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.
WHAT’S HOT:
Coastal Commission to
Conduct Oceano Dunes
OHVRA CDP
Compliance Hearing at
Next Meeting, Critical
Staff Report Calls for
Major Changes in
OHVRA Operatons
State Parks Progress
on Compliance with
Dust Reduction SOA.
See the CLEAN AIR
ACTION CHECKLIST for
an Overview of PM
Reduction Action
Status
Concerned Citizens for
Clean Air suspends
wearing red shirts to
public meetings while
SP and APCO are
making good faith
efforts.
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.
COMING UP:
California Coastal
Commission Meeting
July 10-12 in at
Embassy Suites
Hotel, 333 Madonna
Road, San Luis
Obispo
State Parks to
Submit Annual
Report and Work
Plan by August 1,
2019.
State Parks Dust
Controls EIR Public
Scoping Meeting,
July 2 in Grover
Beach Ramona
Garden Park Center
