February 1, 2018 STI-717042 Mr. Mark Stover Chief, Field Operations Branch, California Air Resources Board – Enforcement Division 1001 I Street Sacramento, CA 95814 Via email: mark.stover@arb.ca.gov

Re: Supplemental Environmental Project (SEP) Proposal: Community-Based Monitoring and Assessment Program for Fresno

Dear Mark,

Introduction The Central California Environmental Justice Network (CCEJN) and Sonoma Technology, Inc. (STI) are proposing Supplemental Environmental Projects (SEPs) for the California Air Resources Board (CARB) SEP program. These projects seek to address needed air quality improvements in California’s San Joaquin Valley (SJV). A special focus for these projects is to assist disadvantaged communities identified as environmental justice (EJ) areas of concern, such as the City of Fresno, California.

This proposed project will support community-based air monitoring and assessment in EJ areas within the City of Fresno and in nearby unincorporated Fresno county communities. The project focus is to

• Assess existing air quality in EJ areas in the vicinity of truck traffic serving distribution centers, the Rio Bravo Fresno (RBF) biomass-fired electrical generating facility, and other industrial or traffic-related air pollution sources, particularly in the Malaga, Calwa, and southeast areas of Fresno.

• Compare air quality in areas of interest to regional air quality.

• Illustrate how air quality may change with different truck and stationary source activity.

• Help air quality stakeholders in the Fresno region understand the potential need for air quality mitigation.

Fresno area residents are concerned about air quality impacts from trucks servicing RBF, RBF operations, trucks servicing nearby distribution centers, and emissions related to nearby industrial facilities and other pollution sources. The proposed SEP project area ranks as heavily impacted based on CalEnviroScreen 3.0 (Figure 1). In addition, based on U.S. EPA’s EJ Screen mapping analysis tool,

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the census blocks in the project area rank in the highest 10% on EPA’s EJ Index for PM2.5 and cancer risk from air toxics.

Figure 1. Fresno area CalEnviroScreen rankings. The project area is ranked in the most heavily impacted category (91-100% rating).

Residents in areas near RBF, such as those in the Calwa and Malaga communities, want to better understand current community-based air quality and whether air quality changes over time are due to changes in RBF-related truck activity or other source emissions. The proposed work will therefore serve three purposes. First, it will establish baseline air quality conditions in communities near the RBF plant and other potential pollution sources, and near the roads that service the truck traffic headed to and from the RBF plant and other nearby businesses such as the distribution centers located near RBF. Second, baseline measurements will be augmented, as funding becomes available, by ongoing measurement work to enable comparisons over time if RBF expands operations to process increased biomass from the many drought-related dead trees in California forests. Third, baseline and ongoing monitoring will identify whether there is important spatial variability among community-level air pollution levels, and help assess how such variability is connected to other nearby pollution sources. Given the use of trucks to service the RBF facility and other businesses such as the distribution centers, a central focus of this work is to help the community assess and respond to pollution problems related to truck traffic. Baseline work will begin in one community or neighborhood and, as additional funding becomes available, extend to other areas.

Truck operations, including free-flow travel, stop-and-go driving, idling, and cargo loading/unloading, all have potential to contribute emissions. Trucks are important sources of diesel particulate matter (DPM), which is both a California toxic air contaminant (TAC) and a contributor to fine particulate matter (PM). In addition, some trucks that transport biomass may have agricultural-

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related exemptions from emission controls, meaning that emissions on local roads may be higher than if newer trucks with emission control devices were being operated.1

We propose to conduct community monitoring in Malaga, Calwa, and the community around the RBF facility; engage community members on air pollution through outreach and community-based participatory monitoring, and by making data and findings available online and in a written form for residents who do not have access to the internet; and model the air quality impacts of RBF-related operations on the local community. If monitoring findings indicate the importance of other nearby air pollution sources, the air quality modeling work can also be expanded to assess those other sources as funding becomes available. This work will help CCEJN and other stakeholders quantify localized air pollution in areas near truck traffic and other local pollution sources; generate robust information to help stakeholders address community-level air pollution; and, provide an example framework for other community-based participatory monitoring efforts to understand and address local air pollution problems.

