6­
356
6.9
Region
9
Nonattainment
Areas
6.9.1
EPA
9­
Factor
Analyses
for
California
for
the
Designation
of
PM2.5
Nonattainment
Areas
This
attachment
to
the
modification
letter
to
California
contains
EPA's
preliminary
evaluation
of
the
state's
recommended
PM2.5nonattainment
areas.
The
recommended
areas
have
been
evaluated
to
determine
if
they
follow
the
guidance
provided
in
EPA's
memo
of
April
1,
2003,
"
Designations
for
the
Fine
Particle
National
Ambient
Air
Quality
Standards"
from
Jeffrey
R.
Holmstead,
Assistant
Administrator
of
EPA
to
Region
Administrators.

In
the
April
1,
2003
memo,
EPA
states
that
for
the
purposes
of
designating
PM2.5
nonattainment
areas,
it
"
presumes
the
entire
MSA
should
be
designated
as
nonattainment."
In
areas
where
there
are
multiple
MSA's
comprising
one
larger
CMSA,
the
entire
CMSA
is
the
presumptive
nonattainment
area.
This
is
based
on
the
assumption
that
"
violations
of
the
PM2.5
NAAQS
in
urban
areas
may
be
presumed
attributable
at
least
in
part
to
contributions
from
sources
distributed
throughout
the
Metropolitan
Area."

The
April
1,
2003
memo
also
states
that
in
some
cases,
a
State
or
Tribe
may
find
that
a
violation
of
the
PM2.5
standard
is
attributed
to
a
significant
metropolitan­
scale
component
and
yet
believe
that
the
Metropolitan
Area
does
not
appropriately
define
the
area
that
should
be
designated
nonattainment.
EPA
will
consider
requests
for
urban
nonattainment
area
definitions
that
deviate
from
OMB's
metropolitan
area
definitions
on
a
case­
by­
case
basis,
considering
the
factors
described
below:

 
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
 
Air
quality
in
potentially
included
versus
excluded
areas
 
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
 
Traffic
and
commuting
patterns
 
Expected
growth
(
including
extent,
pattern
and
rate
of
growth)
 
Meteorology
(
weather/
transport
patterns)
 
Geography/
topography
(
mountain
ranges
or
other
air
basin
boundaries)
 
Jurisdictional
boundaries
(
e.
g.,
counties,
air
districts,
Reservations,
etc.)
 
Level
of
control
of
emission
sources
This
attachment
provides
EPA's
preliminary
conclusions
on
California's
recommended
PM2.5nonattainment
areas
with
respect
to
EPA's
April
1,
2003
guidance
and
the
nine
factors
that
must
be
considered
when
designating
an
area
smaller
than
the
Metropolitan
Statistical
Area.

California
has
recommended
four
PM2.5
nonattainment
areas:

San
Diego
County
San
Joaquin
Valley
South
Coast
Air
Basin
City
Of
Calexico,
Imperial
County,
California
6­
357
6.9.1.1
City
of
Calexico,
Imperial
County,
California
There
are
three
PM2.5
monitoring
sites
in
Imperial
County
that
are
being
used
to
determine
this
area's
compliance
with
the
NAAQS:
Calexico
­
Ethel
Street,
El
Centro,
and
Brawley.
When
the
State
submitted
their
recommendations
for
PM2.5
nonattainment
areas
they
used
data
from
the
years
2000
through
2002.
This
data
set
indicated
that
the
monitor
at
Calexico
­
Ethel
Street
was
in
violation
of
the
annual
PM2.5
NAAQS,
with
a
3­
year
annual
average
of
15.6
µ
g/
m3.
The
2000­
2002
three­
year
annual
averages
for
El
Centro
and
Brawley
were
11.3
µ
g/
m3
and
14.7
µ
g/
m3,
respectively.

When
the
2003
data
set
became
available,
EPA
recalculated
the
three­
year
annual
averages
for
these
monitoring
locations.
The
most
recent
three
years
of
data
(
2001­
2003)
indicate
that
while
the
three­
year
annual
averages
are
close
to
the
NAAQS,
none
of
the
sites
exceed
the
annual
NAAQS
of
15
µ
g/
m3.
The
2001­
2003
year
annual
averages
for
Calexico,
El
Centro,
and
Brawley
are
14.3
µ
g/
m3,
11.1
µ
g/
m3,
and
14.5
µ
g/
m3
respectively.

