Review the Current State of the
Drought, Potential Air Quality
Impacts, and Additional
Emergency Relief Actions that
the District May Need to Pursue
Governing Board Study Session
May 6 - 7, 2015
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• California is currently suffering through the worst
drought in recorded history
– Despite improved atmospheric conditions during 201415, precipitation still below average for much of the
Valley
– Snow pack levels at record low (6% of normal)
– State of Drought Emergency declared by Governor since
January 2014
– 100% of SJV is under “exceptional” drought conditions
– Federal and state surface water deliveries are at an alltime low, 0 to 20% allocation
– Mandatory 25% reduction in water usage by cities and
towns
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• Significant increase in fallowed land
– Approximately 500,000 acres fallowed in 2014
– Estimated 30 to 40% increase in 2015
– Potential “dust bowl” conditions
• Lack of water for dust control
– Water is significant dust control measure
– Potential for increased fugitive dust
• Increase chances of wildfires
– Potential for emissions to overwhelm Valley (2008)
• Increased well-water usage
– Increased use of internal combustion engines means
increase NOx emissions
• Drilling new and deeper wells
– Increased NOx from drilling and from new remote internal
combustion well pumps
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April & August of 2014, your Board directed the
District staff to implement targeted drought
relief measures
• Expedited permit processing for certain
drought relief projects, and mitigate
increased emissions through Voluntary
Emission Reduction Agreements
• Supported CEQA waivers for certain drought
relief projects, provided air impacts mitigated
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• Provided assistance to stakeholders
– Drought relief webpage
– Ag stakeholder meetings
– Compliance Assistance Bulletins
– Numerous direct meetings with farmers,
producers, water districts and other businesses
• Promote the use of less water intensive
Conservation Management Practices
– Developed, with stakeholders, comprehensive
CMP information packet
– Prepared to expedite CMP Plan modifications at
no charge
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• Expedited portable equipment registration
processing for certain drought relief projects
– Worked with ARB to clarify applicability and
interpretation of emergency provisions for portable
equipment under state rules
• Appropriated $500,000 from contingency funds
to mitigate air quality impacts from water well
drilling emergency drought projects
• Determine if additional actions by the District
are necessary or feasible with respect to the
following areas:
– Wildfires
– Fugitive dust regulations
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• Wildfires can generate tremendous
emissions and lead to exceedances of air
quality standards on the Valley floor
• Fuel loading levels of up to 600 tons per acre
– At these levels, wildfires pose significant threat to
public health
• Epidemic bark beetle infestations devastating
nearby forests
• Exceptional drought and tree mortality
associated with bark beetles have set the
stage for extreme wildfires
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• Coordination with land managers
– Evaluate prescribed fires, management of wildfires, and
hazard reduction burning
– Daily call with land managers, ARB staff, and fire
weather meteorologists
– Review fuels, geographic extent of fires, fire
management capabilities, and relevant atmospheric
conditions
• Actions during a wildfire
– Conduct field observations of smoke impacts
– Work with land managers to increase resources to limit
smoke impacts
– Work with land managers to deploy portable monitoring
equipment
– Issue Health Cautionary Statements and Air Quality
Alerts when wildfire impacts are severe
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• Untimely wildfire emissions can be reduced through
prescribed burning, pile burning, and hazard
reduction burning practices
• Consistent with the District’s Legislative Platform,
District staff will continue to work for:
– Additional resources for land managers to conduct
prescribed burning
– Additional resources to manage wildfires
– Lessoning or removal of contradictory environmental
protection policies that prohibit the of mechanized
methods or prescribed burning to reduce fuels
– Changes in federal policies that better incorporate air
quality concerns by shifting focus to prescribed burning
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• Water has been used for many years to
control dust in the Valley
• Control measures are necessary to limit
particulate matter emissions
• As mandatory water usage restrictions are
implemented, evaluation/promotion of less
water-intensive dust control measures is
necessary
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• Farmers required to employ Conservation
Management Practices (CMPs) to reduce
particulate matter emissions
• District worked with ag community to develop
less water-intensive measures (speed limits,
restricted access, other dust suppressants)
– 65% of unpaved roads and 69% of equipment
areas under CMPs employ non-water dust
control methods
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• Highly trafficked unpaved agricultural roads and
equipment areas must also comply Regulation
VIII
– More stringent requirements for visible dust and
surface stabilization
• Not all cost-effective, non-water CMP methods
are sufficient to ensure compliance with
Regulation VIII
• Regulation VIII allows for implementation of
Fugitive PM10 Management Plans
– In lieu of visible dust and surface stabilization
standards
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• Fugitive PM10 Management Plans (FPMP)
– Flexibility to implement less water intensive
measures (or a combination of measures) to
ensure compliance with Regulation VIII
– Not highly utilized
• Ramp up efforts to educate farmers and
promote less water intensive measures
• District will work with ag representatives to
develop additional alternative measures
through the FPMP process as necessary
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• Required to limit visible emissions and maintain
a stabilized surface under Regulation VIII
• Water is specifically required or is only feasible
measure under certain provisions
– Inconsistent with state’s water conservation goals
under the drought emergency
• Individual companies may pursue a variance to
allow temporary relief
– Approach may be inefficient
– Number of individual petitions may overwhelm
District Hearing Boards
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• Your Board may want to consider directing
Executive Director/APCO to:
– Pursue class action variance
– Exercise enforcement discretion during drought
emergency
– Explore feasibility of developing “Emergencies”
rule
• Suspend certain rules during a declared state of
emergency
– Explore feasibility of amendments to Regulation
VIII
• Exemptions for drought emergencies
• Expand the allowable use of FPMPs
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• Remedies may lead to increased particulate
matter emissions
• Consider limiting temporary relief to driest
summer months
– Limit emissions to the non-peak particulate
season (Nov – Feb)
• Could be supplemented by safeguards such
as pre-authorization
• District would need to consult with EPA
– Rules are federally enforceable under attainment
plans
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