rates  usually attract
 traffic vhich results  in an ultimate decrease in speed.


 ^5-65 Retrofit  Device  Effectiveness:  The following device effectiveness
 vas agreed upon.


          •  Pollutant             HC         CO        NOX

            Percent  Reduction     25         28        31


 66-_7_p_Retrofit  Device Effectiveness:  The following device effectiveness
 vas agreed upon.


            Pollutant             HC         CO        KOX

            Percent  Reduction     lU         10        50


 Mandatory Inspection - Maintenance:  This program is to begin initially in
 the  South Coast ACQR.  However, it was the groups opinion that this program
 is  an essential part of  any retrofit program.   There were two figures
 discussed, the  EPA effectivity of 30$ initially  declining to 0^  in one
year with an  average of 15$ effectivity.   The ARB evaluation indicates a
 10$  effectiveness.


 It was agreed to use the following Inspection-Maintenance effectiveness.


              Pollutant             HC            CO

              Percent Reduction     10$            5$
                                    G-5

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                         UOP CATALYTIC REACTOR
                                  (LDV)


Vehicles Eligible  for UOP Retrofit:  It was agreed that the following percent
of vehicles by model year would be retrofitable.

                 Model Year              $ of Vehicles Retrofitable
                   66-70                              60
                   71                                75
                   72-7^                              95

UOP Device Effectiveness:  The following device effectiveness was agreed upon.

        Pollutant          THC        RIIC        CO
        Percent Reduction   50$    '    70$       60$  '

NOTE:  The reactivity of exhaust emissions from a vehicle with a catalytic
       retrofit device is h6%.
                       HEAVY DUTY MOTOR VEHICLES
Population Distribution:  The ARE agreed to provide the total number of
vehicles and the population distribution.

Low t-iileage Emission Factors:  It was agreed to use EPA emission factors
as published in AP-42.

Emission Degradation Factors:  It was agreed to use the EPA degradation
factors as nublished in AP-te.

Vehicles Eligible for UOP Retrofit:  It was agreed that Q2$ of gasoline
powered HDMV will be under 26,000 pounds CVW and 75$ of these will be
retrofitable.

Device Effectiveness:  It was agreed the same effectiveness as used for
LDV would be appropriate.

Exhaust Gas Reactivity:  It was agreed the same reactivities as used for
LDV would be appropriate.
                        EMISSION GROWTH FACTORS
Mobile Sources:  There was a discussion concerning the use of statewide
trends as opposed to data generated specifically for the San Diego AQCR.

It was decided to use locally generated vehicle growth data to be supplied
by the County Office of Environmental Management.

St at ionary Sources:   It was decided to use locally generated per-capita
growth rates where appropriate.  Data is to be provided by the County
Office of Environmental Management.


                                    G-6

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                                        STRATEGIES TO BE EVALUATED
                1.  The most recent EPA control strategy.
•              2.  The most recent AKB control strategy using 30% aircraft control,
—              3-  VMT reduction projects as proposed by  CPO.
™              k.  Maximal retrofit.   ARB and UOP devices.
B              5.  CPO proposed VMT reducing projects and maximal retrofit.


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                     APPENDIX H - PLUME COMPUTATIONS


     To estimate the maximum probable effect of mineral  industry

operations in the Mission Valley area on the particulate readings at

the El Cajon monitoring station, a simple Gaussian continuous point

source plume dispersion model was utilized.   This model, for a source

at ground level, is described by the equation:


                             Q,
                   x  =  	=L-=—
where:
       X  = ground level  concentration of material  (gm/m )  along
            the centerline of the plume

       Q1 = source strength (gm/sec)

    a  a  = standard deviation (m) of material  concentration within
     y   z   the plume in the y- and z- directions respectively,
            as a function of downwind distance.

        u = average wind speed (m/sec)
     The selection of appropriate factors for the computation of max-

imum expected concentrations was based on Figure H-l ,  which is a display

of point source emissions of particulate matter in San Diego.  Each

digit displayed represents an emission level  in a 5,000 foot square

grid which is identified in the accompanying  legend.   This  display

is the product of a software package developed by TRW  for  the San Diego

County Air Pollution Control District.  The relationship of the grid to

geographical  features of San Diego is shown in Figure  H-2.   In addition,

the location  of the monitoring station at El  Cajon is  indicated by

arrows along  the perimeter of the grid in Figure H-l.
                                   H-l

-------
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-------
     On the basis of this  display,  the most  significant concentration
of point source emissions  occurs  in the  Mission Valley area  (denoted by
a 7 and a 9 on the emissions  grid).   If  it is  assumed that the plume
generated by these sources passes directly over the  El Cajon site, the
appropriate input values are  as follows:
       Qj = 100 grams/second  (9.5 tons/day)
        u = 2 meters/second
          downwind distance = 19  km (12  miles)
       o-  = 150 meters
        J
       °z = 54 meters
     The resulting predicted  maximum concentration attributable to these
                              3
sources at El Cajon is 21  |ug/M .
     To estimate the maximum  probable effect of the  freeways on the
particulate readings at the El  Cajon monitoring station, a simple
continuous line source dispersion model  was  utilized.  This model, for an
infinite line source at the ground,  is given by:
                     •V*
ozu
                                            3
where X   =  concentration of  material  (gm/m ) at ground level
      Cu  =  source emissions  rate  (gm/sec/m)
      o_  =  standard derivation  of material concentration within
             the plume in the  z  - direction  (m), as a  function of
             downwind distance
       u  =  average wind speed  (m/sec)
                                   H-4

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     Estimated participate emissions from freeway traffic in San Diego

are displayed in Figure H-3.   Again, the position of the El  Cajon

monitoring station with regard to the freeways is indicated  by arrows

at the perimeter of the grid.   Selecting the grid denoted by a 4 as the

most probable source, the appropriate input data is  as follows:
        Q2  =  .003 gm/sec/meter (assuming 100,000 vehicles/day and
               a 0.43 gm/mile particulate emission factor)

        u   =  2 m/sec

        downwind distance = 800 m (1/2 mile)

        a   =  28 meters
     The resulting predicted maximum concentration attributable to
                      3
this source is 40
                                  H-5

-------
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                               APPENDIX  I

                              STUDY CONTACTS


     This program was initiated in San Diego on April  16,  1974 at the

Comprehensive Planning Organization (CPO)  headquarters.   The agencies

represented were EPA, TRW, Inc.,  Deleuw,  Gather & Company,  the California

Air Resources Board, the San Diego Air Pullution Control  District,  and the

San Diego County Comprehensive Planning Organization.   Several sub-

sequent meetings were held in San Diego and at Durham, North Carolina to

discuss progress of the report.

     The bulk of the data used in this study came from a  limited number of

sources.  Reports used in the report are  listed in the reference section

of chapters.  In addition, some private conversations  are cited where

appropriate.  These and other contacts are  listed below.
Air Pollution Control  District of San Diego County
1600 Pacific Highway
San Diego, California 92101   (714) 236-3826
  Mr.  Norm Schell, Deputy Air Pollution Control  Officer
  Mr.  Rich Sommerville, Assistant to Mr.  Norm Schell
  Mr.  William Louthen, Air Pollution Engineer
  fir.  Michael Foley, Air Pollution Data Section



California Department of Transportation,  alias CalTrans or Cal  Dot.
2829 San Juan Street
San Diego, California 92110
     Mr. Carl West, Assistant Disstrict Urban Planning Engineer in
     charge of CalTrans traffic modeling  studies,  District 11,  San
     Diego (714) 294-5068

     Mr. Chad Lambirth, Transportation Planning  Section, District 11,
     San Diego, in charge of projected traffic volumes data files,
     (714) 294-5116


Comprehensive Planning Organization (CPO)
1200 Third Avenue, Suite 524
San Diego, California 92101
     Mr. Arthur Letter, Intergovernmental  Coordinator  (714)  233-5211
     Mr. Lee Johnston, Senior Regional  Planner
     Mr. Bill Bamburger, in  charge of industrial employment growth projections
     Mr. Ronald J. Hertel, Associate Transportation  Planner
     Mr. Stuart Shaffer, Assistant Director of Land  Use and Public Facilities
        Planning
     fir. Michael Aulick
                                    1-1

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STUDY CONTACTS (continued)
 San  Diego  Environmental Quality Department
262 C Street, EQD 7-A    	*	K	
San Diego, California 92101
     Ms. Cordelia Ridenour, Assistant Director
Air Resources Board
1709 Eleventh Street
Sacramento, California 95814
     Mr. Daniel  Lieberman
State Department of Land Use Programs for San Diego County
1600 Pacific Highway, Mail Station 201
San Diego, California
     Mr. Herman Rosenthal, Director
San Diego Unified Port District
3165 Pacific Highway
San Diego, California 92112
     Mr. Thomas E. Firle, Environmental  Management Coordinator
San Diego Chamber of Commerce
223 "A" Street, Suite 300
San Diego, California
     Mr. Lee Grissom
San Diego Gas and Electric Company
     Mr. Jon Hardway, Environmental Representative (714) 232-4252, X1795


Planning and Land-Use Committee
State Capitol
Sacramento, California 95814
     Mr. Emilio Varanini, Staff Consultant
Planning and Conservation League
1225 8th Street^
Sacramento, California
     Ms. Melanie Blade
Assembly Select Committee On Open Space Lands
State Capitol
Sacramento, California 95814
     Mr. Robert Odland, Consultant
                                   1-2

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                    STUDY CONTACTS (continued)
                    Office  of Assemblyman  Knox
                    State Capitol
                    Sacramento,  California
                        Mr. Tom Willoughby
                    Chicago  Law  School
                        Ms. Alison Dunham,  Professor of Law
                    Region  IX, Environmental Protection Agency
                    100  California Street
                    San  Francisco, California
                        Ms. Linda Goldman
                        Mr. Andy Mank
                   California State Attorney General's Office
                   San Diego, California
                        Mr. Foster Knight
                   Local Agency Formation Commission
                   San Diego, California (714) 236-2015
                        Mr. Peter Detwiller, Assistant Executive Officer
                   Department of Finance
                   1025 D. Street, Room 498
                   Sacramento, California 95814
                        Ms. Pauline P. Sweezy, Population Research Unit
I                 Regional  Water Quality Board (San Diego)
*                 6154 Mission Gorge Road,  Suite 205
                   San Diego,  California  92120
                        Mr.  Arthur Coe
                   State Department of Water Resources
                   849 South Broadway, Room 1201
                   Los Angeles,  California
                        Mr.  Jack Lyman,  Public  Information Officer
                   Southern  California  Metropolitan Water District
                   1111  West Sunset Boulevard
                   Los  Angeles,  California  90054
                        Mr.  Donald  Brooks
                                                     1-3

