Placer County
Air Pollution Control District
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District Overview
2017 Annual Report
MISSION
The Placer County Air Pollution Control District’s (District) mission is to
manage the County’s air quality in a manner to protect and promote public health
by controlling and seeking reductions of air pollutants while
recognizing and considering the economic and environmental impacts
History
 1970—District formed as a division of the Placer County
Health Department.
ORGANIZATION
 1988/1990—Implementation of California Clean Air Act of
1988 and Federal Clean Air Act amendments of 1990. District’s
focus expands from criteria pollutants—products of combustion,
particulate matter, and lead—to airborne toxic contaminants.
The District is governed by a
Board of Directors composed
of three County Board of
Supervisors and one elected
official from each of the six
County incorporated municipalities:
 1994—District became a separate County Department. The
Board of Supervisors comprised the District’s Governing Board.
 1997—District became a special district with city
representatives joining three County Supervisors on the
District’s Governing Board.
 2006—District efforts expand to include reducing greenhouse
gas pollutants to the atmosphere as directed under Assembly
Bill (AB) 32.
 Auburn
 Colfax
 Lincoln
 Loomis
 Rocklin
 2011—District purchased office building at 110 Maple Street,
Auburn, across from the Historic Placer County Courthouse.
 Roseville
Budget
The District’s Board appoints
the Air Pollution Control
Officer (APCO).
The District’s current annual budget is approximately $4.5
million, and includes over $900,000 in carry over funds each
fiscal year. Most District funding comes from a surcharge
imposed by the Department of Motor Vehicles to support
District activities, along with emission and equipment fees
assessed on permitted facilities. The District’s activities are
programmed into five separate funds depending on the revenue
source. Each fund has its own revenue and expenditure
accounts. The District’s philosophy of budgeting revenues
conservatively and expenditures adequately has allowed the
District to meet its current fiscal needs and provide funding for
beginning the upcoming fiscal year, without implementing any
cross-the-board permit fee increases since 1998.
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The District employs 19 full
and part-time employees, and
is
organized
into
four
operating sections:
 Administrative Services
 Planning & Monitoring
 Compliance & Enforcement
 Permitting & Engineering
District Overview
2017 Annual Report
The Placer County Region is
Diverse and Varied
What is the Role of the District in
Achieving Clean Air Standards?
The
District’s
jurisdiction
includes
six
incorporated municipalities, and Placer County
is a diverse and rich area, spanning many diverse
areas. These include:
 Suburban areas in the southern portion of the
County, such as Roseville, Rocklin and
Lincoln, Loomis and Granite Bay;
 Rural farming and oak lands in the northern
and western portion of the County;
 Mountain communities on the western slope
of the Sierra such as Auburn, Colfax, and
Foresthill;
 Nearly 560,000 acres of public and private
forested land east of Colfax to the Nevada
state line; and
 The diversity of Lake Tahoe’s northern and
western shores.
Regulation, Enforcement, Advocacy
Placer County
Air Quality Plans
In 1970, Placer County had a population of 78,280
and was largely rural, with agriculture and a few
large businesses and government facilities
supporting the economy. Today the population is
nearly 350,000, with diverse employers such as
Hewlett-Packard and Sierra Pacific Industries,
along with a large number of service and IT sector
companies. Because of the geographic and
economic diversity in Placer County, the District
employs a variety of strategies intended to reduce
emissions of air pollutants.
The District is one of 35 local air pollution
control agencies in California. Local air
districts are charged with the enforcement of
local air pollution control rules that have been
adopted by each district’s Board of Directors, as
well as certain state and federal air quality
requirements. The primary duty of the local air
districts is the regulation and control of air
pollution created by industry and businesses,
while mobile sources are the responsibility of
the State Air Resources Board (ARB). Local air
districts permit the control of air pollution by
businesses,
regulating
open
burning,
responding to odor and dust complaints, and
encouraging the reduction of emissions in
areas that are not regulated directly.
Districts are also responsible for preparing,
adopting, and implementing air quality plans
that seek to achieve and maintain state and
federal air quality standards. These plans
include the commitment to implement
measures in order to meet federal and state air
quality standards. In addition, local air districts
usually act as a commenting agency under the
California Environmental Quality Act (CEQA)
with respect to land use projects.
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District Overview
2017 Annual Report
Where Does Air Pollution Come from?
