Comments Provided to the California Air Resources Board on the Proposed Fiscal Year 2017-18 Funding Plan for Clean Transportation Incentives describing allocations for $663,640,000 dated 12-11-17

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 From: Thomas Price <This email address is being protected from spambots. You need JavaScript enabled to view it.> 12-11-17 at 6:00 AM To:   This email address is being protected from spambots. You need JavaScript enabled to view it.

 Clerk of the Board

California Air Resources Board 

1001 I Street

Sacramento, California  95814

 

Re: California Air Resources Board Proposed Fiscal Year 2017-18 Funding Plan for Clean Transportation Incentives describing allocations for $663,640,000 dated 11-9-17, Public Comments Due 12-11-17

 

Dear Board Members: 

 

Environmental Review, Inc. has reviewed excerpts of the Plan and has the following comments:

 

Appendix A Emissions Reductions: Quantification Methodology – Figure A entitled “Largest NOx Emissions Sources in the South Coast and San Joaquin Valley Air Basins” but failed to consider air pollutant emissions from cars and trucks form Mexico which impact those areas.

 

 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 impacting air quality in Imperial County. Under Section 179 B of the Clean Air Act consideration of the impact of transport of pollutants across international borders may be considered.

 

The Proposed Fiscal Year 2017-18 Funding Plan for Clean Transportation Incentives dated 11-9-17 should also consider for emissions originating in Mexico (e.g. Tijuana, Mexicali) consistent with Section 179B of the Clean Air Act, and consider alternatives to reducing the levels of ozone precursor compounds from Mexico including offering incentives to owners of automobiles in Mexico for installation of emissions control systems. This topic should be incorporated in all other sections of the Plan including the Proposed Funding Allocations section.

 

Sincerely yours, Tom Price-Program Mgr., Environmental Review, Inc. 1792 Rogers Ave, San Jose, California  95112 www.envreview.org