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STUDY CONTACTS (continued)
San Diego Coast Regional  Commission
6154 Mission Gorge Road,  Suite 220
San Diego, California 92120
     Mr. Daniel Gorfain,  Director
Solid Haste Management Task Force, County of San Diego
8995 Complex Drive
San Diego, California 92123
     Mr. Eric Elliot, Research Analyst
State Water Resources Control Board
1416 9th Street, Room 1015
Sacramento, California 95814
     Mr. Raymond Walsh
San Diego County Hater Authority
2750 4th Avenue
San Diego, California 92103
     Mr. Linden Burzell, General Manager
                                   1-4

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                                              APPENDIX J
                            •Letter from Frank Covington  (EPA/Region  IX)
                            to the Ad Hoc San Diego Air Quality Task  Force
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                                             7 JW 1914-
Hr. Richard G. Rypinski, Chairman
San -Diego Air Quality Task Force
Security Pacific Plaza, Suite 524
1200 Third Avenue
San Diego, CA  92101                          %

Dear Mr. Rypinski:

    On May 6, 1974, I met with the San Diego Air Quality Task
Torce to outline nreli/ninary EPA thinking on institutional
^rranaetr.onts for Indirect Source Review, Parking Facility
Review and Parkinq Management Plans.  As we stressed on May  6,
T~PA's policv is to c'elerrate these land use related functions
to local government whenever possible,

    'Te look to the members of the San Diego Air Quality Task
Force to develop a concensus among the area's local qovern-
rents on how these functions should be delegated without
further fracmentina local decision-inaking on air quality
related land use natters.  We anticipate delaying delegations
until the policy group advises us on the following:

    (1)  Would all the cities and the County participate in
         the plan development and request delegation?

    (2)  At what level of government will the Parking
         Management Plans be developed and the Indirect
         Source and Parking Facility Reviews be conducted?
         '.,"ho will resolve inter-jurisdictional conflicts
         amonrr Parking Management Plans within the air
         basin?  T7hich agency(s) would be responsible for
         taking the lead in insuring that these thre« functions
         are carried! out?
                            J-l

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   ^For your_^foraapSn, we have enclosed ,a:__^,.^_-._	
Region IX's current '^thinking on one approach to^;3japi«osenting
these functionsii^rThis'proposal, is merely, a 3aore*;rafined;,r;:.
version" of^urjp^s^ntation to you on May 6.' .^e'^ii^id^^df1
coarse," be^ateriested in knowing of any changes  In thisll^^
proposal that  the Task Force would advise in 'the San :Diego
air basin.  Upon receiving an early response from  the  ?ask
Force, EPA Region-XX will assist to the extent possible in
carrying out these functions.                 o

                               Sincerely,
                               Prank M. Covington,  Director
                               Air and Water Programs

Enclosure          _    _ ,   .   ' .-._.,:-  .;".- -^^-

cc:  Members of  the  Task  Force Policy Committee
       Mayor Wilson                ,          ."-"".:.
       Supervisor1Conde
       Mayor^Richardson "  ~ -                 .  r
       Mr. -Lawrence  Cox. :     ;   -       ,   :_/-..;:,._.
     -'•' Dr. Brage:Golding  ;.-". . 7= •--.-:  •''•. ".\    '~ ~'"--: ^ '
                            J-2

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•                                             APPENDIX K
•                       1. Opinion of the State of California Attorney General
                           concerning APCD indirect source review authority,  (p K-1,15)
I
                         2. Opinion of the State of California Fourth District
I                         Court of Appeal, Western Oil and Gas Association, et al , v.
                           Orange County Air Pollution Control District, et al.
|                          (p  K-16,27)
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           vi I L'  ' YOUNGIK                    STATE1 OH CALIFORNIA

           Al 1 ( 'I'M *! C f Nl RAL
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                                    (
•                                   if jiartutfttt itf }
                                     OFK1CK OI Tilt; ATTOKNKY
                                         5SS CAPITOL MALL SUITE 55O

                                           SACRAMENTO  95814
 |                                      December 17, 1973



 I


 |                        Honorable John A. Maga
                          Executive Officer
 _                        Air  Resources Board
 •                        1025 P  Street
 *                        Sacramento,  California 95814

 fl                        Dear Sir:

                          Enclosed is  our Opinion No. SO  73/43 issued

 |                        to you  in accordance with your  request.
                                                 TT  X" j f  1
•                                               Ve^y  (,ruly,. v^ours ,


                                                 |EVELLEVJ/r';OUNGEi|
                                                 Attomr',/ Cjtp^fal
                                                       t-a tf-
                                                       f'A
                          IEJY:barn
                          Enclosure


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            OFFICE OF THE ATTORNEY GENERAL
                 State, of California

                  EVELLE J. YOUNGER
                  Attorney  General
         OPINION

            of

    EVELLE J0 YOUNGER
    Attorney  General
    Eo ROBERT WRIGHT
 Deputy Attorney General
No. SO 73/43

DECEMBER 18, 1973
          The Honorable John A. Maga,
State Air Resources
following question:
"Rnnrd
 Executive Officer,
               on the
has requested, an opinion
          Are California's county, regional,  and bay area
air pollution control districts authorized to regulate com-
plex sources of air pollution for the purpose of denying
authority to construct such sources where the emissions
resulting from vehicular traffic, and other activities
indirectly generated by such sources, would prevent the
attainment or maintenance of a federal or state air quality
standard?

          The conclusion is:

          California's air pollution control  districts
presently are authorized to regulate complex  sources of air
pollution for the purpose of denying authority to construct
such sources where the emissions indirectly generated by
such sources would prevent the attainment or  maintenance of
federal or state air quality standards.
                        K-2

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                       ANALYSIS

          Complex sources are  facilities such as airports,
highways, shopping centers, and sports complexes which may
not themselves create emissions but may affect air quality
indirectly by means of the secondary activities  (such as
vehicular traffic) associated with them._V

          The analysis herein will first focus on the Federal
Clean Air Act of 1970.  Then, because there are three dif-
ferent types of agencies  (county, regional, and bay area) in
California with similar statutory provisions vesting authority
in them to regulate activities causing air pollution, the
authority of each agency  to regulate complex sources in order
to attain federal and state air quality standards will be
considered in turn.

          Major attention will be given to the county air
pollution control districts.  Generally, conclusions regarding
the authority of the county air pollution control districts
to regulate complex sources are applicable also to the Lay
Area Air Pollution Control District and regional districts
although at this time there are no regional air pollution
control districts in existence.  The distinctions between
the agencies with respect to regulation of complex source=
are primarily in terms of geographical boundaries ratheJL
than in terms of the extent of regulatory authority.

          It should be kept in mind for the sake of clarity
that the air pollution control districts have explicit statu-
tory authority recognized by the courts to regulate direct
stationary sources of emissions, such as factories with
smokestacks.  Orange County Air Pollution^ Control Dist. v,
Public Utilities Com., 4""Ca 1.3TP9~537"9T3 (197TTAnalysis
is necessary only because the California air pollution con-
trol laws nowhere state in so many words that the air pol-
lution control districts may regulate complex sources.
          Federal Requirements^ Speci fying the Means_by_
          Which Federal Air Quality Staridarcls Will Be
          Attained and_Ma~in_taine_d~"

          The question of whether California's air pollution
control districts have the authority to regulate compJex
     1.  See 38 Fed. Reg. 6279-80 (liar. 8, 1973) and 38
Fed. Reg. 15836-37  (App. 0) (June 18, 1973).
                           K-3                     SO 73 M 3

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sources for the purpose of denying authority to construct
such sources must. begin with an examination of the Federal.
Clean Air Act  (of 1970) (42 U.S.C. §  1857 ct soq.).  Under
the Federal Clean Air Act, the state  is responsible  for
submitting an  implementation plan to  specify the means by
which the national ambient air quality standards promulgated
by the Administrator of the Environmental Protection Agency
(hereinafter EPA) will be achieved and maintained throughout
each air quality region within the state.  42 U.S.C. § 1857c-2,
California's original implementation  plan was submitted by
the State Air  Resources Board on January 30, 1972.

          The  objectives of the Federal Clean Air Act are
"to protect and enhance the quality of the Nation's air
resources so as to promote the public health and welfare and
the productive capacity of its population; . . ."  42 U.S.C.
§ 1857(b) (1) .  The prevention of air pollution at its source
remains the primary responsibility of state and local govern-
ment.  42 U.S.C. § 1857 (a) (3).

          Under the Federal Clean Air Act, the EPA Admini-
strator is required to promulgate national ambient air
quality standards.  42 U.S.C. § l857c-4.  Each state must:
then submit a  plan within nine months after the promulgation
of the federal standards for implementation of the standards
within the state.  42 U.S.C. § 1857c-5(a) (1).  The  plan
must provide for the attainment of federal standards as
expeditiously  as practicable.  42 U.S.C. § 1857c-5(a) (2)  (A).
The plan must  include "emission limitations . . . and such
other measures as may be necessary to insure attainment and
maintenance oi; . . . [the federal standards]  j-jcjludirig but_
not_ limited to., land u se and t ra n s port at ion con_t_rpfg_.   H/*
U.S.C. § 18~57c-5TaT~(2) (B) . "TEmphasis aciHedT)

          In _Naturalj_Res_ources Defense Council., ljnc_. v.
E n v i r pnm e n t a 1  P r o t e c t i on Agency, 575 F . 2d~9"C"8~ (D . C . Cir .
     ~I the court ordVrea"!

     "That [state implementation! plan must satisfy each
     and every requirement of Sections 110 (a) (2) (A)
     through (H) if it is to be approved by the Admini-
     strator.  In particular, it must provide for the
     attainment of the primary standard as expeditiously
     as -practicable bin:: in no c a s e later than May 3_1,
     1975, and it must include 'emission limitations,
     schedules, and timetables for compliance with such
     limitations, and such other measures as may be
     necessary to insure attainment and maintenance of
     such primary or secondary standard, including, but
     not limited to, land-uc-e and transportation controls.1"
     475 F.2d  968, 970-71.  (Emphasis by the court.)