It
should
be
noted
that
the
three
monitoring
sites
did
not
have
complete
data
sets
for
the
2001­
2003
timeframe.
In
order
to
calculate
the
annual
averages,
EPA
used
the
data
substitution
procedures
in
"
Guideline
on
Data
Handling
Conventions
for
the
PM
NAAQS"
(
EPA­
454/
R­
99­
008,
1999).

6.9.1.2
San
Diego
Area
For
the
San
Diego
area,
California
recommended
San
Diego
County
as
the
PM2.5
nonattainment
area.
It
includes
the
entire
San
Diego
MSA.

The
presumptive
PM2.5
nonattainment
area
for
San
Diego
is
the
San
Diego
MSA
which
includes
San
Diego
County
in
its
entirety.

The
state's
recommended
PM2.5
nonattainment
area
is
the
same
as
EPA's
presumptive
nonattainment
area.

Based
on
EPA's
preliminary
nine­
factor
analysis
of
California's
recommendation,
the
presumptive
nonattainment
area
and
all
adjacent
counties,
EPA
agrees
that
California's
recommendation
is
an
appropriate
nonattainment
area.
We
have
included
comments
on
each
factor
in
the
pages
following.

Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
presumptive
boundary
for
the
San
Diego
MSA
is
all
of
San
Diego
County.
The
State
of
California's
recommended
PM2.5
nonattainment
area
includes
all
of
San
Diego
County,
under
the
jurisdiction
of
the
San
Diego
Air
Pollution
Control
District.
All
potential
emission
sources
in
the
San
Diego
MSA
are
included
in
the
State's
state
recommended
nonattainment
area.
6­
358
Adjacent
counties
to
San
Diego
include
Orange,
Riverside,
and
Imperial
Counties.
Emissions
generated
in
Orange
County
and
Riverside
County
are
included
in
the
state
recommended
South
Coast
nonattainment
area.
Emissions
originating
in
Imperial
County
do
not
contribute
to
elevated
PM2.5
concentrations
in
San
Diego
County
because
Imperial
County
is
separated
from
the
San
Diego
area
by
the
Laguna
Mountains
and
many
miles
of
desert.

EPA
concludes
that
analysis
of
this
factor
supports
designating
San
Diego
County
as
the
nonattainment
area
for
the
San
Diego
Metropolitan
Area.

Factor
2:
Air
quality
in
potentially
included
versus
excluded
areas
The
State's
recommended
boundary
includes
all
violating
monitoring
sites.
Violating
monitors
in
Orange
County
and
Riverside
County
are
included
in
the
state­
recommended
South
Coast
nonattainment
area.
There
are
no
monitors
in
Imperial
County
that
are
currently
in
violation
of
the
either
the
24­
hour
or
annual
PM2.5
NAAQS.

EPA
concludes
that
analysis
of
this
factor
supports
designating
San
Diego
County
as
the
nonattainment
area
for
the
San
Diego
Metropolitan
Area.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
All
urbanized
areas
in
the
San
Diego
MSA
are
included
in
the
state's
recommended
boundary
and
exist
west
of
the
Laguna
Mountains,
which
bisect
San
Diego
County
from
the
north
to
the
south.
Urbanized
areas
in
the
adjacent
counties
of
Orange
and
Riverside
fall
within
the
South
Coast
nonattainment
area.
The
nearest
urbanized
area
in
Imperial
County
is
the
El
Centro
area
which
is
separated
from
the
San
Diego
area
by
the
Laguna
Mountains
and
many
miles
of
desert.
The
El
Centro
area
is
currently
not
violating
either
the
24­
hour
or
annual
PM2.5
NAAQS.

EPA
concludes
that
analysis
of
this
factor
supports
designating
San
Diego
County
as
the
nonattainment
area
for
the
San
Diego
Metropolitan
Area.

