On   April   30,   2018   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.      (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 (PRMP)   describing   how   the   requirements   of   the   SOA   will   be   accomplished.      The   SOA   was   a   compromise   agreement   arrived   at though   negotiations   between   Gary   Willey,   the   SLO   County   Air   Pollution   Control   Officer   (APCO)   for   SLO   County,   and   State Parks. SOA Events to Date: 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. 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 (PRMP) The   SOA   requires   State   Parks   to   prepare   a   Particulate   Matter   Reduction   Plan   (PRMP).      The   PRMP   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   PRMP   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   PRMP,   and   both   requested   various   changes   be   made   by   State   Parks.      On   March 28,   2019   State   Parks   submitted   a   revised   draft   PRMP.      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   PRMP   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   PRMP.      The   updated      Draft   PRMP   was   conditionally   approved by Gary Willey on June 10, 2019.  See the updated PRMP  and the letter of conditional approval . To   date,   none   of   the   conditions   listed   in   Gary   Willey’s   conditional   approval   of   the   Draft   PRMP   have   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   PRMP.      A   scoping   meeting   for   the   SEIR   for   the   PRMP   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 PRMP, but that document does not yet exist. 5.  Annual Report and Work Plan (ARWP) On August 1, 2019 State Parks submitted to the Gary Willey (APCO) and the Scientific Advisory Group (SAG) a draft Oceano Dunes State Vehicular Recreation Area Particulate Matter Reduction Plan 2019 Annual Report and Work Plan.  The Work Plan is required by the existing 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.   Since then State Parks has 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 a new Order of Abatement and issued a notice of public hearing on November 18 where the Hearing Board will consider the petition and take testimony and public comment.  Links to the public hearing notice, Gary Willey’s petition and the proposed Order of Abatement can be found on the APCD website Oceano Dunes Particulate Emissions Reduction Efforts page (click here).

Mesa Air Facts!

Concerned Citizens for Clean Air
See     the     Clean     Air     Action     Checklist     for     a progress   overview   of   actions   required   by   the SOA and proposed by State Parks in the PRMP.