State Parks Fails to Submit Acceptable PM Reduction Work Plan
On August 1, 2019 State Parks submitted to Gary Willey, Air Pollution Control Officer (APCO), and the
Scientific Advisory Group (SAG) a draft of the 2019 Annual Report and Work Plan (Work Plan). The Work
Plan is required by the existing Stipulated Order of Abatement (SOA) to describe in detail the measures
taken and proposed by State Parks to reduce particulate matter emissions from the Oceano Dunes SVRA.
Contrary to the requirements of the SOA, State Parks did not consult with the SAG before making this
submission. On August 26, review comments requesting revisions were returned to State Parks. Since
then State Parks made a second and third submission. Each was found by the APCO and SAG to be
deficient according to the requirements of the SOA.
As a consequence, on November 1, Gary Willey submitted to the APCD Hearing Board that issued the
existing SOA a petition requesting a modified or new Order of Abatement. He also issued a notice of public
hearing on November 18 where the APCD Hearing Board will consider the petition and take testimony and
Links to the public hearing notice, the APCO’s petition and the proposed Order of Abatement can be found
on the APCD Oceano Dunes Particulate Emissions Reduction Efforts website page (click here).
These recent events are a continuation of a long history of denial, resistance, foot dragging and excuse-
making on the part of State Parks. See the SOA Background page.
Highway Dune Riding - Commission Action Deferred
At its meeting on June 11, 2019, the California Coastal Commission conducted a hearing on Oceano Dunes
SVRA operations as required by the 1982 Coastal Development Permit establishing temporary operating
parameters for the off-highway vehicle park. Prior to this hearing Coastal Commission staff issued a
report highly critical of numerous failures by State Parks to operate the SVRA in a manner consistent with
the requirements of the permit, the California Coastal Act, and the San Luis Obispo County Local Coastal
Plan (LCP). (See the Staff Report). Commission staff proposed 13 major environmental protection
measures be implemented in the near term, including support for PM Reduction projects as required by
the SLO County Air Pollution Control District. Commission staff also concluded that off-highway recreation
on the dunes was not compatible with the requirements of the Coastal Act and LCP, and recommended
such activity be phased out. This highly controversial recommendation resulted in hundreds of people
participating in the hearing on both sides of the issue.
In response to the staff report, State Parks Director Lisa Mangat requested that the Coastal Commission
defer action on the recommended changes to allow State Parks more time to address these issues in a
Public Works Plan (PWP) currently being developed by State Parks. After a day of often heated comment
and testimony, the Commission voted to defer action, but did require that State Parks include the
recommended changes in the PWP that is to be submitted in the summer of 2020 to the Commission for
consideration. The Commission Chair asked and got from Mangat a promise that the changes would be
addressed by the PWP. In the days following the hearing ,letters from the Commission formalizing this
required commitment were sent to State Parks. (See the Coastal Commission Chair’s letter and Executive
Director ‘s letter.)
It is worth noting that while the Commission staff report called for support for the PM Reduction program,
deferral of the recommended changes does not relieve State Parks from proceeding with the dust control
projects necessary to comply with the Stipulated Order of Abatement. Indeed, State Parks committed to
the APCD Hearing Board that the SVRA Public Works Plan process would not adversely impact PM
Mesa Air Facts!