Comment Log Display

The attached document are comments that were submitted to the
SJVAPCD on their latest version of the PM2.5 plan.  These are
submitted into the public record for the ARB meeting on
5/22/2008.

To summarize the plan lacks the following regulatory essentials.

Analysis of recent data showing 2007 concentrations of PM2.5 well
over the NAAQS (65 ug/m3)

Analysis of missing (FRM) data when real-time data indicates the
highest concentrations of PM2.5

Lack of PM2.5 predictions for intermediate years to show
reasonable further progress

Lack of simplified explaination of the attainment demonstration
showing the RRF and what model was used to calculate it

Lack of an alternative attainment demonstration showing RRF's
directly calculated from the photochemical model

Lack of information from the photochemical model on the spatial
extent of the Sulfate, Nitrate, and Carbon plumes