                           K-4                     SO 73/43

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                         The  current  EPA  position  appears  to be  a reason
              Iablc  interpretation  of congressional  intent.   Congress
              expressly  provided for emission  limitations in state  i
           Prior  to  the  decision  in  Natura 1  Ror.ources  Do fenc;o.
Council,_Inc_.  v.  En v i r o n m e n t aI P r o t G c 1; •? o n A >; e 11 c y , •'iilPJ'a, the
E"P"A~7CdiiT 1 nls t r a t o r had r e q u fr cliPe'acTi state ImpTeinentnti on
plan  to set forth a "control  strategy"  which would  provide
for the necessary emission reductions  in order to attain the
applicable  federal  standards.  40 C.F.R. §  51.12  (1972).
"Control  strategy"  is defined as the combination of measures
designed  to achieve the requirements set by national  standards
including any  land-use  or transportation control measures
not specifically  set  forth.  40  C.F.R.  § 51.1(n)  (9)  (1972).
The EPA Administrator had required  each implementation  plan
to show that the  state  had legal authority  to  prevent the
construction of a stationary source if  emissions from the
source would prevent  the attainment or  maintenance  of a
federal standard.   40 C.F.R. § 51.11(a) (4) (1972).   See also
40 C.F.R.  § 51.18 (1972).

          The  court in  Natura 1 Resources^Defense J3oun_cj.] ,
In c^. v. Environ mental Prp_te_cJ:J-^on Agency , s ivpra, ordered the
EPA AdrninTstrator to~~9Tsapprove  state  implementation  plans
which do  not provide  the measures necessary to maintain
federal standards.  The EPA Administrator thereafter  noted
that maintenance  of standards had been  partially insured by
40 C.F.R. § 51.18 which states that each state plan must pro-
vide authority to review and if  necessary prevent the con-
struction of stationary sources  if  emissions from such sources
will interfere with the attainment  or maintenance of  national
standards.  38 Fed. Reg. 6279 (Mar. 8,  1973).  The EPA
Administrator  said  that such measures,  by themselves,  are
not adequate to insure  the maintenance  of the national stan-
dards, particularly with respect to pollutants emitted by
motor vehicles and  emission sources associated with general
urban and commercial development.   The  EPA  Administrator
continued:

     "Accordingly,  in order to comply with  the court
     order, it has  been determined  that all State plans
     must be disapproved to the  extent  that they do not
     contain provisions which will  permit the review,
     and provide  the authority to prevent,  the construc-
     tion, modification, or operation of complex sources
     at a location  where emissions  associated with such
     source would result in violation of a  national
     standard or  the State's control strategy."  38 Fed.
     Reg.  6279 (Mar. 8,  1973).
I

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V* L' J- V_- J_i*l_\^i»U-'J->_.k- \~4- W O- W 11 W A, V- V-* 1 i f—j ±- V— k-> I J X. V-1 I t *.* Jk -LllL-V^Jl^-*  \J \^J 1 I I' i_ ^— . J O
expressly provided for emission limitations in state imple-
mentation plans which pertain to direct sources of emissions
In going on to provide that the plans are to contain such
                                                   SO  73/43

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other measures, including land-use and transportation con-
trols, as are necessary to insure attainment and maintenance
of federal standards, Congress used broad language indicating
an intention that indirect as well as direct sources must be
regulated, where necessary.

          The EPA Administrator promulgated amendments to the
federal regulations which require an implementation plan to
show that the state has legal authority to prevent the con-
struction of complex sources in addition to "traditional
stationary sources", where such complex sources would inter-
fere with the attainment or maintenance of the national
standards.  40 C.F.R. §§ 51.11(a) (4), 51.18; 38 Fed. Reg.
15836 (June 18, 1973) .

                           II

          The
          Pollut
Legislative Authority of the County Air
ution Control"' Dfstr icts to Regulate
          Comple?T~S_ou?cJRS~ in Order to Attain or Ma in ta in
          Fe "de'r a 1 and S~tate Ai"r~QuaTTEy~STan?a_r_ds_

          A.  Statutory Language

          The first issue to be considered is whether the
county air pollution control districts have the authority to
regulate for the purpose of preventing construction of com-
plex sources as required by the nex<7 federal regulations.

          The County Air Pollution Control Law (California
Health and Safety Code section 24198 et seq.)2/ was enacted
in 1947 and was the first detailed state legislation dealing
with air pollution.  The purposes of the County Air Pollu-
tion Control Law include creating county air pollution
control districts with regulatory power to reduce air con-
taminants in order to safeguard life, health, property, and
public welfare, and make possible the comfortable enjoyment
of life and property.  § 24199 subd. (d).  The Legislature
also declared that the people of the state have a primary
interest in freedom of the air from air contaminants.
§ 24198.

          Section 24260 of the County Air Pollution Control
Lav; as originally enacted gave county air pollution control
boards authority to make and enforce all needful orders,
rules and regulations necessary or proper to accomplish the
purposes of the law, the administration of the district,
     2.  Hereinafter all statutory citations are to sections
of the Health and Safety Code unless otherwise indicated.
                           K-6                     SO 73/43

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and  to  perform all other acts necessary or proper to accom-
plish the  purposes of  the chapter.   (Stats. 1947, ch. 632,
§  1, p.  1645.)

           In  1967 the  Legislature enacted the Mulford-Carrell
Air  Resources Act (§ 39000 et seq.), which created the State
Air  Resources Board  (hereinafter referred to as board) and
divided  responsibility for the regulation of air quality be-
tween the  board and  county and regional boards.  After the
adoption of the Mulford-Carrell Act, section 24260 was
amended  to not only  give the county air pollution control
districts  authority  to make and enforce needful orders, rules,
and  regulations necessary or proper for accomplishment of the.
purposes of the County Air Pollution Control Law, but also
those necessary or proper for accomplishing all provisions
of part  1  of  the Mulford-Carrell Air Resources Act relating
to nonvehicular sources of air contaminants.  As presently
worded,  section 24260  provides as follows:

     "The  air pollution control board of an air pollution
     control  district may make and enforce all needful
     orders,  rules,   and regulations necessary or proper
     for the administration of the district and to
     accomplish the  purposes of this chapter and all
     provisions of Part: 1 (commencing with section 39000)
     of Division 26  relating to nonvehicular sources of
     air contaminants, and may perform all other acts
     necessary or proper to accomplish the purposes
     thereof. '  Stats. 1947, ch. 632; amended Stats. 1972,
     ch. 577.

Significant provisions of part 1 of the Mulford-Carrell Air
Resources Act are summarized or quoted below.

          The purposes of the Mulford-Carrell Air Resources
Act  include:  (a) providing a means for an intensive coordin-
ated state, regional, and local effort to combat the problems
of air pollution within the various air basins in the state
by dividing the state into basins; (b)  providing the state
authority  to establish ambient air quality standards that
could vary from basin to basin as well as statewide motor
emission standards;  and (c)  providing for control of emis-
sions from nonvehicular sources.  § 39011.  Local and
regional authorities  are given the primary responsibility
for the control of air pollution except for the emissions
from motor vehicles,  and these authorities are to control
emissions from nonvehicular sources.   § 39012.   The Legis-
lature further declared that the state  authority shall
undertake enforcement activities only after it has  deter-
mined that the local  regional authorities have failed to
meet their responsibilities.   §  39012.   The state board  is
empowered,  inter alia,  to adopt  standards of ambient air


                           K-7                     SO

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quality for each basin.  § 39051  subd.  (b) .  And  under
certain limited conditions  the state board  may adopt, emis-
sion standards for all nonvehicular air  pollution  source's
for application for each basin.   § 39051 subd.  (d).

          Section 39052  subdivision  (f)  of  the Mulford-
Carrell Air Resources Act empowers and directs the  board
to "[r]eview rules and regulations of  local or regional
authorities ... to assure that  reasonable provision  is
made to control emissions from nonvehicular sources and  to
achieve the_ air quaJLij:^  standard^ established by_ the boarcT."
(Emphasis adcfed.)  Under~a~T9TO  amendment to "section T9TF5~2
subdivision (f), if the  board "finds  .  .  .  that  any rule or
regulation of a local or regional authority submitted  to it
will not achieve applicable air  quality  standards,  it  may
repeal such rule or regulation and promulgate a  rule or
regulation which it finds would  achieve  such standards",
and the board's rule or  regulation shall then be enforced
by the local or regional authority.

          In 1970 the Legislature also added provisions  to
the Mulford-Carrell Air  Resources Act requiring  the establish-
ment of a Basinwide Air  Pollution Control Coordinating Council
in each air basin in which  there  is not  a single regional
district with boundaries coterminous with those  of  the air
basin (§§ 39270-39272),  and directed that each basinwide
regional district and each  such  Basinwide Air Pollution  Con-
trol Coordinating Council shall  establish and submit to  the
board a coordinated basinwide air pollution control plan.
The plan "shall include  emission  standards  and enforcement
procedures which will within a reasonable time achieve or_
exceed the air qual^ity_ standards  establ_ishe_d bv  the boand
for that a^iF^ajinT71^mpn¥sTs" a^HecTT)  if~3'9~2~73." Th7e
plan was "to be submitted to the  board by no later  than
January 1, 1972, and provision is made for  review  and
revision of the plan by  the basinwide regional district  or
council.  § 39273.  The  1970 amendments  further  provide:

     "if the board finds that any original  or revised
     coordinated basinwide air pollution control plan
     . . . will not achieve the_  air quality standards
     e staV^lT¥Ke'd'~Fo'r~j:1hatT"Fasin ,  or iT no timely
     original or revised plan has been submitted,  the
     board shall establish a coordinated basinwide  air
     pollution control plan WJTJ.Ch would_  ach_ic_ve_  th_e_
     standards in e^f_fe_c^ f_pr jthjat basin.  Such plan
     sTKaTl inc'lud'c emission stand"arUs~~a"nd rules  and
     regulations, which  shall be  enforced by the basin-
     wide regional air pollution  control district  or,
     if no basinwide regional district is functioning
     in that basin by all local  and regional authorities
                            K-8                     SO  73/43

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     within  that  hasin.   If the  b'oard finds that reason-
     able action  to  enforce that plan has not been taken,
     .  .  . the board may  take  any appropriate legal action
     to enforce any  such  plan,  including the emission
     standards and enforcement  procedures therein .  . .   ."
     (Emphasis added.)  §  39274.

The 1970 amendments  also  provide that:

     "On or  before January 1,  1972,  each county district
     all or  part  of  which  lies within an air basin shall
     submit  to the board a program to implement the  air
     pollution control 'plan of  the basin within that
     county  district.   If  the board finds that the pro-
     gram will not achieve the  aiir quality standards
     established,  for th_e~"basin_>  or if no p r FgranTlL s  sub-
     mitted  ~.  ".  . ,  the b bar d may exercise the powers
     of the  county air  pollution control district within
     the basin.11  (Emphasis added.)   §  39275.