Air pollution comes from many different “sources”. This includes larger stationary sources, such as power
plants and boilers, and smaller sources such as dry cleaners and gas stations. Even small emission sources,
such as the use of consumer products and paints at home, have an impact. However, in Placer County, the
vast majority of emissions come from mobile sources, such as cars, trucks, and trains. One of the District’s
primary responsibilities is to regulate emissions of combustion pollutants, dust, and toxic compounds that
are discharged to the atmosphere .
ROG Emissions (20 tpd)*
Consumer
Products/
Paints
30%
On-road
Mobile
17%
NOx Emissions (21 tpd)*
Residential
Heating 5%
On-road
Mobile
48%
Stationary
Sources
28%
Off-road
Mobile
25%
Stationary
Sources
21%
District
Permit
24%
Off-road
Mobile
26%
District
Permit**
11%
Ozone Pollution
The District meets all federal ambient air quality standards, with the exception of ozone (summertime
smog). Ozone (O3) is produced through the reaction in the atmosphere of oxides of nitrogen (NOx), and
reactive organic gases (ROG), also called Volatile Organic Compounds (VOC), along with sunlight.
Typically, ozone exceedances of federal air quality standards occur during long stretches of hot stagnant
days. Emissions from all Placer County emission sources, as well as emissions that blow in from other
parts of the State, contribute to the County not meeting federal air quality standards for ozone.
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District Overview
2017 Annual Report
How Does the District Reduce
Emissions?
The District utilizes many strategies to reduce
emissions. These include:
 Issuing operating permits for commercial or
manufacturing operations, as required under
federal and state law;
Measuring Air Quality
The District operates four official monitors in the
County to measure air quality on a 24-hour basis.
These monitors, combined with one operated by
ARB, provide valuable real-time information on
the “State of the Air.” Current air quality
information can be found on the District’s
website at www.placerair.org
 Responding to resident complaints of air
pollutant nuisances and odors;
 Concurrent compliance activities to ensure
expected emission reductions and provide a
“level playing field” for businesses;
 Developing and implementing cost-effective
regulations to reduce emissions;
 Providing incentives to local businesses to
acquire cleaner equipment and vehicles;
District’s Tahoe City Air Monitoring Station
 Working with local jurisdictions to minimize
impacts of land use decisions; and
 Working with federal, state and regional
partners to ensure that sources of air
pollution from other areas that impact Placer
County are reduced.
In implementing these strategies, the District
continually seeks to minimize the regulatory
burden on business and industry. The District
has also sought to level the regulatory field by
developing regulations that are consistent with
those of neighboring air districts, and through
even-handed enforcement.
The monitors, along with who operates them, are:
 Lincoln (District)
 Roseville (ARB)
 Auburn (District)
 Colfax (District)
 Tahoe City (District)
In addition, the District deploys additional
mobile monitors during periods of exceptional
events, such as wildfires, to inform the public and
public health officials on local air quality readings
and potential impacts on residents and first
responders.
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District Accomplishments
District Accomplishments
2017Annual
AnnualReport
Report
2017
District Accomplishments
The District has a long legacy of successful air quality efforts
Since its inception, the District has successfully implemented a number of actions and initiatives to
reduce emissions in Placer County, meet air quality standards, and improve public health for all
residents. Many of the programs that are in place today are a result of work that has occurred over
the last decade to continue to improve air quality and provide a better quality of life to those who
live and recreate in Placer County.
Forestry Initiatives
Rail Yard Emissions
The District continues to
initiate a number of
studies and programs to
better understand the
emissions and greenhouse
gas impacts of wildfires,
open pile burning, and
prescribed fires in Placer
County. These impacts
were recently exacerbated
by the epidemic of tree
mortality, caused by the
combination of prolonged
drought and bark beetle
infestation, making the
occurrence
of
more
frequent and severe wildfires
more likely.
In partnership with the District, Union
Pacific has undertaken a number of
strategies to reduce toxic diesel particulate
emissions at the J.R. Davis Rail Yard in
Roseville by 25 percent, relative to 2004
levels. Known as the “Western States Hub”,
the J.R. Davis Yard was considerably
expanded in the wake of Union Pacific’s
merger with Southern Pacific Railroad, and
is now the largest classification rail yard
west of the Mississippi River.
In the last decade alone, the frequency and intensity of
wildfires have caused over 100,000 acres to burn, about
20% of the forested lands in the County. To address
this, the District is working with forest land managers
on prescribed burning, and has an interest in
promoting feasible alternatives such as biomass to
energy, renewable fuels, and biochar. The District has
teamed with other public and private stakeholders to
implement
economically
self-sustaining
forest
management activities, which restore the forest land to
a fire-resilient condition, and will help reduce criteria
pollutant and greenhouse gas emissions.
