Carol Sutkus-Manager

South Coast Air Quality Planning Section

California Air Resources Board

P.O. Box 2815

Sacramento, California  95812

Re: California Air Resources Board Meeting in Riverside to Consider the Ozone State Implementation Plan

Dear Ms. Sutkus:

 Please request the Board to consider the following late comment on the document:

 The California Air Resources Board’s Review of the Imperial County 2017 State Implementation Plan for the 2008 8-Hour Ozone Standard (report) dated September 22, 2017 discussed the nonattainment of the air quality 8-hour ozone standard of 75 part per billion due to the air transport of the contaminant across the border from Mexicali, Mexico.

 Under Section 179 B of the Clean Air Act consideration of the impact of transport of pollutants across international borders may be considered. At page 11 of the report, the Border Regional Emissions Inventories section states that stationary sources of reactive organic gases and nitrogen oxides shows significant percentages come from stationary sources. At page 12 the report,  the reasonably available control measures were only considered for emissions originating in Imperial County. Consistent with Section 179B of the Clean Air Act, please consider alternatives to reducing the levels of ozone precursor compounds from Mexicali including: cooperative solutions to upgrading the control equipment at stationary sources through funding and incentives to the companies with stationary sources. Also please consider offering incentives to owners of automobiles in Mexicali, Mexico for installation of emissions control systems.

 Sincerely yours, Tom Price-Director, Environmental Review, Inc. P.O. Box 2756, Berkeley, California  94702 www.envreview.org