          Despite the above legislation and similar  legis-
lation in other states, it was noted after the enactment of
the Federal  Clean Air Act  that  it was doubtful whether any
state could  meet  such federal requirements as  provision  for
land-use and transportation controls without enacting new
legislation.  T. A.  Trumbull, Federal Control  of Stationary
Source Air Pollution, 2 Ecology  Law Quarterly      ~~
        ~
          In  1972 the Legislature  added section 39276 to
part 1 of the Mulford-Carrell Air  Resources  Act which pro
vides that :

          "The board and  the air pollution control
     districts shall endeavor to attain not  only the
     ambient air quality  standards  e s t abTI's'h'e cPUy •' the
     board pursuant to sub d i vTs i on  (b_)  of Sect ion
     T9 (J5T , b u t al s o the  ambient a"ir  Quality_ s_tandard_s_
     established^ _by_ the E n y i r onme n t a 1 Protection Agency_
     pursuant to Section  1857c -4 of Title 4~2~ 6T~th~e
     United States Code.  The board may order,  pursuant
     to Section 39273, review of a  coordinated  basin-
     wide air pollution control plan  for rcvisioj^ t_o_
     attain fede^ral_ ambien^ air quality s t a'n Jalrd s in_
     tjio ba's in , a_s_ pa^rt oT~the state  ini^lc_mq n t 
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     by the board pursuant to Section 39274."
     (Emphasis added.)

          In interpreting section 39276, it is reasonable
to assume that the Legislature would not direct the air
pollution control districts and the board to endeavor to
attain federal ambient air quality standards if their
authority to do so were lacking.

          Thus the Mulford-Carrell Air Resources Act authorizes
establishment of state ambient air quality standards by the
board  (§ 39052), directs in substance the districts to achieve
applicable air quality standards (see §§ 39052 subd. (b),
39273,  39274, and 39275),  directs the board and the districts
to endeavor to attain both the ambient air quality standards
established by the board and also the federal ambient air
quality standards established by the Environmental Protection
Agency, and authorizes revision of coordinated basinwide
plans to attain federal ambient air quality standards,  as
part of the state implementation plan.  § 39276.  The County
Air Pollution Control Law authorizes the districts to make
and enforce rules and regulations necessary or proper to
accomplish the purposes of the County Air Pollution Control
Law and all provisions of part 1 of the Mulford-Carrell Air
Resources Act relating to nonvehicular sources of air con-
taminants.  § 24260; see also § 24262.

          Accordingly, we conclude that air pollution control-
districts have broad authority to adopt rules and regulations
necessary to implement the state and federal ambient air
quality standards, including regulation of complex sources
where such regulation is necessary to attain state or federal
air quality standards.  The extent of such regulatory authority
would logically include the ability to prohibit the construc-
tion of complex sources.

          B.  Legislative History

          Section 39276 was added to the Health and Safety
Code by A.B. 580, Statutes 1972, chapter 949, which con-
tained an urgency clause,  and became effective August 16,
1972.  The legislative history of section 39276 supports
the conclusion that the county air pollution districts  are
authorized to regulate complex sources.  The facts con-
stituting the urgency are:

          "In order that the State Air Resources Board
     and the air pollution control districts may exercise
     the add!ti'_onal authority that would be conferred on
     them" by~~"Ehis act at the earliest possible time for
     the control of air pollution within the state, it


                           K-10                    SO 73/43

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                    is necessary that this act take effect immediately."
                    (Emphasis added.)

                         Prior to amendment of the urgency clause on June
               16, 1972, the facts constituting the urgency had been stated
               in A.B. 580 as follows:

                         "In order for this act to become effective
                    in time so that the Environmental Protection
                    Agency may consider the provisions thereof when
                    it completes its review in May 1972 of California's
                    implementation plan to attain required federal
                    ambient air quality standards within the state,
                    it is necessary that this act take effect iirjnedi-
                    ately."  A.B. 580 (Reg. Sess., Feb. 28, 1972, last
                    amended June 16, 1972).

                         A.B. 580 was originally intended to be enacted in
               time for EPA review of the state implementation plan.  The
               circumstances indicate that the purpose of A.B. 580 was to
               clarify and strengthen the authority of the state board and
               the districts to fulfill the state's responsibility under
               the Federal Clean Air Act and to obtain EPA approval of the.
               state implementation plan.2.7
                    3.  The Committee Bill Analysis of A.B. 580 as amended
               April 4, 1972, states that:

                         "California's implementation plan is being re-
                    viewed in May, 1972, by the EPA; changes in the
                    California code have been recommended to meet the
                    federal guidelines requiring necessary authority
                    to be held by the ARE [board]  and counties and to
                    meet federal guidelines for ambient air quality
                    standards.  The EPA and Attorney General have
                    expressed doubts as to whether this authority is
                    adequately expressed in our existing laws."  Bill
                    Analysis, A.B. 580, Assembly Committee on Environ-
                    mental Quality (April 17, 1972).

•                        Likewise, the Legislative Analyst said with respect
               to A.B. 580 that!
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to A.B. 580 that:

          "Present state law requires that attainment
     of Ambient Air Quality Standards through the estab-
     lishment of coordinated basinwide air pollution
     control plans.  These plans to satisfy state
     standards already have been developed, modified,
     and approved by the State Air Resources Board (ARB)
                                         K-ll                     SO 73/43

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          Broa'd delegations of authority to administrative
agencies charged with the responsibility of dealing with
complex economic, social, or technologic problems, are not
uncommon and have been upheld by the courts.  See Holloway
v- Puree11, 35 Cal.2d 220, 230-32 (1950), cert, denied 340
U.S. 883;"Jersey Maid Milk Products Co. v. Brock, 13 Cal.2d
620, 658 (TSffiTTiButterworth v. B^yH7~l2 CaT72"3~140, 148-49
(1938) ; Lloyd A. Fry RooRng Co. v. State Department of
Health Air Pollution Variance Board, 499 P.2d fl76 (Colo.
1972) , upholding ~a~~broad delegation of authority to a state
air pollution control agency.

          The legislative policy and purpose sections of
the Federal Clean Air Act and the state air pollution con-
trol laws provide adequate legislative guidance for admini-
strative action.

          To conclude that the districts have the authority
to regulate complex sources where necessary to achieve or
maintain federal air quality standards, is to interpret
such sections as 39276 and 24260 consistently with the policy
and operative sections of the state acts (County Air Pollu-
tion Control Law and Mulford-Carrell Air Resources Act) and
the policy and operative sections of the Federal Clean Air
Act.

          C.  Construction of Environmental Acts
          Legislation concerning environmental protection
is given broad construction to accomplish the objectives of
such enactments.  Thus, in Friends of Mammoth v. Board of
Supervisors,  8 Cal.3d 247 (T9T27^tRe Supreme Court at page
254 statedT

          "More recently, a circuit court discussed
     statutes attesting  'to the commitment of the
     Footnote 3. continued;

     and submitted to the Environmental Protection
     Agency (EPA).  The federal Clean Air Amendments
     of 1970 added newer and more stringent controls
     which the states are required to possess.

          "This bill would add three new sections to the
     Health and S~aTe"ty Code to clarify and strengthen
     the ARB's authority as follows: . . . ."  Analysis
     of A.B. 580 as amended in Senate June 16, 1972,
     Legislative Analyst  (June 26, 1972).
                           K-12                    SO 73/43

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      Government  to control,  at  long last,  the destruc-
      tive  engine of material "progress1".   The duty of
      the judiciary,  it  held, is  to assure  that important
      environment purposes,  heralded in legislative halls,
      are not  lost or misdirected in the  vast  hallways
      of administrative  bureaucracy."

           We  think the  Legislature intended that  section
 39276 and  the other provisions  of the  state air pollution
 control laws  discussed  above be  given  a  broad construction
 in  order to combat the  evil  of  air pollution  to which  the
 legislation is directed.  See Fr;_i_ends  pf __Manimoth  v.  Board
p f_ S u p e r v is or s ,  supra,  8  Cal.3cT ar, 2~5^T

                          III

           The Authority of  the Air Pollution  ControJL
           Ms trie-TV to  Indirect ly Re_gulate  VeljTcu'Iar
           Em is s i ojis__in~'t n e C ou r s e ot R e gu la ti ng^
           Corn pTex S our c e s      ~~

           An  additional problem  is  presented  by the  fact
that  regulation  of complex sources  operates in part  as an
indirect regulation  of vehicular emissions.  Local and
regional authorities  have the primary  responsibility for the
control of nonvehicular sources.   §  39012.  Part  1 of  the
Mulford-Carrell  Air  Resources Act provides  a  comprehensive
scheme for regulation of vehicular  emissions  by the  board.
The board  is  expressly authorized to adopt  emission  standards
for vehicles.  §  39052.

           This office has previously concluded that  the
Legislature did  not  intend air pollution control  districts
to supersede  board regulation of  vehicular  emissions.  Letter
to Honorable  Pete  Schabarum,  Assemblyman, 49th  District,
Feb.  17, 1972, I.L.  72-37,   L.B.  No. 382, p.  30.   However,
this  office has  also  concluded that  other control measures
are within the primary jurisdiction  of the  air  pollution
control districts and that "indirect measures ultimately
aimed at reduction of vehicular  emissions"  must in the first
instance be undertaken by the air  pollution control  districts
before the board may  intervene.  Letter  to  Honorable Nicholas
C.  Petris,  Senator,  llth District, Mar.  8,  1971,  I.L.  71-73,
L.B.  No. 381,  p.  47.  This delineation of the  board's
authority  has  been upheld.   In Environmenta_l  Defense Fund,
Inc . v . Air Resources Board,  3 0 Cal.App."JcT~8T9~ f i7/? 3~77~Tn'c
court hercTTliat  the  primary  jurisdiction of the board  in
regulating motor vehicle emissions  is  limited  to  regulation
of the pollutants that come  out  of  the motor vehicle and
that  the board cannot regulate fuel composition.
                           K-13                     SO  73

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          This office has also'expressed the view that the
authority of the board to regulate vehicular emissions does
not preempt county air pollution control districts under
their broad powers from stopping vehicular traffic in emer-
gencies.  Letter to Highway Patrol Commissioner H. W.
Sullivan, Jan. 28, 1972, I.L. 72-18, L.B. No. 382, p. 17.

          Despite the indirect effect on vehicular emissions,
the initial authority to regulate complex sources would
appear to be vested in the air pollution control districts.
The authority of the board with respect to regulation of
complex sources appears to be to review local plans and
implementation programs for their adequacy, to establish
plans when local plans are found by the board to be inadequate,
and to enforce plans when local plans or programs are found
by the board to be inadequately enforced.  See §§ 39052
subd. (f), 39274, 39275 and 39276.

