The Bay Area Air Quality Management District (BAAQMD) is accepting comments on its recently released draft Community Emissions Reduction Plan (CERP) for the Richmond, North Richmond, and San Pablo communities, also known as the Path to Clean Air (PTCA) Area. The CERP has been prepared to address California Assembly Bill 617 requirements, for which the PTCA is a selected Community Air Protection Program (CAPP) community. The BAAQMD and members of the PTCA have identified five key areas of concern related to air quality and have provided strategies for addressing each in the draft CERP. In addition to accepting public comments through January 19, 2024, BAAQMD will also host a public workshop on January 11, 2024, via web stream. Many identified key issues of concern and proposed action items to address them are detailed below.
Commercial and Industrial Sources Near Community
Large industrial facilities as well as smaller industrial and commercial sources are addressed under this area of concern. This key statement targets both PM exposure and cumulative impacts from local facilities. Proposed strategies to address concerns include:
- Implementing best management practices for reducing fine particulate matter;
- Incorporating environmental justice (EJ) principles into permitting;
- Reducing exposure from food preparation through white paper approaches;
- Implementing Rule 11-18 expeditiously; and
- Determining measures to reduce localized exposure from backup generators.
Fuel Refining, Support Facilities, Storage and Distribution
This key statement targets the fuel refining sector as being the largest source of emissions in the PTCA, the lack of accountability with Air District Regulations, persistent flaring conditions, as well as achieving a just transition, or an inclusive economy that is fair to all community members and workers. Proposed strategies to address concerns discussed in this area include:
- Incorporating just transition principles into the final PTCA plan;
- Reducing flaring events to the to the lowest levels possible;
- Improving community communications surrounding major incidents and flaring;
- Strengthening the Industrial Safety Ordinance (ISO);
- Implementing standardized inspection and monitoring protocols of the Chevron Richmond Refinery;
- Prioritizing improvement and implementation of BAAQMD Rule 11-18; and
- Implementing BAAQMD Rule 6-5.
Marine and Rail
The Marine and Rail (M&R) community is addressed in the CERP as it results in harmful emissions, such as diesel particulate matter (DPM). The key areas targeted under this area of concern are cancer risk, older equipment, and pollution sources present during operations at M&R hubs, such as ports or terminals. Strategies proposed in the CERP include:
- Regulating and enforcing emissions reductions from Rail, ocean going vessels (OGVs), commercial harbor craft (CHC), cargo handling equipment (CHE); and
- Regulating emissions reductions from Cumulative Impact Facilities and Operations.
Vehicles and Trucks, Streets and Freeways, Warehouses and Logistics
Mobile sources such as truck and non-truck emissions produce a significant amount of air pollution in the PTCA community and is thus addressed in the draft CERP. Key issues identified include goods movement, truck and non-truck vehicle emissions, streets, and freeways. Proposed strategies include the following:
- Modeling and mapping freight activity in the PTCA area;
- Modeling Policy/Ordinance for low to zero emission operations;
- Developing and proposing criteria for safety improvements and air quality projects;
- Preparing an initial feasibility and needs analysis for developing a Truck Management Plan;
- Conducting a street sweeping study and implementing an enhanced Street Sweeping Program; and
- Enforcing CARB’s clean fleet regulations.
The CERP calls on agencies such as BAAQMD, California Air Resources Board (CARB), County of Contra Costa, and the cities of Richmond and San Pablo for assistance in implementing the plan. The CERP has identified mechanisms for implementation such as creating incentives, rule development, and stricter rule enforcement. The PTCA community members and BAAQMD staff are developing an annual implementation plan for achieving the above strategies for emissions reductions. Additionally, there will be an annual analysis of plan implementation progress and identification of challenges that may be inhibiting progress towards the CERP’s goals.
Interested parties can find more information about the draft CERP on BAAQMD’s website. If you would like to discuss the draft CERP and how it may impact your facility, please contact Trinity’s Oakland office or call 510.285.6351.