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District Accomplishments
2017 Annual Report
Successful Incentive Programs
Sustainability Efforts
Clean Air Grants (CAG)
The District has made significant efforts towards
sustainability of the District’s operations,
through a reduction of energy usage overall and
more reliance upon electricity than fossil fuels
(i.e. gasoline). Prior to moving into the 110
Maple Street offices in 2011, insulation
improvements were made; two main heating,
ventilation and air conditioning units were
replaced with higher more energy efficient ones;
higher efficiency lighting was installed; and the
conventional tank water heater was replaced by
an on-demand heater.
The District has an extremely successful Clean
Air Grant incentive program that continues to
reduce criteria pollutants from unregulated
activities and sources. Since 2001, approximately
$17.4 million has been invested locally on
emission reducing projects, which have resulted
in a total of 1,172 tons of NOx, ROG and PM
reductions.
Since that time, the District has installed a solar
voltaic system which produces 63% of the
building’s annual power usage, and deployed a
District vehicle fleet that includes two hybrid
vehicles—Toyota Prius and Honda Civic.
District CAG Program Funded Truck
Woodstove Incentive Program
Since 2008, the District has offered incentives
for the replacement of older non-certified
woodstoves with cleaner burning alternatives.
In total, 415 non-certified stoves have been
replaced throughout the County, resulting in
reductions of 8.5 tons per year of particulate
matter (PM) emissions, which has helped the
region meet ambient PM standards and reduce
the local impacts of wood smoke.
Solar Panels at District Office at 110 Maple Street, Auburn
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2016: Building on Progress
2017 Annual Report
2016: Building on Progress
2016 was a busy and successful year for the District. District staff continued working and advocating
on biomass and forest resiliency issues, made continued progress on reducing air pollution emissions
throughout the County as well continued to update the District’s regulatory program and streamline
operations and improve sustainability.
Revising CEQA Project Review Policy
Updating District Regulations
The District Board approved a new policy
regarding how staff will review land use projects
under CEQA. The policy contains two
components, including revised thresholds of
significance for criteria pollutants and new first of
their kind thresholds for GHG emissions, as well
as new policy direction that will better ensure
consistency and transparency in staff’s reviews
and recommendations.
In 2016, the District Board, in keeping with the
statutorily required 2016 Regulatory Measures
List, amended two existing rules and rescinded
two other rules that are no longer required. These
amendments were needed to address comments
from the U.S. Environmental Protection Agency
(U.S. EPA) so that the amended rules would be
State Implementation Plan (SIP) approvable, and
to remove obsolete requirements and references.
Tracking Air Quality
These changes will assist lead agencies in
preparing
legally
adequate
environmental
documents with professional analyses, to address
potential air quality impacts from land use
projects, and ensure that any environmental
mitigation efforts focus on achieving local
benefits.
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District staff worked with ARB and the other
local air districts in the Sacramento region to
certify ambient 2015 Ozone and fine particulate
(PM2.5) monitoring data. The data certification
process confirmed that the Sacramento Region
attains the federal 1997 8-hour Ozone standard
and 2006 PM2.5 daily average standard, based on
the data from the latest three year period (20132015). In addition, several training sessions for
monitoring staff were budgeted in order to
maintain and continue enhancing the District’s
air monitoring program.
2016: Building on Progress
2017 Annual Report
Continuing Efforts on Biomass and Forest Resiliency
In 2016, the District continued to make significant progress on our numerous forest sustainability,
resiliency and biomass energy initiatives that reduce air pollution through:
 Utilization of forest wastes for energy or biochar as an alternative to open burning;
 Better quantification of the emissions associated with open pile burning;
 Fostering cooperative efforts with private and public technology providers, land managers, state
agencies and academia;
 Hazardous fuel reduction thinning and defensible space clearing to mitigate the size and severity of
wildfire, including participation on the State and County Tree Mortality Task Forces; and
 Development of tools that quantify and provide monetary value to air emission reductions, while also
offering other societal benefits such as renewable energy; reduced fire-fighting costs; and protection
of upland watersheds, timber resources, forest ecosystems, and wildlife habitat.