                           IV

          The Legislative Authority of the Bay Area
          Air Pollution Control District^ and the
          Rgg^ipnal'Ijistricts to Regulate Complex
          Sources in Order to Attain or Maintain
          Federal and State AirDuality S'tandarjTs_

          The Bay Area Air Pollution Control District and
regional air pollution control districts also have the
authority to regulate complex sources where necessary to
achieve or maintain federal or state ambient air quality
standards.

          Section 24354.2 was enacted as part of the Bay
Area Air Pollution Control Law of 1955.  As amended in 1972,
it provides:

          "The district shall do such acts as may be
     necessary to carry out the provisions of this
     chapter and all provisions of Part 1 (commencing
     with Section 39000) of Division 26 relating to
     nonvehicular sources of air contaminants."

          Section 39382 pertaining to regional air pollution
control districts was enacted in 1967 as part of part 2 of
the Mulford-Carrell Air Resources Act.  As amended in 1972,
it is identical to section 24354.2.  These sections are
comparable to section 24260 of the County Air Pollution
Control Law.  Other sections of the Health and Safety Code
also confer broad rule-making authority on the Bay Area Air
Pollution Control District (see e_.£. , §§ 24362, 24362.1,
24362.3 and 24350.5), and on regional districts (see e_.g_. ,


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 §  39460).V  Also see sections 24354.1 and 39381 which pro-
 vide  that  the Bay Area Air Pollution Control District and
 the regional districts respectively shall establish an
 effective  program for the reduction for air contaminants in
 the district.

           These sections together with those provisions of
 part  1  of  the Mulford-Carrell Air Resources Act discussed
 above confer authority upon the Bay Area Air Pollution Con-
 trol  District and the regional districts to regulate complex
 sources by denying authority to construct where necessary
 to achieve or maintain federal or state ambient air quality
 standards.

          Our conclusion is that the county, regional, and
 bay area air pollution control districts have the authority
 to regulate complex sources including authority to prohibit
 construction of complex sources where the emissions indirectly
 generated by such sources would prevent the attainment or
 maintenance of federal or state ambient air quality standards.
                        xxxxxxxxxx
     4.  This office has previously expressed the view that
in order to reduce or alleviate the air pollution within the
district, the Bay Area Air Pollution Control District rray
adopt general performance standards which, if reasonable and
uniform, may be such that certain types of residential or
commercial development may be inhibited or entirely pro-
hibited.  Letter to Honorable John A. Maga, Executive Officer,
State Air Resources Board, October 6, 1971, I.L. 71-23, L.B.
No. 381, p. 144.  This conclusion was based on the rule-
making authority conferred on the Bay Area Air Pollution
Control District by sections 24362, 24362.1 and 24362.3.



                           K-15                    SO 73/43

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                                                          r•'".•-"'•' •* •''
                                                             C l' r    I
               COURT OF APPEAL, FOURTH  DISTRICT

                        SECOND DIVISION

                      STATE OF CALIFORNIA
WESTERN OIL & GAS ASSOCIATION,          )
et al.,                                 )

          Plaintiffs and Respondents,   )        4  Civil 13466
                                        )     (Sup.Ct.No,  lrU239)
-v-                                     ) .

ORANGE COUNTY AIR POLLUTION             )        0  P !_ W I O N
CONTROL DISTRICT, et al.,               )

          Defendants and
          APPEAL from a  judgment  of  the  Superior Court of Orange

County.  James F. Judge, Judge.   Affirmed.

          Adrian Kuyper, County Counsel,  and' John F.  Povell,

Deputy County Counsel for  Defendants and Appellants.

          Kvelle J. Younger,  Attorney General,  Robert H.  O'Brien,

Assistant Attorney  General,  Nicholas C.  Yost,  C. Foster Knight

and Jan E. Chatten, Deputy Attorneys General,  as Amici Curiao on

behalf of Defendants and Apps 11 tints.

          McCutchen, Black,  Verleger & Shea,  Philip K. Verloger,

•Jack D. Fudge, and  David A.  DcKcino  for  Plaintiffs and Respon-

dents.
                                K-16

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          In October 1971, the Orange County Air Pollution

Control District ("District") adopted Rule 74.   The purpose of


the rule was to eliminate the lead content in gasoline sold in

Orange County over a three year period commencing July 1, 1972
                        1 / "
and ending July 1,  1975.

          In March 1972, Western Oil and Gas /vssociation, i\ non-

profit corporation, and several of the major oil companies doing


business in California filed suit in the superior court seeking

declaratory and injunctive relief against enforcement of the


rule.


          In July 1973, the-case came on for trial on stipulated

facts, stipulated exhibits and depositions.  The court held that



I/  Rule 74 states, in part:
    "B. 3.   No retailer shall sell any gasoline having an octane
number of 96 or more containing, lead exceeding  the following:
on or after July 1, 1972, 3.0 grams per gallon; on or after July
1, ].973, 2.0 grams  per gallon; on or after July 1, 1974, 1.0
grams per gallon; on or after July 1, 1975, traces.
    "2.  No retailer shall sell any gasoline having an octane
number of less than 96 containing lead exceeding the following:
on or after July 1, 1972, 0.5 grams per gallon; on or after July
.1, 1973,. 0.1 grams  per gallon; on or after July 1, 1974, traces.
    "3.  Every manufacturer of gasoline and every retailer cf
gaso]ine shall sell at least one grade of gasoline having an
octane number of not less than 90 and containing lead not exceed-
ing the following:   on or after July 1, 1972, O.C grans pc>r gallon;
on or after July 1, 1973, 0.1 grams per gallon; on or af-cer July i,
IS'74 , traces .
    "'Retailer,' as used in this Rule means any person possessing
a valid motor fuel  pump license issued pursuant to the California
Business and Professions Code Section 20767."
                               K-17

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the primary purpose and effect of the rule was to control the



emissions of lead from motor vehicles; that under section 39012



of the Health and Safety Code, county districts are authorized



to control "... air pollution except for the _emiRsions_frg_m_



motor vehicles";  that Rule 74 is null and void and its enforce-



ment is enjoined.  The District challenges this ruling.



          California is the only state which had adopted an



ambient air quality standard for lead.  (Cal. Admin. Code, tit. -



17, § 70200.)  The standard is 1.5 micrograms of lead per cubic



meter as a 30 day average.  This standard was adopted in Novem-



ber 1970 by the California Air Resources Board to protect public



health.  The State Department of Public Health found that con-



centrations of lead above 1.5 micrograms per cubic meter are



associated with increased storage of lead in human bodies which,



in turn, produces detectable metabolic effects.



          Thirty day average"lead levels as high as 8.2 micro-



grams per cubic meter have been measured in Los Angeles Couniry.



Orange County measurements of 30 day averages show as high as



6 micrograms per cubic meter.



          The major source of lead in California's air ir the



emission of  lead from motor vehicles due to the combustion of



lead and anti-knock compounds in gasoline.  More than 90 percent



of the gasoline sold in the state is for highway vehicular use.
                               K-18

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          The California Air Resources Board has determined

that an 80 percent reduction in lead emissions from motor

vehicles is necessary to attain the statewide ambient air
                          !/
quality standard for lead.

          The most effective way to reduce lead emissions from

motor vehicles is to reduce or eliminate the lead content in

gasoline.  While there are other ways of reducing lead emissions,

such as requiring the installation of lead trap devices on motor

vehicles, the effectiveness of these types of structural alter-

ations is debatable.

          This appeal raises the single issue of whether the

District can validly regulate the lead content of gasoline used

in automobiles or other motor vehicles.

          Controlling the resolution of this question is the

principle that, the District, as a regulatory agency, can regu-

late only what the Legislature says it can regulate, and can do

so only in the manner prescribed by the Legislature.  It has no

authority to enact rules or regulations which enlarge the terms

of the legislative enactments which give it existence and pov;er.


2/  In December 1973, the Environmental Protection Agency pro--
iaul gated regulations concerning lead additives in gasoline.
(38 Feel, keg I 33734.)  By the terms of the Clean Air Act, the
proMulgatJon of these regulations by EPA preempted the field of
leaded gasoline regulation throughout the United States excrpl.
for the State of California.  (42 U.S.C.A. 1857f-Gc (c) (4) (B) .}
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(California Sch.  Employees Assn.  v.  Personnel Commission,  3



Cal.3d 139; Morris v.  Williams, 67 Cal.2d 733; Ellis v. Board



of Education, 27  Cal.2d 322;  Whitcomb Hotel, Inc. v. Cal.  Emp.



Com._,  24 Cal.2d 753;  Environmental Defense__Fun_d v. California



Air Resources Bd,, , 30 Cal.App.3d  829; People v. Barter Packing



Co.,  160 Cal.App.2d 464.)   From this it follows that, in order



to define the limits  of the District's power, we must inspect



the statutes which spell out those boundaries.



          The trial court rested its decision primarily on



section 39012 of  the  Health and Safety Code.  This measure in



question, enacted in  1967, is one of the prefatory sections of



the Mulford-Carrell Air Resources Act.  It pronounces the policy



which the Legislature proposed to follow in fighting the evils



of air pollution.   It provides:  "Local and,regional authorities



have the primary  responsibility for the control of air pollution



except for the emissions from motor vehicles.  These authorities



may control emissions from nonvehicular sources.  ..."



          It is difficult to imagine a plainer statement of what



a  state-created agency can and cannot do.  It is  to the litigant



District and to similar agencies that the term "local and regional



authorities" refers (see § 39009.5).  With the District specific-



ally in mind, the Legislature has said that such  entities "may



control emissions from ncnvehicular  sources"  to whatever extent
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             they  deem  advisable.  What  they may not do is to deal with
•           "emissions from motor vehicles."  So much is clearly the  "substance
•           contained", in  section 39012 (Code Civ. Proc., § 1858).  But this
             apparently is  not clear to  the District.
•                     It is the contention of the District that its rule
             does  not fall  under the ban of section 39012 because it does not
•           control automobile emissions; it "merely" regulates fuel  content.
•           While this proposition is offered in all seriousness, it  is not
             a  serious  argument.  The parties have stipulted that "the only
•           significant effects of regulating the lead content of ... gas-
             oline sold for highway vehicle use are to reduce from highway
™           vehicles the emission or discharge of lead into the atmosphere
•           and to extend  the life of catalytic afterburners in automobiles
             .  . ."  (which  are themselves emission control devices).   Given
||           that  the only  significant effect of controlling lead content is
_           the control of exhaust emissions, it is specious to argue that
*           Rule  74 is anything but an  attempt to do what the higher  author-
•           ity of section 39012 forbids to be done.
                       Taking another tack, the District contends that it
|           does  have  the  power to regulate fuel, after all, regardless of
•           what,  section 39012 says.  This claim is based upon the language
             of a  1957  enactment, section 24263.7 of the Health and Safety
•           Code,  which provides:  "The air pollution control board by

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regulation may:  (a)   Establish standards of performance for



any article, device,  equipment, or method spec ifica 1 ly de s igned



or intended for installation or use upon or in any motor vehicle



as defined in the Vehicle Code, for the purpose of eliminating,



reducing or controlling the issuance of air contaminants.  [11]



(b)  Prohibit the -sale, offering for sale or installation of any



article, device, equipment or method specifically designed or



intended for installation or use upon or in any motor vehicle



as defined in the Vehicle Code to eliminate, reduce, or control



the .issuance of .air contaminants, unless such article, device,



equipment or method is of a type which has been submitted to and



approved by the air pollution control officer as meeting the min-



imum standard of performance as authorized in this section.



