Stipulated Order of Abatement Background and Progress to Date

On   April   30   the   SLO   County   APCD   Hearing   Board   approved   a   Stipulated   Order   of   Abatement   (SOA)   that   requires   State   Parks   to implement   dust   control   measures   designed   to   bring   the   Oceano   Dunes   SVRA   into   compliance   with   federal   and   state   PM10   air   quality health   standards,   and   to   reduce   PM10   emissions   by   50%   over   four   years.      A   draft   SOA   was   proposed   by   State   Parks,   and   after negotiations   between   State   Parks   and   Gary   Wiley,   the   Air   Pollution   Control   Officer   (APCO),   a   mutually   agreed   upon   SOA   was   issued   by the Hearing Board. (See the Filed SOA.) The   SOA   requires   State   Parks   to   take   certain   initial   PM   emission   reduction   actions   and   to   develop   a   Particulate   Matter   Reduction   Plan describing how this will be accomplished.  Progress to date is describe below. 1.  Dust Control Measures Implemented in 2018 - Completed On Time The   SOA   required   State   Parks   to   fence   off   foredune   areas   and   install   internal   fence   arrays   in   these   areas   by   September   15,   2018,   which it   accomplished   on   time.      In   subsequent   years   State   Parks   is   required   to   replace   the   internal   fence   arrays   with   native   vegetation intended   to   mimic   foredune   vegetation   as   it   existed   in   1930.      (See   the   2018   Fencing   Map ).      The   APCO   reported   in   his   comments   on the   draft   Particulate   Matter   Reduction   Plan   (see   below)   that   these   initial   measures   have   already   provided   a   degree   of   PM   emmission reduction. 2.  Install Sand Track-Out Control Devices - Complications The   SOA   requires   State   Parks   to   install   sand   track-out   devices   at   Grand   and   Peir   Avenue   park   entrances   by   June   30,   2019.      After initially   informing   the   APCD   that   it   could   not   meet   the   June   30   deadline,   State   Parks   has   now   said   it   would   meet   the   deadline   using   a temporary track-out system until a permanent one can be installed. 3.  Establish A Scientific Advisory Group - Delayed Activation, but Finally Completed The   SOA   required   State   Parks   to   establish   a   Scientific   Advisory   Group   (SAG),   which   will   evaluate,   assess   and   provide   recommendations on   mitiation   of   PM10   emissions,   on   the   development   of   the   Particulate   Matter   Reduction   Plan   and   on   annual   reports   and   work   plans.     State   Parks   and   the   APCO   mutually   agreed   on   the   members   for   the   SAG   in   the   time   required.      However,   State   Parks   was   responsible for   entering   into   contracts   with   the   SAG   members,   and   contracting   complications   delayed   the   start   of   SAG   activities.      Nevertheless, the   SAG   was   activated   in   time   for   its   members   to   review   the   draft   Particulate   Matter   Reduction   Plan   submitted   by   State   Parks   (see below). 4.  Particulate Matter Reduction Plan - Revised Draft Delivered in Response to Critical APCO and SAG Comments The   SOA   requires   State   Parks   to   prepare   a   Particulate   Matter   Reduction   Plan   (PMRP).      The   PMRP   is   intended   to   describe   how   State Parks   will   achieve   compliance   with   state   and   federal   ambient   PM10   air   quality   standards   and   reduce   emissions   by   50%   within   the   4- year   period   required   by   the   SOA.      State   Parks   delivered   an   initial   draft   Plan   on   February   1,   2019,   as   required   by   the   SOA.      This   draft   was reviewed   by   the   APCO   and   the   SAG,   and   on   February   25   the   APCO   forwarded   to   State   Parks   a   detailed   SAG   review   report   and   the APCO’s   comments.      Both   the   APCO   and   SAG   were   highly   critical   of   the   initial   draft   PMRP,   and   both   requested   various   changes   be   made by State Parks. On   March   28   State   Parks   submitted   a   revised   draft   PMRP.      Public   comments   received   through   May   15   and   other   related   documents   can be   found   on   the   APCD’s   website   ( Oceano   Dunes   Particulate   Emissions   Reduction   Efforts) .      The   plan   defines   measures and   tracks   projects   that   allow   the   annual   work   plans   to   be   developed   based   on   each   year's   actual   experience   in   an   annual   report   that is   due   on   Aug.   1   each   year.   These   annual   work   plans   will   be   subject   to   public   review   each   year   before   the   plans   are   approved   by   the APCD.  The first annual work plan is due on August 1, 2019. The   APCD,   SAG   and   State   Parks   held   a   public   workshop   on   May   1,   2019,   where   representatives   of   the   entities   made   presentations   and addressed   questions      take   from   citizens   in   attendance.      Members   of   the   public   also   were   able   to   speak   to   representatives   one-on-one.        This   session   clarified   the   process   that   these   entities   are   using   to   develop   a   more   detailed   and   specific   dust   control   program   work   plan, which   is   required   to   be   submitted   by   State   Parks   to   the   APCO   by   August   1,   2019.      Public   comments   received   by   the   APCD   by   May   15 may be addressed in an update to the PMRP.  The updated PMRP was approved by Gary Wiley on June 10. See the updated PMRP  and the letter of approval .   5.  Annual Report and Work Plan Development State   Parks   is   in   the   process   of   development   an   Annual   Report   and   Work   Plan,   which   is   due   to   be   submitted   to   the   APCO   and   SAG   by August   1,   2019.      An   important   aspect   of   this   is   preparing   and   Environmental   Impact   Report   (EIR),   as   required   by   the   California Environmental   Quality   Act   (CEQA).         On   June   17,   2019   State   Parks   issued   Notice   of   Preparation   for   a   Subsequent   EIR   and   a   public scoping   meeting   for   the   Oceano   Dunes   State   Vehicular   Recreation   Area   Dust   Control   Program   Particulate   Matter   Reduction   Plan.      The public   scoping   meeting   will   be   held   on   July   2,   6:00   to   8:00   p.m.   at   the   Ramona   Garden   Park   Center,   933   Ramona   Avenue,   Grover   Beach.     See the signed public notice. ================================================================================================================= See the   Clean Air Action Checklist for the status of actions required by the SOA and proposed by State Parks in the PMRP.