Forest After Fuel Reduction Treatment
Forest without Fuel Reduction Treatment
The District also worked with our numerous partners and others on the successful approval of key
legislation that includes:
 Better enabling small biomass facilities to interconnect with investor owned utilities in Senate Bill (SB)
840;
 Addressing electricity interconnection issues for small biomass projects through SB 850;
 Requiring the procurement of 125 megawatts (MW) of bioenergy derived from dead and dying trees
under SB 859, which directly benefited the continued operation of the Rio Bravo bioenergy facility in
Lincoln through a new five year contract for 24 MW of procurement by SCE; and
 The inclusion in SB 830 of $25 million for the State’s Healthy Forest program.
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2016: Building on Progress
2017 Annual Report
Providing Local Investments in
Cleaner Technologies
Efficient Permitting
PLACER COUNTY AIR POLLUTION CONTROL PERMITTED FACILITIES
The District Board approved over $1 million in
grant funding for 14 clean air projects to
private and public fleets in the County.
Through these investments, staff estimates a
total of over 14 tons of NOx, ROG, and PM will
be reduced annually over the life of the
projects. The District is also currently in its
third year of implementing a woodstove
program in the Lake Tahoe region on behalf of
the Tahoe Regional Planning Agency. The goal
of this program is to replace older non-certified
woodstoves with cleaner burning alternatives.
In 2016, 32 vouchers were issued to qualified
applicants, and 26 were redeemed for new
cleaner stoves.
NUMBER OF FACILITIES
250
200
150
100
CITIES AND UNINCORPORATED AREA
Ensuring Compliance and
Responding to Complaints
District staff continued to implement an
effective and fair enforcement and resident
complaint resolution program. Over 130 citizen
complaints were investigated, half concerning
burning, and the remainder equally from odors,
dust, and other miscellaneous causes. In
addition, over 140 violation notices were issued,
and $111,000 in penalties collected, primarily
through mutual negotiated settlement with
violations. Further, over 600 facilities were
inspected, with no backlog in inspections
remaining, and over 40 emission source tests
were observed. These activities are critical to
ensure that expected emission reductions from
the District’s programs are realized, and that
there is a level playing field for compliance
among regulated and permitted sources in the
County.
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UNINCORPORATED
ROSEVILLE
ROCKLIN
LOOMIS
LINCOLN
COLFAX
0
AUBURN
50
As prescribed under federal and state law, the
District successfully implemented its permitting
requirements through the issuance of 1318
operating permits in FY 15-16. These permits were
issued to nearly 800 facilities in Placer County. Of
these facilities, five facilities are required to have
five-year federal operating permits, commonly
known as “Title V” permits, under the
requirements of the Federal Clean Air Act. In
2016, one Title V permit required renewal.
Permitted Facilities Inspections
2016: Building on Progress
2017 Annual Report
Continuing to Improve Sustainability
and Improve Efficiency
Representing the District at the
State and Federal Level
The District completed several efforts to improve its
sustainability, consistent with its long track record
of success. This included the installation of two
plug-in electric vehicle DC fast charging stations at
the District office, coupled with the purchase of a
new plug in hybrid electric vehicle, a 2017 Chevy
Volt.
The District has a long history of engaging in
policy discussions and advocacy at the federal
and state level, and 2016 was no exception.
This included:
 District staff participation in the Sacramento
Region’s annual “Cap-to-Cap” advocacy
delegation, which included discussions with
congressional staff and federal agencies on
air quality, wildfire, and forest resiliency
topics.
 The District’s selection
The vehicle replacement was coordinated with the
retirement of two older, less fuel efficient vehicles
from the District fleet.
Staff also began the
replacement of halogen lighting in the District
offices with low-energy LED lights.
To improve efficiency, staff completed a Capital
Facility Five Year Maintenance Plan which consists
of a schedule of required long term maintenance for
the building exterior, parking lot, roof and interior
flooring. A long-term vehicle replacement fleet
management schedule was also developed. District
staff also initiated an organization and resource
assessment, including a review of the District’s
mission objectives and the alignment of resources,
as well as the availability of funding and staff to do
the work needed.
Finally, much effort was given to commencing work
on creating unique branding of the District’s
website and implementing a new web address—
www.placerair.org, as well as beginning work on
developing a new permitting, enforcement and
complaint portal for staff and citizens to replace an
older system that is reaching the end of its useful
life.
to co-chair the
Mobile Source and Fuels Committee of the
National Association of Clean Air
Agencies, which provides a unique
opportunity to engage nationally on mobile
source issues that disproportionally impact
emissions and air quality in Placer County.