Upon approval the air pollution control officer shall issue a



permit authorizing the sale, offering for sale or installation



of any said approved article, device, equipment or method re-



ferred to in this section."   (Emphasis added.)  We cannot agree



that this statute empowers the District to control gasoline con-



tent.  It is abundantly clear that gasoline is in no sense an



"article, device, equipment or method specifically designed or



intended" to "eliminate, reduce, or control the issuance of air



contaminants."  It is fuel, pure and simple; far from reducing



air pollution,  fuel causes it; and fuel is not what this piece
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            of legislation is concerned with.   The statute parcels out
            power to control standards, sales,  and installations of what,
            in the parlance of air pollution control,  is referred to as
            "hardware"  — structural additions  to or modifications of
            motor vehicle parts.   Since section 24263.7  has nothing to do
            with what goes into gasoline,  it cannot be used to sustain
            Rule 74."
                      Trying essentially the same approach, but using a
            different piece of legislation,  the District asserts that its
            rule is a valid one because based on section 24262 of the Health
_           and Safety Code.  This states:   "Whenever  the air pollution con-
™           trol board finds that the air  in the air pollution control dis-
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            trict is so polluted as to cause any discomfort or property dam-
            age at intervals to a substantial number of(inhabitants of the
            district,  the air pollution control board may make and enforce
            such orders, rules, and regulations as will reduce the arnour.t
            of air contaminants released within the district."  At first
            glance, the statute seems to do everything the District says it
            does.  It  is as broad and flexible as the "elastic clause" of
            3/  It is,  in any event,  doubtful whether section 24263.7,  while
            still  on the books,  is still in effect.   The enactment of the rJ r
            Reso-orces Act of 1967  (Health & Saf.  Code,  § 39000 et scq.)  appears
            to repeal, it sub sij_ontio,  and to transfer  the powers therein
            created to the Air Resources Board.   In  light of our construction
            of the statute, however,  we need not  roach  the question of.  its
            continuing force.

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the United States Constitution.  But it is also dead letter.



Regardless of what the Legislature may have intended in 1947,



when section 24262 was enacted, it can no longer be considered



the law in light of the subsequent enactment of section 39012,



which gives the air pollution control districts a more limited



role in the battle, against air contamination.  It is a familiar



proposition that, where the Legislature passes contradictory



statutes, the later in time controls.  (County of Ventura v.



Barry, 202 Cal. 550; People v. Dobbins, 73 Cal. 257.)   The



passage of section 39012 repealed section 24262 by implication.



          But, argues the District, the decision in Environ-



mental Defense Fund v. California Air Resources Bd., supra, 30



Cal.App.3d 829, changes all this.  In that case, the court held



that the California Air Resources Board had no authority, under



any provision of the Air Resources Act of 1967 or the Pure Air



Act of 1968, to regulate the lead content of gasoline.  Had the



Legislature known that this was going to happen to the state-



wide board, contends the District, it would at the very least



have left the 1947 powers of the local air pollution control



districts untouched when it passed the Air Resources Act  (ol



which section 39012 is a part) in 1967.  While this may be. true



(as it: may also be false), this court is unaware of any author-



ity for importing the principle of dependent relative revelation
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•          from the law of  wills into the rules  of  statutory  interpreta-
            tion.   Our touchstone here is the  intent of  the  Legislature.
J          (Code Civ. Proc. ,  § 1859;  People v. Superior Court,  70  Cal.2d
_          123.)   We are concerned  with analysis of what the  Legislature
™          did  do,  not with attempts  to predict  what would  have happened
•          in a hypothetical  past had the Legislature enjoyed pov;ers of
            prevision.  We decline to  indulge  in  this sort of  speculation.
|                    The actual intent of the Legislature as  to what the
_          power of the air pollution control districts shall be is  dds-
™          cernible from more sources than simply section 39012.   In
I          measure after measure of the Air Resources Act,  the power
            handed out to the  District and its fellow agencies is confined
|          to jurisdiction  over the nonvehicular portion of the state's
M          pollution sources  -- a domain smaller than wnat  the District
            lays claim to, but sizeable nonetheless.  Such limits are
•          found, for example, in section 24260  of  the  Health and  Safety
            Code which restricts the powers of the pollution control  boards
•          to the promulgation and  enforcement of rules,  regulations,  and
•          orders necessary or proper to achieve the purpose  of curbing
            "nonvehicular sources of air contaminants."   Similar provisions,
I          sections 24224 and 24355.2, similarly circumscribe the.  duties
            and  powers of APCD control officers.   More obliquely, but none-
H          theless clearly,  sections  39057 and 39078 et seq.  limit t>^

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power of the local districts to create emission standards for


lead and other air pollutants to those having nonvehicular


sources.


          As a final argument, the District submits the propo-


sition that the Attorney General and the California Air Resources


Board have consistently adhered to the view that the regulation


of the lead content of gasoline is within the authority of the


air pollution control districts.  This is the interpretation


which these authorities have put upon the provisions of the Air


Resources Act (Health & Saf. Code, § 39000 et seq.).  The District


maintains that,  under the authority of Rivera v. City of Fresno,


6 Cal.Sd 132, 140, the opinions of the Attorney General and of


the Board must be given great weight in the resolution of this


appeal, inasmuch as it turns upon the interpretation of the same
                                           i

statutes.  While this may be so, the fact remains that these


opinions do not constitute controlling authority in the disposi-


tion of this case.  That authority rests in the statutes them-


selves; and their meaning and effect, as developed earlier in


this opinion, is clearly the contrary of what the Attorney


General and the Air Resources Board hold.  Our obligation is not


to imitate their error, but to correct it.


          In the case at bar, we are invited to sustain a rule


which is unsupported by the language of any statute or the
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             decision  of  any  court,  and  against which is  ranged the entire
•            weight  of ail  existing  authority.  In  such a case, there can
•            be  but  one. result.
                       The  judgment  is affirmed.
I              "        CERTIFIED  FOR PUBLICATION.

I
                                            I/s/ Kerrigan __ ^ __
                                                                 Acting  P.J.
             We  concur :
Kaufman
 I           /s/ Gabber t

             j/
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                       J:*
                       J.
             I*   Retired Justice of  the  Court of Appeal sitting under assign-
             ment by the Chairman of  the Judicial  Council.

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                              APPENDIX  L

                  POTENTIAL CONFLICTS WITH OTHER PROGRAMS


     The overall success in achieving and maintaining air quality will

depend in part on possible conflicts and interactions with other environ-

mental goals.  This results from two general  factors.  First,  some types

of control technology result in the transfer of air pollutants to another

medium.  For instance, wet scrubbers result in a wash water to be disposed

of, and electrostatic precipitators discharge solid wastes.  Second,  and

perhaps more important for San Diego County,  is the propensity of other

environmental programs to induce or inhibit growth.  The availability

of services such as water, sewer, and solid waste removal  strongly affect

the location and magnitude of urban and suburban growth.  If such services

promote, for example, "bedroom" communities,  that is, suburbs  with little

or no local employment, then commuting long distances to work  adds increased

air pollutant loads to the basin.  Since the current clean up  of new  and

existing automobiles alone cannot be expected to reduce reactive hydro-

carbons to levels required for air quality standards to be met, anything

which promotes VMT increases in the country will magnify the problem.

Since most of the larger stationary sources are coming under progressively

stricter controls, minor dispursed contributors such as motorcycles,

lawnmowers, etc. become important.  With all  the easy control  measures

exhausted, some measures to dampen growth will  become necessary if air

quality is not to deteriorate.
                                                       L-l

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L-l   Water Supply

     The majority of water used in the San Diego region, about 560,000
acre-feet in 1970, is imported (L-3).  Only about 14% of the water is
obtained from local surface supplies, and 23% from groundwater reservoirs.
Presently, Colorado River water is delivered from the Colorado aquaduct at
San Jacinto to two San Diego aquaducts under contractual arrangements with
the Metropolitan Water District of Southern California (SCMWD).  (See
Figure L-l)  Although Colorado water is of good quality at present, total
dissolved solids (about 750 ppm) and hardness are slowly increasing.
Streams in the region are ephemeral  in nature and potential  storage reser-
voirs are essentially fully developed.  Ground water quality varies but is
generally lower than imported Colorado water.  The State water project
(L-4) is scheduled to bring northern California water to the San Diego
aquaduct starting in 1975, although complete blending of northern and
Colorado water may not start at that time.
     The Colorado River Basin Project Act of 1968 (L-4) apportioned to
Arizona, Nevada, and California, water from the Colorado River based on
the 1964 Supreme Court decision.  Specifically, California was assigned
4.4 million acre-feet per year plus a percentage of excess available,
with supplies to the SCMWD to be reduced from 1.2 million acre-feet to
0.55 million acre-feet after completion of the central Arizona project.
Hence, the necessity of northern California water for the Southern
California Region.  The exact timing of the central  Arizona Project is
not certain at this time, however.
                                  1-2