A key benefit from this work is that it will also give regulators practical implementation lessons to address requirements under the recently enacted AB 617, which mandates community-based air monitoring. The work described here will be modeled on prior community-based monitoring studies done by STI, such as a recent assessment we completed in Sacramento, California, where air toxics, PM2.5, and other pollutants were measured in three EJ and three non-EJ communities during the 2016-2017 winter season.

The rest of this proposal is organized as follows:

• Description of participating organizations • Project description (work scope) • Project locations • Support for emissions reductions (benefits for air quality and disadvantaged communities) • Project budget • Project timeline

Description of Participating Organizations

CCEJN will be the lead organization. CCEJN is a Fresno-based non-profit organization that seeks to preserve the natural resources of the SJV by working towards minimizing or eliminating environmental degradation within Fresno communities. STI will support CCEJN. STI is a Petaluma-based air quality research firm founded in 1982; it has completed air quality studies throughout the U.S., including in Fresno, where STI has a satellite office. STI will lead air quality measurement support work, training, and analysis work. CCEJN will lead community outreach and information dissemination work, with support from STI. Highlights of related experience are available on the STI (http://www.sonomatech.com/projects/2136) and CCEJN (https://ccejn.wordpress.com/current-projects/) websites.

1 See, for example, ARB guidance describing biomass-related exemptions:

https://www.arb.ca.gov/msprog/onrdiesel/documents/fsag.pdf.

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Project Description (Work Scope) We are proposing community-based participatory air quality monitoring and modeling, and related outreach and education to inform community members about specific air quality issues in their community. This knowledge has the potential to empower them to develop community-based strategies to reduce air pollution exposure to protect their health.

Our vision is to conduct measurement and analysis of PM2.5, black carbon (BC), and air toxics over a four-year period to help Fresno communities understand current and future air quality in multiple areas within the Fresno region. To better match work with upcoming settlement agreements, we have subdivided planned work into elements that can be funded incrementally. Example work elements include measurement equipment setup and site identification, individual pollutant measurements at two sites for a three-month period, and companion meteorological measurements. These work elements are described in more detail in the following task discussion. Monitoring locations will be selected in consultation with CCEJN and community members in consideration of potential impacts from distribution center-related truck activity, RBF-related truck activity, Highway 99, nearby rail facilities, and other sources. Typically, sites will be chosen to represent upwind and downwind conditions at locations of interest.

Field work can begin once a minimum package of work elements has been funded. We propose to launch field work once funds have been secured to support, for at least PM2.5, equipment setup, site identification, three months of measurements, online display of findings, and related community outreach and education. As further funding becomes available, work can be extended to support additional pollutant measurements, time extend measurements in three-month increments, complete analysis and reporting, complete public outreach, and evaluate source scenarios with emissions and dispersion modeling. The work to be done is covered by the following five tasks.

(1) Initial project planning and outreach. The first task will involve the creation of a detailed work plan to guide subsequent work and ensure effective CCEJN and STI collaboration. Work plan development will be led by STI with support from CCEJN. As part of the work plan, STI will identify the specific sampling and lab analysis methods to be used for pollutant measurements. STI will also identify the quality control (QC) procedures to be employed to ensure high quality data. CCEJN will identify and make initial contact with community groups and individuals in the community important to completing later tasks. This task can be completed as one work element.

(2) Conduct community monitoring and perform analysis of results. In this task, we will set up community monitoring stations near the primary roadways used by trucks, near RBF, and elsewhere in the community using a combination of traditional monitors and low-cost sensors. CCEJN will conduct outreach on the study to the community and identify participants willing to host community monitors. Community outreach will consist of door-to-door canvassing in the targeted communities and holding a minimum of three (3) community meetings at the Malaga Elementary School, the Calwa Elementary School, and the Friends of Calwa Community Center. All community outreach will be conducted in a culturally appropriate manner by bilingual and bicultural CCEJN staff who are

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knowledgeable of this area. Project implementation is planned in funding increments to support siting monitors at two locations (e.g., an upwind and downwind location to evaluate one neighborhood) for each funded increment of work.

Figure 2 illustrates a low-cost sensor monitoring platform STI installed in a residential yard as part of its recent Sacramento community-based monitoring project.

