Summary SOA History 1. Dust Control Measures Implemented in 2018 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 emissions reduction. 2. Install Sand Track-Out Control Devices The SOA required State Parks to install sand track-out devices at the Grand and Pier Avenue park entrances by June 30, 2019. After initially informing the APCD that it could not meet the June 30 deadline for a permanent track-out device installation, State Parks did install temporary track-out devices. It is not clear if or when the requirement will actually be met. 3. Establish A Scientific Advisory Group (SAG ) The SOA required State Parks to establish a Scientific Advisory Group (SAG), which will evaluate, assess and provide recommendations on mitigation 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 (PMRP) 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 PMRP on February 1, 2019, as required by the SOA. This draft was reviewed by the APCO and the SAG, and on February 25, 2019 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, 2019 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 PMRP is intended to define 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 August 1 of each year. These annual work plans are subject to public review each year before the being approved by the APCO. The APCD, SAG and State Parks held a public workshop on May 1, 2019 where representatives of the entities made presentations and addressed questions 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. Public comments received by the APCD by May 15, 2019 were to be addressed the final PMRP. The updated Draft PMRP was conditionally approved by Gary Willey on June 10, 2019. See the updated PMRP and the letter of conditional approval . To date, none of the conditions listed in Gary Willey’s conditional approval of the Draft PMRP has been met. With regard to compliance with the California Environmental Quality Act (CEQA), State Parks issued on June 17, 2019 a Notice of Preparation (NOP) for a Subsequent EIR for the PMRP. A scoping meeting for the SEIR for the PMRP was held on July 2, 2019 at the Ramona Garden Park Center in Grover Beach. State Parks promised expedited preparation of a draft SEIR for circulation and public comment, but no draft SEIR has yet been published. Under the terms of the Stipulated Order of Abatement, submission of Annual Reports and Work Plans presumes the existence of an approved, final PMRP, but that document does not yet exist. 5. 2020 Work Plan On August 1, 2019, State Parks submitted to the Gary Willey (APCO) and the Scientific Advisory Group (SAG) a draft ODSVRA 2020 Work Plan. Annual Work Plans were required by the original Stipulated Order of Abatement (SOA) to describe in detail the measures 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 the SAG before making this submission. On August 26 the APCO requested that State Parks make certain revisions to address concerns raised by the SAG. State Parks submitted two revised Work Plans and both were found by the APCO and SAG to be deficient with respect to the requirements of the SOA and the dust control measures the SAG considers essential to achieving the required PM emissions reduction. As a consequence, on November 1 Gary Willey submitted a petition to the APCD Hearing Board requesting an Amended Order of Abatement. On November 18 the Hearing Board considered the petition and took testimony from State Parks, the APCO and the public. An Amended Stipulated Order of Abatement was approved. Since then State Parks has prepared a revised 2020 Work Plan compliant with the Amended SOA, which was accepted by the APCO. The dust controls described in that plan have been completed. 6. 2021 Work Plan On September 5, 2020, the APCD announced that State Parks provided the 2020 Draft ARWP. Based on Scientific Advisory Committee and SLO County APCD review of the first draft, the ARWP was deemed not acceptable in its current form.