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     The magnitude of projected population in the county varies with dif-
ferent  sources of the estimates (see Appendix B, for instance).  In the
water supply area, a recent survey by San Diego County Water Authority
(SDCWA)  (L-5) of local contracting agencies which supply filtered water
for  public use showed that water requests were equivalent to a total
population of 2.7 million in 1990 compared to the comprehensive planning
agency  (CPO) estimate of 2.29 million.  Assumed is a constant per capita
consumption of 0.25 acre-feet per year.  SDCWA has adopted the CPO estimate
for  its  planning purposes, (L-5) thus bringing some consistency to water
supply  planning.  Being service oriented and mandated by law, water utili-
ties like SDCWA cannot deal  with side issues such as air quality, and are
as likely to induce as to slow down the growth of suburbs.  Water supply
for  the  future will involve only small direct air quality impacts, mainly
construction activities and fuel use for pumping and potable water treat-
ment.
     The San Diego Regional  Water Quality Control  Board has also made
projections of water supply and demand based on Dept. of Finance E-0 and
D-150 population projections for the San Diego County (see Appendix B for
details  of population projections).  As mentioned previously, essentially
all  local surface and ground water is developed, so that imported water
is projected to increase by factors of 2.0 and 2.3 by the year 2000,
respectively, under the two population estimates.   Reclaimed water is to
increase by a factor of 10 under both assumptions  about population growth.
As to use of this water, agriculture, which currently accounts for a third
of water use, is seen to increase slightly for the next decade, then drop-
ing off  somewhat by 2000.  The dramatic increase is in urban use, as might
be expected.
L-1.2  Waste Water Treatment and Water Quality
     Several state and federal  laws affect water supply and water quality
in the San Diego Region.
     The National  Environmental  Policy Act (requiring impact statements
for  projects involving federal  support) and the Federal  Water Pollution
Control   (L-14) Act (FWPCA) of 1972 are the primary national  laws dealing

                                     L-3

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with water supply and quality.   Analogous legislation at the State level
includes the California Environmental  Quality Act (CEQA) and the Porter-
Cologne Water Quality Act of 1969.   The California administrative code
(L-13) also defines the role of the State Water Resources Control  Board.
The State Board and nine regional  boards formulate basinwide plans, as
required under Section 303 of FWPCA.   Grants for wastewater treatment
and related facilities are also administered by the State Board (Section
201 (L-14A) of FWPCA).  At present, over 87% of the cost of wastewater
treatment facilities is born by state and federal  governments.
     One of the few examples of policy coordination between agencies
involved with environmental  decision making is the current practice of
the State Water Resources Board of  funding waste water facilities only
to the extent of E-0 population projections in critical  Air Basins (L-12).
(San Diego County is defined by the Air Resources Board  as one  such basin.)
This policy represents a departure  from traditional thinking for agencies
with a "service" orientation to the public.  The board seems to recognize
the partially self-fulfilling nature of projections about "needs" and
"demands."  By itself, the funding  policy of the board is not able to
resolve land use issues affecting  air quality, such as the desirability
of any growth in some areas, or tradeoffs involving growth between areas.
Despite the lack of comprehensiveness of the policy, it  is bound to have
some slowing effect on urban growth for San Diego County.
     The State Board has authority  to deny new sewer hookups to municipal
systems until treatment capacity is increased or upgraded.  Although a
current sewer connection moratorium is in effect in the  Santee-Lakeside
area, it appears the decision is related to a public health nusiance from
mosquitos downstream on the San Diego River rather than  a concerted attempt
to control growth in the suburban  area
     At the Regional level,  the San Diego Basin Regional Water  Quality
Control Board has developed a comprehensive water quality control plan,
(L-3) in compliance with state and  federal legislation described above.
A brief sketch of this plan is given here in the context of possible
interactions with the air resource  and air quality maintenance.  In the
San Diego Water Basin (definition  also includes portions of Riverside and
Orange Counties) (See Figure L-l )  the lower San Diego hydrographic subunit,

                                   L-4

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 San  Diego Bay, and two north county subunits are recognized by the State

 Board as water quality class units - that is, segments known to exceed

 current water quality standards and expected to exceed standards even

 after effluent limitations (see Figure L-l).  The Regional Board has also

 asked that several coastal lagoons be added to this list.  All other waters

 in the county are "effluent class segments," meaning that water quality can

 be met by limiting of inputs (FWPCA Section 303).   The Pacific Ocean is

 classified as "effluent limiting."  Eutrophication presents the major

 problem for surface waters and coastal  lagoons, while San Diego Bay is

 unable to assimilate the current thermal load.

     As specified in Section 402 (L-14C), FWPCA, best available treatment

 for  discrete industrial  sources is required by the board by 1983, while non-

 discrete sources must comply with compatibility requirements for discharge

 to municipal sewers.  Reclamation is emphasized for inland treatment plants,

 with some reinjection of sludges to the metro system for San Diego City area

 Secondary treatment is required for all plants in the future,  including the

 largest in the county, Point Loma.  Sludge is to be disposed of on land

 rather than ocean outfall.  Table L-l  shows the total  municipal  wastewater

 expected in San Diego region through the year 2000.

                                Table L-l
YEAR
1970
1980
2000
FLOW
(MGD)
122
175
287
BOD
(Tons
75
15
21
TSS
per day)
39
15
25
TDS
818
614
841
     The improvement in quality reflects both the secondary treatment

requirement (required by Section 301,  FWPCA) and the lower dissolved

solids of imported northern California water.  The Regional  Board has

also requested some automony from Section 208 requirements of regional

treatment in order not to discourage local  reclamation projects.

     Direct effects of any air quality maintenance program on water quality

are generally less important than factors inducing or inhibiting  growth.

Since oxidant is the major air pollutant requiring control  in San Diego

County, limitations of reactive hydrocarbons will  receive most emphasis.
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 Only a few stationary sources  emit  significant  amounts  of  hydrocarbons,
 and these will  generally use vapor  recovery  systems,  floating covers  for
 storage,  mechanical  systems, or  combustion systems  for  control  of  emis-
 sions.  None of these processes  result in the discharge of much wastewater.
 Control of hydrocarbons  and carbon monoxide  from mobile  sources, requiring
 both controls on  new  and existing vehicles,  and on  the  number of vehicle
 mile travelled, are not  expected to affect water quality in a direct  sense.
 Rather, the  impact on population distribution and growth will affect  potable
 water demands and required wastewater  treatment facilities.  Control  of sus-
 pended particulates can  be seen to have some  influence  on water quality due
 to  the use of such devices as  scrubbing systems, especially in  the minerals
 industry.   The  quantities involved are not particularly  large,  however.
 Additional  water may  be  required for control  of dust  from the minerals
 industries or for minimizing construction born emissions.  Particulate
 (and NO )  emissions are  currently controlled from power  plants  by combustion
        /\
 modifications,  rather than by  "add on" controls.
      The  increase in  treated sewage sludges  and solids,  resulting from both
 increased  population  and better treatment, present  a  possible air pollutant
 source since ocean disposal of such materials is to be  phased out under the
 ocean plan.  In land  plants many also  reinject treated  sludges  into the
 metro system, increasing the load at Point Loma.  Incineration  is generally
 not part  of land disposal plants.  A combination of landfill and fertilizer
 (soil  conditioner) use will be the ultimate  fate of these sludges.  Impacts
 directly  on  air quality  will be limited to possible local odors.  The water
 plan for  the region thus seems to present few direct  conflicts  with air
 quality.   Moreover, growth inhibition  through treatment  plant funding and
 sewer connection moritori urns may help  out in meeting  air quality objectives.
L-1.3  Coastal  Zone Commission
      Proposition  20,  which passed during  the election of November 1972,
 established  the California Coastal Zone Conservation  Commission, along
 with six  regional commissions.  The purpose  of this legislation was to
 prepare a  comprehensive  plan for the coast zone environment, to be sub-
 mitted to  the legislature in 1976 for  approval.  The  Commission also  is
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charged with issuing permits for development projects within 1000 yards of
the coastline.  Currently, the San Diego Regional Commission is preparing
a series of reports to be synthesized into the plan for the future of the
entire California coast.  One report in this series, (L-10) dealing with
the land environment, in San Diego County, has some policies and recommen-
dations regarding air quality.  Cited are meterological conditions which
often confine air pollutants to small areas near the coast, especially in
winter.  In the summer, on the other hand, low clouds and fog prevent
local photochemical smog, although emissions near the coast may drift to
sunny inland areas and contribute to oxidant concentrations there.  Mobile
source emissions are recognized as the major factor involved in coastal air
pollution.  The recommendations therefore include exclusion of major high-
ways from the immediate coastal environment, while maintaining recreational
access to beaches.  Public use of ocean resources for recreational purposes
should be included in any transportation plan, and the private automobile
is assumed to continue to be the mode which the public will use for such
travel.
     Regarding stationary sources, the long range goal  is to phase out
industrial pollutant sources from the coast zone.  Also, no new power
generating stations are to be built on the coast, and expansion of exist-
ing plants is subject to cumulative air pollutant effects on public health
and other coastal  resources.  Agricultural  resources are heavily emphasized
in the San Diego County coastal zone.  The Commission recognizes both the
direct effects of air pollutants and increasing consumption of agricultural
land by urban and suburban growth, with consequent air pollution.   The
coastal  land report also deals with industries such as sand and gravel
operations and effects on beach sand supply.  Regulations on the location
and magniture of these industries may affect air quality, especially par-
ticulates.
     Although the coastal  zone commission has not finalized its policies,
it does not appear that its  decisions will  represent comprehensive planning
with regard to air pollution.  Despite the concern shown for air pollution
in the coastal  land environment report,  the commission lacks expertise in
the field.  The broad nature of its jurisdiction and responsibilities will
probably result in air pollution being only one of a series of factors
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 involved  in any decision.  Although some of the goals involved in air and
 water quality are perfectly in line with policy statements so far by the
 regional  commission, the net effect if these policies are implemented may
 be to transfer problems inland.  The recreational access emphasized by the
 commission, laudable though this goal is, suggests problems with road and
 freeway siting.  How this will be resolved and the effects on VMT and air
 quality are unclear.
     As mentioned in Section 2.3.5, the Navy presents jurisdictional
 problems  for the coastal commission.  Also, the Navy has not filed an
 Environmental Impact Statement for its master plan.  Presumably, the
 commission would have to appeal to EPA if the Navy conducted its busi-
 ness contrary to the commission policies.  Navy activities also induce
 certain support service growth along the coast, with uncertain effects
 on air qua!ity.
     The  coastal commission has recently followed through on its ocean
 discharge policy by recommending that the Point Loma treatment plant be
 limited to serving the present population level until a long range popu-
 lation study for the area is done.
     It should be noted that the coastal commission is relatively new and
 policies  are still being refined.  In addition, the final plan must be
 approved  by the legislature, and the commission's recommendations may be
 tempered  by political realities as impacts on the local  economies becomes
 clearer.  In summary, the coastal zone commission's preliminary policies
 are generally consistent with air quality goals along the coast but the
 ability to implement these policies and the effects inland remain uncertain.
L-1.4  Electric Power Generation
     Electric power production presents a number of questions for both air
 and water quality in San Diego county.  Despite the water quality class
 status of San Diego Bay mentioned before, the regional board has recommended
 exemption of existing power (plants there from the  thermal plan.  San Diego
 Gas and Electric currently has a county wide base load generating capacity
 of about  1700 megawatts, roughly 1000 of which is on San Diego Bay.  Also
 planned is a 300 megawatt expansion of the Encina facility at Carlsbad
 (L-9).  Some inland sites are currently being investigated for future