Figure 2. Community-based monitoring platform using a low-cost air sensor that was installed by STI in a residential yard in Sacramento during 2016-2017.

For each increment of funding to support measurements, STI will set up monitoring sites and conduct monitoring for three months. CCEJN will help STI by identifying individuals willing to host a monitoring site at their residence or business. Participants hosting monitors will be provided with all the technical support required to install the monitors and troubleshoot any technical problems that may arise, and will be given a $150 gift card as a stipend for their participation for the duration of the project. CCEJN will complete outreach to ensure the identification of sufficient participant pairs to enable measurement work at two locations for each increment of funding received.

Monitoring will include PM2.5, BC as an indicator for DPM, and gaseous air toxics; meteorological data will be collected at one site. For budget purposes, we assume that each increment of funding will support a monitoring program that includes two sites, situated to be upwind and downwind of a location of interest, with continuous PM2.5 monitors. As budget allows, BC, air toxics (12 samples per funded work increment), and site-specific meteorological measurements can be added. With these data, we will determine what air pollution gradients exist in the community and quantify whether localized emissions sources are contributing to localized air pollution levels that differ from the community at-large.

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The type of measurement equipment envisioned for use during the study includes:

a. For PM2.5, we plan to use Purple Air or sensors of similar performance. We plan to assess sensor precision and accuracy against a GRIMM or a similar continuous PM2.5 instrument prior to sensor deployment in the field.

b. For BC, we plan to use the Aethalometer AE33, which is a well-established instrument for monitoring BC.

c. Given that there may be a time delay between proposal preparation and actual field work, at the time field work takes place we may reconsider available instrumentation, to see if approaches exist that improve study outcomes without increasing cost, or that help reduce study costs.

All three pollutant categories (PM2.5, BC, air toxics) or some combination of pollutant categories can be covered under this Task, depending on funding levels. Our budget proposal assumes financial support for at least PM2.5 measurements; BC or air toxics measurements can be completed as additions to the PM2.5 measurement work. Local meteorological data will also be measured as funding becomes available. Subsequent to the baseline monitoring, we will conduct periodic ongoing monitoring to assess changes in conditions. Costs for the baseline and ongoing monitoring are provided for incremental three-month periods so that work can continue to address community concerns as funding becomes available over the four-year period. For funding purposes, this task is subdivided into the following elements:

o PM2.5 measurement setup and site identification o PM2.5 three months of operations at two sites, using one low-cost sensor per site o PM2.5 data assembly, analysis, and reporting o BC measurement setup and three months of operations at two sites o BC data assembly, analysis, and reporting o Air toxics setup, sample collection at two sites, analysis, and reporting o Meteorological measurement setup at one site and three months of operations

(3) Support online management and real-time display of community-based findings. In this task, STI will support real-time data display and work with CCEJN to periodically (about once per quarter) display collected community-based monitoring information on the IVAN network website. For the IVAN website, STI will provide English-language website content to CCEJN; CCEJN will provide a Spanish-language version of the content, obtain access to the IVAN network website, and post English and Spanish versions to IVAN. CCEJN will also provide support to STI to ensure the content is appropriate for a general public audience. Through the existing IVAN website, the public and local community can provide feedback, ask questions, and provide information on odors or other hazards observed in the community. CCEJN will respond to IVAN-related public feedback as needed.

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In addition, as part of this task, STI will provide CCEJN with web-based access to approximately real-time measurement data. This will let CCEJN observe monitoring results and share the real-time results with the community. To assist CCEJN in fielding public information requests related to the real-time data, STI will provide CCEJN with a weekly support briefing to discuss observed air quality. As needed, CCEJN will respond to public information requests resulting from the outreach efforts and the display of real-time data. For example, CCEJN Fresno staff will check the real-time data display from STI’s website at least once a week and, depending on the concentrations displayed, will send text messages alerting community members about measurement findings. The messages will be distributed to those who attended the Task 2 community meetings and to others, such as those residing near the sensors, who provide CCEJN with their contact information. This additional educational element will allow community members, especially those who cannot access the internet, to be informed of the community-based monitoring findings. For funding purposes, this task is subdivided into the following elements:

o Setup for IVAN content posting and online data display o Community outreach/education in response to real-time data display (three months)

(4) Complete community-based outreach and education. In this task, CCEJN will engage the local community, industry, regulatory agencies, and other stakeholders on air quality issues and insights gained from the measurement work in this project. This will include on-site community workshops on the project and its results, and educational outreach on air pollution and its health effects. In addition to organizing and running the community workshops, as needed, CCEJN will respond to public information requests resulting from the outreach efforts. STI will support CCEJN by providing presentation-ready information on air pollution science and the monitoring findings. This task can be completed as one work element.