 The District’s election to the Secretary and
Chief Financial Officer positions for
CAPCOA, in addition to membership on
their Board of Directors and on their Climate
Protection Committee.
 The District’s selection to serve on the
Steering Committee of the Capital Region
Climate Readiness Collaborative.
These assignments provide both an influential
venue for the District’s priorities to be
considered in statewide policies affecting air
quality and incentive funding, as well as unique
opportunities to help shape the efforts of local
jurisdictions throughout the region on climate
adaptation and policies.
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Looking Ahead to 2017
2017 Annual Report
Looking Ahead to 2017
2017 is expected to be another productive year, with several new efforts planned and a significant
amount of work expected in order to continue building on the successes of 2016.
Forest Resiliency and Biomass Energy Efforts will Remain a Priority
The District will continue to be a recognized world-wide leader in advancing forest and
biomass efforts in 2017, with goals to:
 Approve a fuel thinning offset protocol into a voluntary GHG Offset Exchange, with the
long-term goal of seeking approval of a compliance grade offset protocol approved by the
ARB for use in the State’s Cap and Trade Program;
 Comprehensively characterize black carbon emissions from open pile burning and forest
and ag wastes, and develop a black carbon offset protocol;
 Finalize cooperative work with technology providers demonstrating the emissions from
biomass gasification/internal combustion engine systems;
 Coordinate biochar GHG offset projects through the CAPCOA GHG Exchange;
 Assist the County and local jurisdictions in developing proposals for the use of State forest
resiliency funds, and seek additional state and local funding for such efforts;
 Participate and contribute technical expertise to forest restoration working groups; and
 Advocate for, develop, and implement state legislation that values the wide range of
societal benefits of forest restoration and distributed biomass energy activities,
particularly focusing on the California Forest Carbon Plan, released in January 2017.
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Looking Ahead to 2017
2017 Annual Report
Implement New State and Federal Regulations
In 2017, District staff plan to begin implementing several new state and federal regulations that were
approved in 2016.
 The California Air Pollution Control Officer’s Association (CAPCOA) updated their Air Toxics “Hot
Spots” Program Public Notification Guidelines (Guidelines). The District plans to adopt a new policy to
follow these Guidelines because a recent change in health risk analysis methods resulted in 3-4 times
higher risk levels than previous methods. Thus, the air toxic thresholds at which a risk is considered
significant, and at which public notification is required, will be exceeded more frequently.
 Revisions were made by U.S. EPA to Clean Air Act permitting program public notice regulations so that
the posting of notice announcements may take place on an agency’s webpage (eNoticing), in place of
the traditional publication of public notices in a newspaper of general circulation. Several existing
District rules need to be amended to implement the new eNoticing regulations.
 U.S. EPA adopted a revision to its standards for solid waste landfills and emission guidelines to control
greenhouse gas emissions which will impact Placer County’s Western Regional Sanitary Landfill
(WRSL), and possibly the gas collection system of the Eastern Regional Sanitary Landfill (ERSL).
District Staff are working closely with CAPCOA and ARB to better understand any new requirements,
and to align existing state requirements and District rules with the new U.S. EPA requirements.
Plans for meeting Federal Ambient
Air Quality Standards
Continue to Improve Efficiency and
Modernize District Operations
District staff will continue working with ARB and
other local air districts in the Sacramento Region
to
finalize
the
regional
ozone
State
Implementation Plan (SIP) documents for the
federal 2008 8-hour Ozone standard. The District
anticipates releasing the draft SIP for public
review in early 2017 and submitting it to the
District Board for approval in 2017.
In the upcoming 2017-18 fiscal year, District
management will continue to evaluate its
functions to better maximize the air quality and
economic benefits to Placer County residents and
businesses. District management will align this
work with existing and required staff and contract
resources to determine what work can be done,
and where additional resources are required.
Staff also plan to revise the existing PM2.5
attainment implementation/maintenance plan
which was suspended by U.S. EPA for review. The
latest three-year monitoring data (2013-2015) has
demonstrated that the Sacramento region attains
the federal 2006 PM2.5 daily average standard.
The existing plan will be updated, based on the
latest three-year data and control strategies, to
demonstrate that the Sacramento Region can
remain in attainment of the federal PM2.5
standard. The revised plan is anticipated to be
submitted to the Board for approval in late 2017.
On the fiscal side, management will continually
evaluate work and available resources against
available funding sources, to determine if funds
are being utilized effectively and whether funds
should be re-directed to support high priority
projects. This will include evaluating core District
functions, the ability to effectively recover District
implementation costs, and where appropriate,
identifying additional revenue options. Finally, an
update to the District organizational structure will
be considered, to accommodate succession
planning, as well as ongoing and future goals.