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generating stations, but no firm plans exist at present.  Steps taken to
date  in compliance with APCD regulations (L-ll) have generally involved
combustion modification and have not generated wastewater.  Since both
the WRCB Ocean Plan and the regulations of the Coastal Commission will
probably prohibit locating of fossil fueled generating stations on the
coast, increased local air pollution loads (not necessarily hydrocarbons)
inland will result from future fossil fueled power generation.  Policy
regarding nuclear power plants is undecided at this time.  Power production
illustrates better than other industries the lack of mechanisms for inter-
nalizing the tradeoffs necessary for overall environmental improvement.  The
location of power plants inland with consequent efficiency losses from closed
cycle cooling will result in more fuel burned (and more emissions) per unit
of output.  Combustion modifications also decrease generating efficiency as
a trade-off for air quality.  One option for both air and water quality
improvement would be to import power.  (Currently about 180 megawatts are
imported.)  But some of the problems merely move to the northwest, or
perhaps Arizona and New Mexico.  Clearly, air quality maintenance with
respect to power production involves administrative powers and structure
not currently in existence.
L-l.5  Assembly Bill 3421

     An interesting piece of proposed legislation having implications for
both air and water quality is Assembly Bill  3421, (L-6).  Essentially this
bill  would consolidate the ARG, WRCB, Solid Waste Management Board, State
Transportation Board, and the Division of Transportation Planning, into the
State Resources Conservation Board and 8 Regional Boards.  At a later date,
the Coastal  Commission might be included.  The thrust of this legislation
is to incorporate various environmental  considerations into overall  land
use planning.   Policies such as the funding  practices of the WRCB would
thus become an integral part of the environmental  planning process, and
would perhaps  eliminate potential  conflicts  at an early stage.  Moreover,
since control  of pollution is often accompanied by a transfer from one
medium to another (i.e.,  air to water),  tradeoffs could be more easily
made under a  consolidated agency than from several  single purpose agencies.
AB 3421  would  not change  existing  powers, but rather attempt to coordinate
the exercise  of these powers.   Disfunctional  geographic boundaries between
agencies such  as  the air  basin vs.  water basin would be made more manageable.

                                   L-9

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 Regional boards are necessary to retain local input and deal with problems
 of  strictly local nature.  On the negative side, it is not apparent that
 consolidation of environmental agencies will be more effective directing
 or  dampening urban growth.
L-1.6  Solid Waste Disposal
     The majority of municipal solid wastes in the county are currently
 disposed of by sanitary landfill methods (L-7).  Open burning of refuse
 is  limited to small and isolated sites, and agricultural burning is
 regulated by the San Diego APCD.  A comprehensive plan for solid waste
 management in the county is currently being prepared, according to the
 requirements of the Nejedly-Z'berg Solid Waste Management and Resource
 Recovery Act of 1972 (L-8).  The State Solid Waste Management Board,
 created by the Act, is to review plans submitted by local governments.
 In  addition to health and sanitation regulations, plans are to recognize
 state water quality and national air quality control plans.  Guidelines
 for solid waste plan development require permit systems for waste handlers
 and disposal site operators.  Reclamation is to be planned for and encour-
 aged for both materials and energy.
     The direct impacts of solid waste disposal on air quality, and con-
 versely, are likely to be small.  Control, for instance of particulates
 from stationary sources will generate some solid wastes.  Little conflict
 is  apparent between air quality and current disposal practices, since open
 burning is not permitted and only small amounts of solid wastes are incin-
 erated in the county.  A retrofit program for automobiles will probably
 generate only slightly more "junk" parts that would occur normally.  VMT
 from disposal service vehicles is probably a larger emission source than
 any other from solid waste programs.
     Although the detailed plan for San Diego County is unavailable at this
 time, the guidelines for preparation suggest some problems with air quality,
 especially regarding urban growth.  One is the preservation of local control
 of  solid waste management.  Despite this tradition and its administrative
 simplicity, it seems unlikely that local government can effectively deal
 with complex growth issues.  Local economic pressures have often encouraged
 growth, expecting services such as solid waste disposal and handling, to
                                 L-10

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follow.  In this regard, the guidelines prescribe that State Department
of Finance projections of population growth, without stating which series
to use.  The local  area is apparently free to choose the higher population
projection if growth is viewed as desirable.  Another problem is,  that
although solid waste planning is to recognize air and water quality plans,
no mechanism is incorporated to deal with urban growth which might be in
conflict with such  plans.  In addition, financial  arrangements are, by
and large, left to  local agencies to decide.  If past experience is a
guide, the additional  costs, both direct and indirect, of future solid
waste disposal will  not be internalized to the producers of such wastes.
For instance, the expanded capital  costs of a solid waste system for a
new subdivision will most likely be recovered from property owners in the
future, rather than  from the developer at the time of construction.
     As was mentioned under water quality, AB 3421  would incorporate the
Solid Waste Management Board into the proposed Resource Conservation Board.
The Regional  Conservation Board would perhaps be more likely to address con-
flicts and interaction between environmental problems.
     With or without this legislation, the current city/county arrangement,
with inputs from CPO would largely be preserved.  Further comments about
possible conflicts  of air quality maintenance with solid waste disposal
should be reserved  until the plan being prepared is available.
                                   L-12

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                                REFERENCES
L-l.    State of California, Resources Agency, Air Resources Board,
       "A Report to the Legislature on Guidelines for Relating Air
       Pollution Control to Land Use and Transportation Planning
       in the State of California", August, 1973, pp. 3-4.

L-2.    Personal correspondence from D. Lieberman, Land Use Planning
       Program, Air Resources Board, to E. Leong, TRW, Inc., dated
       June 13, 1974.

L-3.    Comprehensive Water Quality Control Plan for the San Diego
       Basin, State Water Resources Control Board, April  1974.

L-4.    The California Water Plan, Outlook in 1970, California
       Department of Water Resources Bulletin No. 160-70, December 1970.

L-5.    San Diego County Water Authority, "Filtered Water Distribution
       Study", April 1974.

L-6.    Resources Conservation Board, A Report by the Legislative
       Analyst, State of California (pursuant to ACR 16), February 1974.

L-7.    California Solid Waste Management Study and Plan,  U.S.
       Environmental Protection Agency (USPHS #2118), 1971.

L-8.    "Guidelines for the Preparation of County Solid Waste Management
       Plans", California State Solid Waste Management Board,
       February 1974.  Regulations appear in California Admin.
       Code, Title 14, Div.  7.

L-9.   Hardway, J., San Diego Gas and Electric Private Conversation,
       June 10, 1974.

L-10.  Coastal Land Environment, San Diego Coastal Zone Region
       Commission, Draft, June 14, 1974.

L-ll,   William Louthen, San Diego APCD, Private Communication, June 12, 1974.

L-12,   Clean Water Coast Regulations, California Administrative Code
       Title 23, Chapter 3, Subchapter 7, Article 9, Section 2133, adopted
       August 16,  1973.

L-l3.   Title 23, Chapter 3 of the California Administrative Code contains
       administrative procedures for the waste water resources control
       board.  Sections 2500 to 2550 define a program to control solid
       wastes.  Title 17, public health covers water quality for domestic
       use and reclaimed water.
                                   L-13

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L-14.  Federal Water Pollution Control  Act (PL 92-500), October 18, 1972.

       a.  Section 201 -- defines best  practicable waste treatment for
           municipal facilities receiving Federal  grants.   The administrator
           shall encourage waste treatment management which emphasizes
           recycling and reclamation of waste water and sludges in an
           environmentally acceptable manner.

       b.  Section 208 -- resources designation of areas which would
           benefit from area-wide waste treatment, being consistent
           with the basin-wide plan (Section 303).

       c.  Section 301 -- defines effluent limitations, requiring best
           practicable control technology by July  1, 1977 and best
           available technology by July 1, 1983.

       d.  Section 303 -- requires basin-wide planning by states in order
           to achieve water quality standards.  Daily maximum pollutant
           loads for surface waters (including thermal load) are to be
           determined.  Waters are to be classified as to current and
           expected loads.  A compliance schedule  for direct and indirect
           sources is required.
                                   L-14

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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1 RE-PORT NO 2.
EPA-450/3-74-051
4 T IT LE AND SUBTITLE
Development of a Sample Air Quality Maintenance
Plan for San Diego
7 AUTHOR(S)
Transportation and Environmental Operations of TRW, Inc
J PERFORMING ORGANIZATION NAME AND ADDRESS
Transportation and Environmental Operations
TRW, Inc.
1 Space Park
RpHnnr|n Rparh , California 90278
i ' SPONSORING AGENCY NAME AND ADDRESS
Environmental Protection Agency
Research Triangle Park
North Carolina 27711
3 RECIPIENT'S ACCESSION-NO
5. REPORT DATE date Of 1SSU6
September 1974
6. PERFORMING ORGANIZAflON CODE
8. PERFORMING ORGANIZATION REPORT NO
10. PROGRAM ELEMENT NO.
Task Order No. 5
11. CONTRACT/GRANT NO
68-02-1385
13. TYPE OF REPORT AND PERIOD COVERED
Final Report
14. SPONSORING AGENCY CODE
1b SUPPLEMENTARY NOTES
1C ABSTRACT
 This report documents the development of a sample plan for maintaining the
 National Ambient Air Quality Standards in San Diego.  In the preparation of this
 sample plan, air quality and emission inventory data were analyzed, and an
 attainment strategy as well as a maintenance strategy was proposed.  In addition
 to the examination of various alternative source emission controls, various land
 use controls were analyzed through the use of the Delphi technique.  Finally,
 alternative organizational structures for administering the development and
 implementation of an air quality maintenance plan in San Diego were examined.
17 KEY WORDS AND DOCUMENT ANALYSIS
.1 DESCRIPTORS
Air Pollution
Land Use
Regional Planning
IS DI3 TRIBUTION STATEMENT
Release Unlimited
b. IDENTIFIERS/OPEN ENDED TERMS

19. SECURITY CLASS (This Report)
Unclassified
20. SECURITY CLASS (This page!
Unclassified
c. COSATl I'icld/Ciroup

21 NO. OF PAGES
258
22 PRICE
EPA Form 2220-1 (9-73)

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EPA Form 2220-1  (9-73) (Reverse)
                                                                                                                                       --'i

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