(5) Perform emissions and dispersion modeling of RBF-related impacts on community. STI will conduct emissions and air quality dispersion modeling for the RBF facility and selected truck routes to test how localized air quality varies with different biomass-burning levels and related truck and plant emissions. Analyses will cover scenarios that vary the times of day and seasons of the year (and therefore meteorological conditions) when emissions occur. STI will then compare modeled to measured concentrations from Task 2 to help interpret the modeled results. STI will work with CCEJN to develop a presentation of results suitable to share with the community. CCEJN will lead work to share the findings via community meetings or other appropriate venues, with support from STI. The main value of this work is to help educate the community and stakeholders about the relationship between different emissions situations and the resulting pollution. The modeling work complements the monitoring effort by enabling stakeholders to understand situations that may not yet have been measured. Budgeted work includes modeling for a base case and two alternative scenarios. Additional modeling work can be

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performed if needed and as additional funding becomes available. For funding purposes, this task is subdivided into the following elements:

o Emissions modeling for base case and two future scenarios o Air quality dispersion modeling (base and two scenarios)

Project Locations

This project will take place in Fresno EJ settings, including the Malaga and Calwa communities of Fresno County. Specific monitoring locations in the community will be determined via STI and CCEJN collaboration. STI will recommend monitoring location options based on technical analysis, and CCEJN will help finalize site selection through community outreach and securing volunteers to host monitoring equipment. Work will begin in one community or neighborhood and, as additional funding becomes available, extend to other communities or neighborhoods.

Support for Emissions Reductions

The project will help stakeholders understand whether community-scale air quality differs from the surrounding region. By focusing work on areas near local truck traffic and other sources, the project will enable local stakeholders to assess the need for and take appropriate actions to implement local controls. For example, if the project findings indicated that further reductions in truck emissions would be beneficial, stakeholders could work with regulatory officials and others to reduce truck traffic, reroute truck traffic, or accelerate the replacement of trucks that receive agricultural exemptions from emissions controls. Efforts such as these would reduce community exposure to air pollution.

Project Budget

Estimated costs to complete the work elements described earlier are provided in Table 1 by task. Tasks and related work elements can be funded individually or in combination. Recommended minimum starting points for work include the following elements:

1. Funding for initial project planning and outreach (Task 1 in Table 1).

2. Funding to support a package of pollutant measurements, data display, and outreach, beginning with PM2.5 (Tasks 2a, 2b, 3a, and 3b in Table 1).

As shown in Table 1, the estimated cost for the recommended minimum starting work elements is $184,400. Following the recommended initial work beginning with PM2.5 (Tasks 1, 2a, 2b, 3a, and 3b), additional funding can support: measurement work for other pollutants (Task 2d for BC, Task 2f for air toxics); measurement of site-specific meteorology (Task 2g); measurement work for extended time periods (Tasks 2b, 2d, 2f, 2g); data assembly, analysis, and reporting of pollutant findings (Tasks 2c and 2e); ongoing real-time data display and related outreach support (3b); community outreach and education based on measurement findings (4); and emissions and dispersion modeling (Tasks 5a and 5b). These efforts can each be funded incrementally, as indicated by the rows in Table 1.

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Planned work includes the tasks described. If unforeseen circumstances affect task completion, STI and CCEJN will perform comparable work matched to the available budget and consistent with the overall project objectives.

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Table 1. Community monitoring and outreach costs.a Settlement funds can be used to fund row-by-row elements individually or in combination. See text for recommended initial work elements.