State Parks Proposed Public Works Plan

In   a   presentation   to   the   California   Coastal   Commission   on   September   14,   2018,   State   Parks   stated   its   intention   to   seek   a   new collaborative   approach   to   managing   the   Oceano   Dunes   SVRA   under   the   California   Coastal   Act.      The   current   Coastal   Development Permit   process   would   be   replaced   by   a   Public   Works   Program   (PWP).         State   Parks   again   promoted   this   approach   at   the   February   7, 2018   Commission   meeting.      The   PWP   would   give   State   Parks   broad   latitude   to   implement   changes   in   the   design   and   operation   of   the SVRA without project-by-project approval by the Coastal Commission. After   seeking   public   input   via   surveys   and   “listening”   meetings,   in   February   2019   State   Parks   conducted   open   meetings   in   Pismo   Beach and   Tulare   to   introduce   its   proposed   Public   Works   Plan   concepts   to   public.      Along   with   these   meetings,   State   Parks   published   an information   package   describing   its   concepts   and   options   for   the   future   of   the   SVRA.      (See   the   PWP   Project   Concepts   Public Meeting   Information   Packet ).      Public   comments   deadline   was   March   5,   however,   State   Parks   has   stated   to   media   that   is   will continue   to   accept   and   consider   public   comments   beyond   this   deadline.      The   next   step   will   be   for   State   Parks   to   prepare   a   preliminary draft PWP document. While   the   PWP   projects   being   considered   do   not   include   the   PM   reduction   actions   required   by   the   APCD   Stipulated   Abatement   Order, any   changes   to   SVRA   operations   has   potential   air   quality   impacts,   which   must   be   addressed   by   the   required   Environmental   Impact Rerport   (EIR)      Also,   PWP   projects   could   strain   State   Parks   apparently   limited   resources,   detracting   from   the   PM   reduction   efforts.      At the   same   time,   a   proposed   expansion   of   the   riding   area   may   give   State   Parks   greater   flexibility   in   implementing   PM   emission mitigation measures.

Nipomo Mesa - Concerned Citizens for Clean Air

Mesa Air Facts!

Concerned Citizens for Clean Air Suspends Wearing Red Shirts

The   leadership   of   Concerned   Citizens   for   Clean   Air   have   decided   to   suspend   encouraging   the   group’s   supportes   to   wear   red   shirts   to public   meetings.      The   wearing   of   red   shirts   was   started   to   demonstrate   to   officials,   the   press   and   the   public   that   the   group   has   many supporters,   and   that   we   care   deeply   about   getting   effective   dust   control   action   accomplished.      Instead,   the   group   will   provide   Clean Air buttons to peope who want to show their support at public meetings.  See Action page.

Coastal Commission to Hear Staff Report Calling for Major OHVRA Changes

The   California   Coastal   Commission   will   conduct   a   hearing   on   July   11   to   review   State   Parks   compliance   with   the   Coastal   Development Permit   (CDP)   that   allows   vehicle   access   to   the   Oceano   Dunes   Off   Highway   Vehicle   Recreation   Area.      Commission   staff   have   released   a report   highly   critical   of   State   Parks   failures   to   comply   with   the   current   CDP,   and   which   calls   for   major   changes   limiting   vehicle   use   on the dunes and requiring enhancements to environmental protections, including fugitive dust controls.  See the Staff Report  and the Action page call for concerned citizens to attend the CCC meeting.