From: rod4376@yahoo.com
Sent: Sunday, May 23, 2010 4:23 PM
To: Clerk of the Board@ARB
Subject: Strengthen air standards for Imperial County

Roderick Brown
4533 North Avenue Unit 3
San Diego, CA 92116-2601


May 23, 2010

CARB board members
 


Dear CARB board members:

Re: CARB Board Meeting, May 27, 2010- Agenda item 10-5-1 (Imperial County 
Air Quality and Consideration of the Imperial County PM10 State 
Implementation Plan)

Dear CARB Board Member:

Thank you for making the Imperial County PM10 clean air plan, known as the 
State Implementation Plan (SIP), a priority by including its review on 
your agenda for the May 27 board meeting. I support a strong SIP that will 
ensure that Imperial County will meet the federal PM10 standard and 
protect the health of the community.

The current Imperial SIP contains weak measures for fugitive dust rules 
800-806, and it does not go far enough to ensure that particulate matter 
air pollution is reduced to meet the federal PM10 standard. Recognizing 
this, the U.S. EPA Region 9 in December sent a letter to the California 
Air Resources Board (CARB) calling Imperial County's continual violations 
of the federal PM10 standard inexcusable.  The EPA's analysis of Imperial 
County Air Pollution Control District's Regulation VIII - Fugitive Dust 
Rules 800-806, which was sent to CARB and Imperial County Air Pollution 
Board in February, outlined the deficiencies of the Imperial SIP and how 
it could be strengthened in order to reduce PM10 levels to protect the 
health of those who reside in the county.   The analysis also highlighted 
how a number of critical SIP measures do not meet the standards of other 
California air pollution control districts, namely the SCAQMD and SJVAPCD 
rules that reduce particulate matter pollution from similar sources. At a 
minimum, the Imperial SIP should include standards that meet or exceed 
those of other California air pollution control districts.

The U.S. EPA has stated clearly that it could require rural areas such as 
Imperial County to adopt stricter controls on agriculture and other 
man-made sources of particulate pollution in order to attain the federal 
PM10 standard. By including the EPA's recommendations, the Imperial SIP 
can be strengthened to meet the federal PM10 standard and reduce health 
risks.  

It is imperative that the Imperial SIP incorporate the recommendations 
made by the U.S. EPA regarding fugitive dust rules 800-806. I urge CARB to 
send the SIP back to the Imperial County Air Pollution Control District 
with direction to strengthen it by implementing the U.S. EPA's 
recommendations. This should be completed no later than December 31, 2010, 
and then reviewed by CARB and sent to the EPA for final approval.

Sincerely,


Roderick Brown