Task and Related Work Elements CCEJN STI Total

1. Initial project planning and outreach $5,000 $35,000 $40,000

2. Community monitoring, analysis and sharing of results

a. PM2.5 measurement setup and site identification $3,900 $33,000 $36,900

b. PM2.5 baseline or ongoing operations at two sites for three months

$2,500 $34,000 $36,500

c. PM2.5 data assembly, analysis, and reporting $2,500 $30,000 $32,500

d. BC measurement setup and three months of baseline or ongoing operations at two sites

$2,500 $32,000 $34,500

e. BC data assembly, analysis, and reporting (initial or ongoing)

$2,500 $22,000 $24,500

f. Air toxics setup, sample collection (12 samples), analysis, and reporting (initial or ongoing time periods)

$2,500 $37,000 $39,500

g. Meteorological measurement setup at one site and baseline or ongoing operations in three-month increments

$500 $26,000 $26,500

3. Support online management and real-time display of community-based findings for three-months

a. Setup for IVAN content posting and online data display $3,000 $37,000 $40,000

b. Community outreach/education in response to real-time data display (three month increments)

$6,000 $25,000 $31,000

4. Community outreach and education $18,100 $27,000 $45,100

5. Emissions and dispersion modeling

a. Emissions modeling for base case and two future scenarios $2,000 $39,000 $41,000

b. Air quality dispersion modeling (base and two scenarios) $2,000 $40,000 $42,000

Totals $53,000 $417,000 $470,000 a Costs shown here are valid for calendar year 2018 billing rates. Work completed in future years will include price adjustments as needed to reflect cost escalation. The budget shown here assumes separate settlement agreements disbursed to each organization; if funding support for both CCEJN and STI is routed through CCEJN, an additional 6.5% service fee will need to be added to the STI costs shown here.

The community monitoring cost estimates shown in Table 1 can be viewed as modular and repeatable with additional funding. We envision, as funding becomes available over time, continually adding new measurement sites, pollutants, and/or time extensions to the field work. This will enable us to help the community extend the geographic coverage of the monitoring, the pollutants measured, and the time periods for which data are collected, while also matching the availability of funds on an ongoing basis. So, for example, once PM2.5 measurement setup and site identification

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are complete for a given site (Row 2a in Table 1), we can collect three months of data (Row 2b in Table 1), and continue to collect data in three-month increments as further funding becomes available (as many times as Row 2b in Table 1 is funded). The same concept applies to the number of sites and the number of pollutants covered. Further funding can be used to continually support selected efforts as detailed in the rows shown in Table 1. The work proposed, especially with repeated or time-extended measurements, is envisioned to take place over a period of approximately four years (2018 through 2021). If the community elects to continue work beyond that time period, or elects to support additional monitoring and analysis work that exceeds the number of work elements and total costs shown in Table 1, we will submit an updated version of Table 1 to CARB as an addendum, and request CARB approval for the updated Table 1 cost estimates. We will also submit an updated version of Table 1 as an addendum for CARB approval each calendar year, to reflect any cost escalation changes that occur year-to-year.

Project Timeline

An estimated work schedule is provided in Table 2.

Table 2. Estimated work schedule.a

Work Element Timeline (Assuming Funding Availability)

1. Initial project planning and outreach Delivered within 120 days of contract

2. Community monitoring and analysis (e.g., baseline monitoring of PM2.5 at two sites for three months)

Completed within six months of contract

Community monitoring and analysis (ongoing monitoring)

Completed in three-month increments, following baseline monitoring, as funding becomes available

3. Support online management and real-time display of community-based findings

Ongoing, beginning six months following contract initiation

4. Community outreach and education Completed within one year of contract; will be in conjunction with Tasks 2 and 3

5. Emissions and dispersion modeling Completed within six months of contract a If the community elects to continue the program for an extended time period, we will submit an addendum requesting CARB approval to continue the work for the extended time.

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Please contact us with questions or comments. We look forward to working with you on these important projects.

Sincerely,

Nayamin Martinez, MPH Douglas Eisinger, Ph.D. Director Vice President & Chief Scientist for Central California Environmental Justice Network Transportation Policy and Planning, STI cc: Ann Stacy, Victoria Villa (CARB)