2020 SVRA Dust Control Work Completed

After multiple revisions and resubmissions to the Scientific Advisory Group (SAG) and the SLO County Air Pollution Control Officer (APCO) the 2020 SVRA Annual Report and Work Plan was granted conditional approval on November 25, 2020 ( see the final approval letter ). The approved dust control work described in that plan was completed in April, 2021. This included the following: Converted 33 acres of previously temporary controls to permanent vegetation. Installed 26 acres of new straw/seed mix. Installed 66 acres of new temporary controls, including: o Five acres of new fenced temporary vehicle exclosure. o Twenty-eight acres of new fenced temporary straw mulch. o Thirty-three acres of new temporary wind fence. Of these 125 acres completed in April 2021, only 92 acres were new controls - the straw/seed mix and temporary wind fence, and of these, only 26 acres are new PERMANENT dust control measures. According to State Parks, as of July 1, this brings the total number of acres of dust controls installed to 323 acres. ==========================================================================================

State

Parks

Submits

Oceano

Dunes

SVRA

Dust

Control

Draft

2021

Annual

Report and Work Plan

On August 2, 2021, State Parks submitted a Draft Oceano Dunes State Vehicular Recreation Area (SVRA) Dust Control Program 2021 Annual Report and Work Plan (ARWP) to the SLO County Air Pollution Control District (APCD) . (See the draft ARWP.) This draft AWPR includes the following: A summary of dust control measures installed to date, including those installed between August 1, 2020 and July 31, 2021. Assessment of progress toward meeting particulate matter reduction goals established by the Stipulated Order of Abatement (SOA). A description of the dust controls proposed to be installed in the next 12 months (August 1, 2021 to July 31, 2022), including a draft implementation schedule. Dust Control Work Planned for the Next 12 Months State Parks proposes the following dust control work for the coming year: Install 90 acres of new, temporary dust control measures, including wind fencing, straw, and vehicle exclosure measures. Convert existing temporary dust control measures to permanent vegetation measures, including: o Approximately 20 acres of wind fencing that were installed in 2019. o Approximately 20 to 25 acres of straw measures that were installed in 2020; and o Up to approximately five acres of temporary vehicle exclosures that were installed in 2020. Continue foredune monitoring and assessment. Dune emissivity (PI-SWERL) sampling campaign. Supplemental vegetation planting in previous vegetation treatment areas (non-foredune only). Maintain existing wind fencing measures. Continue Dust Control Program field monitoring and air quality modeling activities. Continued SAG consultation, including updating the approach to evaluating SOA progress and requirements and facilitating adaptive management decisions based on monitoring results and assessment campaigns. Initiate a Dust Control Program public relations campaign in consultation with the SAG. Coordinate with the California Coastal Commission on 2021 ARWP permitting requirements. Continue Dust Control Program activities related to identifying other potential sources of dust and PM10 contributing to air quality conditions. Draft ARWP Review Process The Draft ARWP will be reviewed by the Scientific Advisory Group (SAG) and the Air Pollution Control Officer (APCO). The APCO may deem the work plan to be acceptable or require State Parks to make changes. The review and revise process may continue until October 1, after which the APCO may require State Parks to make the changes necessary for the work plan be acceptable. When APCO deems the work plan to be provisionally acceptable, a workshop will be held to obtain public comment before the work plan is finally approved. How Much Dust Control will be Enough? The Draft ARWP states that, based on computer modeling, the dust controls installed as of July 1 are estimated to reduce particulate matter mass emissions by 21%. The goal established by the Stipulated Order of Abatement (SOA) is a 50% decrease in mass emissions. At the time the SOA was issued, the State’s computer models showed that approximately 500 acres of dust control measures would be needed to achieve the 50% mass emissions reduction goal. The Draft ARWP states that as of July 1 a total of 323 acres of dust control measures have been installed. The estimated 21% mass reduction to date is only 42% of the way to the 50% reduction objective. However, the 323 acres of installed dust controls amounts to 65% of the 500 acres originally estimated needed. This data suggests more than 500 acres of dust controls may be needed to obtain 50% reduction goal if the effectiveness of those controls stays the same as those that have been installed so far. Either that, or the installed controls must be much more effective than those installed thus far. In the 2021 ARWP State Parks proposes only 90 acres of new dust controls in the coming year, all of which will be temporary measures. These controls are similar to those already have been installed. These 90 acres would bring the total dust control area to 413 acres by the end of July 1, 2022. The balance of necessary controls would be left to be installed in the final year of the current SOA. Given the time required for vegetated areas grow and become effective dust controls, and the apparent lower than originally modeled effectiveness of the measures installed to date, it appears highly unlikely that the dust controls proposed by State Parks this year will be sufficient to achieve the dust emission reductions required by the SOA. ==========================================================================================
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