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
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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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TABLE OF CONTENTS (Continued) |
Page
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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
vii
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.
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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.
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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
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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
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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
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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.
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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
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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
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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 .
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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
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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
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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)
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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
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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
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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
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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
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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.
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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
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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.
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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
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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
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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.
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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.
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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.
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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.
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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.
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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
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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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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
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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.
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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.
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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.
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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.
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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
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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.
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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
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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
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• individuals disagreed that enabTing legislation was the
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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
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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.
102
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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.
103
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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.
104
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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.
A-l
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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
A-2
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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)
-------
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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Figure A-2.
Seasonal Trend for Oxidant (Average of Dally
Maximum Hourly Averages by Month) (Continued)
A-21
-------
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igure A-3. Diurnal Pattern for Oxidant (Monthly Average
of Oxidant Values by Hour of the Day)
A-22
-------
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A-4. Cumulative Frequency Distribution for
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A-23
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A-24
-------
CUMULATIVE FREQUENCY DISTRIBUTION FOR OXIDANT
FIGURE A-8
l «uu
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A-25
-------
1.0-
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Cumulative Frequency (%)
98
99.9
Figure A-10. Cumulative Frequency Distribution for Oxidant
A-26
-------
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A-27
-------
CUMULATIVE FREQUENCY DISTRIBUTION FOR CARBON MONOXIDE
HOURLY AVERAGES DOWNTOWN 1972 FIGURE A-12
01
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A-28
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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
-------
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
-------
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
-------
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
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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.
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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.
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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.
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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
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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
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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.
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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.
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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.
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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)
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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
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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.
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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
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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
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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
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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
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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?
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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= •--.-: •''•. ".\ '~ ~'"--: ^ '
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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).
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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
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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.
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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
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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
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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)
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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).
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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.
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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.
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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.
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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."
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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.
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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
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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.
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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.
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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.
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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,
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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.
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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
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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
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