Hearing
Board
Approves
Modified
SVRA
Stipulated
Order
of
Abatement, Drops Compliance with PM10 Air Quality Standard
On
September
13,
2022,
State
parks
submitted
a
final
draft
2022
Annual
Report
and
Work
Plan
(ARWP).
It
included
a
primary
dust
control
plan
that
included
no
new
dust
control
area.
Gary
Willey,
the
Pollution
Control
Officer,
required
that
the
ARWP
also
include
a
secondary
plan
that
provided
for
additional
dust
control
projects
acreage
for
2023.
Based
on
this
draft
ARWP,
Willey
made
an
application
to
the
Hearing
Board
to
modify
the
existing
SOA.
If
the
proposed
modifications
were
approved
by
the
Hearing
Board
the
primary
dust
control
plan
would
be
approved
by
Willey.
If
not,
the
secondary
plan
would be approved.
The
proposed
SOA
modification
was
considered
by
the
Hearing
Board
at
its
meeting
on
October
14,
2022.
State
Parks,
APCD
staff
and
the
Scientific
Advisory
Group
made
presentations.
Public
testimony
was
heard.
In
conclusion,
the
Hearing
Board
accepted
the
proposed
SOA
modification,
and
Gary
Willey
subsequently approved the draft 2022 ARWP and the primary dust control work plan.
The approved SOA modifications made the following important changes:
1.
The
term
of
the
SOA
was
extended
to
six
years,
giving
State
Parks
two
more
years
to
come
into
compliance with the SOA dust reduction goal.
2.
The
original
SOA
requirement
to
achieve
compliance
with
the
California
air
quality
standard
was
changed
to
require
dust
control
work
plans
to
be
“designed
to
eliminate
emissions
in
excess
of
naturally
occurring
emissions
from
the
ODSVRA
that
contribute
to
downwind
violations
of
the
state
and
federal
PM10
air
quality
standards.”
Compliance
with
this
new
criteria
will
be
determined
by
comparing
measured
PM10
mass
emissions
with
computer
model
estimates
of
emission
levels
that
existed
prior
to
significant
OHV
activity
on
the
Oceano
Dunes.
Because
excess
emissions
will
be
determined
in
part
through
computer
models,
the
public
has
no
means
independently
monitor
compliance
with
the
SOA,
and to hold State Parks accountable for complying with the legal PM10 air quality standards.
The
computer
modeling
performed
to
date
indicates
that
the
mass
emissions
reduction
goal
should
be
lowered
from
50%
reduction
to
40.7%.
The
Scientific
Advisory
Group
recommended
this
change.
Future
measurements
and
model
refinements
could
change
this
goal.
However,
approval
of
the
revised
SOA
essentially accepted the lower PM10 emissions reduction goal.
The
modeling
also
indicates
that
dust
controls
already
installed,
when
mature,
should
be
sufficient
to
achieve
this
new
goal.
Consequently,
no
additional
acreage
of
dust
controls
is
planned
for
2023.
Some
existing
areas
will
be
enhanced
and
some
will
be
converted
from
temporary
controls
to
permanent
native vegetation.
See
the
final
approved
ARWP
and
related
documents
(
click
here)
and
see
the
approved
modified
SOA
(
click here
).
Mesa Air Facts!
NEWS PAGE 1