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Looking Ahead to 2017
2017 Annual Report
Implementing the District’s New
CEQA Policies
Continue to Incentivize the
Deployment of Cleaner Vehicles
and Woodstoves
The District will continue to support the
investment of incentive funding to local fleets
and vehicle operators to achieve voluntary
emission reductions from mobile sources
throughout the County. Implementing the
program, which is estimated to provide an
estimated $840,000 for fiscal year 2016-17, will
include a robust outreach effort that includes
both print and online advertising, emails to fleet
operators, and public workshops. The grant
application acceptance period is open through
February 24, 2017.
The District will update its CEQA Handbook in
2017 to incorporate the policy changes and
significance thresholds previously approved by
the Board. Working cooperatively with
stakeholders, project proponents and local
jurisdictions, the update will incorporate a
number of changes, including:
 Components of the District’s adopted CEQA
Review Policy;
 Recent updates of CEQA guidance, protocols,
and reports;
 Computer emission modeling revisions;
 Updates to address court findings regarding
CEQA project litigation;
 “User-friendly” content that readers can
understand;
 Information that practitioners can use in the
preparation of analyses.
In addition, staff will work with local
jurisdictions on the development of qualified
Climate Action Plans to assist with their review
and approval of local land use projects.
Ensuring CEQA Compliance in the
District’s Permit Program
The District is also working with CAPCOA on
potential new statewide funding for a woodstove
exchange program. This statewide program is
funded by California Greenhouse Gas Reduction
Funding and is anticipated to be launched in
2017 when the program’s administrative
guidance is finalized by ARB. If the
implementation guidelines of the potential
program meets the needs of County residents,
this program can provide new funding for
upgrading non-certified woodstoves in rural
areas.
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Recently, other air districts in California were
sued for issuing permits that were allegedly
discretionary, rather than ministerial, which put
into question how those Districts handled
CEQA review of those projects. In 2016, District
staff have better defined the District’s program
for compliance with CEQA in the permitting of
stationary sources, with a thorough legal review
of the template permits and associated
processes. District Counsel has confirmed that
most permit evaluations and approval
determinations are ministerial, and is finishing
up a process for handling non-ministerial
projects when they occur.
Looking Ahead to 2017
2017 Annual Report
Effectively Engaging the State on Climate Policy and Planning
Since 2006, The Legislature has approved and the Governor has signed a number of key climate bills
that direct the State’s efforts to address climate change. These include, but are not limited to:
 AB/SB 32 which, combined, will reduce statewide GHG emissions by 40% from 1990 levels by 2030;
and
 SB 605/SB 1383 which together identify short lived climate pollutants such as black carbon and
methane, and establish 2030 emission reduction targets.
To implement the first two of these bills, the State is required to regularly develop, update and
implement a number of planning documents. These include the ARB’s AB/SB 32 Scoping Plan, and its
SB 1383 Short Lived Climate Pollutant (SLCP) Plan. In December 2016, ARB released its draft SLCP
Plan, and its draft Scoping Plan in January 2017. District staff, along with our partner stakeholders, are
actively engaged with ARB on the development of these plans, both of which are expected to be
approved in 2017.
SLCP Plan
Short-lived climate pollutants are powerful climate forcers that remain in the atmosphere for a much
shorter period of time than longer-lived climate pollutants, such as carbon dioxide (CO2). Their
relative potency, when measured in terms of how they heat the atmosphere, can be tens, hundreds, or
even thousands of times greater than that of CO2. While recognizing the significant contribution of
black carbon from wildfires, in the most recent draft of the SLCP plan, ARB removed
recommendations for reducing wildfire black carbon emissions. We believe it is important for the
State to identify how it will address the largest source of black carbon emissions in California, and
believe that both SB 605 and SB 1383 require the SLCP Plan to be updated to address this deficiency.
Scoping Plan
In their draft Scoping Plan, District staff continue to encourage and recommend ARB do a better job
of:
 Reflecting the benefits of forest biomass to energy within its working lands discussion, as well as
recognizing the benefits of other uses of forest biomass such as biochar;
 Considering the impacts of placing development near transportation corridors;
 Clarifying how local actions are considered in the statewide accounting of GHG reduction actions;
and
 Encouraging and identifying local GHG emission reduction actions that can be incorporated into
local land use decision-making.
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