Factor
4:
Traffic
and
commuting
patterns
California's
recommended
PM2.5
nonattainment
area,
San
Diego
County,
contains
most
of
the
VMT
for
the
San
Diego
MSA.
The
amount
of
commuting
traffic
between
San
Diego
and
Orange
or
Riverside
Counties
is
minimal
and
would
not
contribute
significantly
to
air
quality
problems
in
San
Diego
County.

Because
of
the
great
distance
between
San
Diego
is
urbanized
areas
and
Imperial
County,
traffic
and
commuting
patterns
in
Imperial
County
do
not
contribute
to
air
quality
violations
in
San
Diego
County.

EPA
concludes
that
analysis
of
this
factor
supports
designating
San
Diego
County
as
the
nonattainment
area
for
the
San
Diego
Metropolitan
Area.
6­
359
Factor
5:
Expected
growth
(
including
extent,
pattern
and
rate
of
growth)

Expected
growth
in
the
San
Diego
MSA
will
be
contained
in
San
Diego
County.
Expected
growth
in
the
adjacent
counties
of
Orange
and
Riverside
will
be
accounted
for
in
the
staterecommended
South
Coast
nonattainment
area.
Growth
in
urban
areas
of
Imperial
County
will
not
impact
the
San
Diego
MSA
due
to
the
great
distance
between
these
areas.

EPA
concludes
that
analysis
of
this
factor
supports
designating
San
Diego
County
as
the
nonattainment
area
for
the
San
Diego
Metropolitan
Area.

Factor
6:
Meteorology
(
weather/
transport
patterns)

The
distribution
of
high
PM2.5
concentrations
within
the
San
Diego
area
appear
to
be
dependent
upon
calm­
to­
light
winds
and
not
as
dependent
upon
wind
direction.
This
suggests,
as
in
the
South
Coast
area,
that
there
is
enough
activity
within
the
San
Diego
area
to
generate
high
PM2.5
concentrations
under
many
conditions
and
that
high
concentrations
are
not
being
caused
by
adjacent
areas
such
as
Orange,
Riverside
and
Imperial
Counties.

Because
high
PM2.5
concentrations
occur
during
periods
of
calm­
to­
light
wind
conditions,
the
source
of
the
high
PM2.5
concentrations
is
likely
within
San
Diego
County
itself.
Under
these
conditions,
it
is
unlikely
that
transport
is
bringing
precursors
into
the
County
in
levels
significant
enough
to
cause
violations
there.

EPA
concludes
that
analysis
of
this
factor
supports
designating
San
Diego
County
as
the
nonattainment
area
for
the
San
Diego
Metropolitan
Area.

Factor
7:
Geography/
topography
(
mountain
ranges
or
other
air
basin
boundaries)

The
San
Diego
MSA
is
bounded
by
the
Laguna
Mountains
to
the
east,
which
bisect
San
Diego
County
into
a
western
portion,
where
the
San
Diego
MSA
is
located,
and
an
eastern
portion
which
is
rural
and
adjacent
to
Imperial
County.
To
the
west
is
the
Pacific
Ocean.
Orange
and
Riverside
counties
are
to
the
north
and
the
U.
S.­
Mexico
border
forms
the
southern
boundary.

Emissions
originating
in
Imperial
County
do
not
contribute
to
elevated
PM2.5
concentrations
in
San
Diego
County
because
Imperial
County
is
separated
from
the
San
Diego
area
by
the
Laguna
Mountains
and
miles
of
desert.
While
there
could
be
some
transport
of
emissions
from
Orange
or
Riverside
counties,
these
areas
are
included
in
the
state­
recommended
South
Coast
nonattainment
area.
Any
emissions
emanating
from
across
the
U.
S.­
Mexico
border
will
need
to
be
dealt
with
through
the
planning
process.

EPA
concludes
that
analysis
of
this
factor
supports
designating
San
Diego
County
as
the
nonattainment
area
for
the
San
Diego
Metropolitan
Area.
6­
360
Factor
8:
Jurisdictional
boundaries
(
e.
g.,
counties,
air
districts,
Reservations,
etc.)

The
state
recommended
San
Diego
County
nonattainment
area
is
entirely
under
the
jurisdiction
of
the
San
Diego
Air
Pollution
Control
District.
To
the
north
of
San
Diego
County
is
Orange
and
Riverside
Counties,
which
are
included
in
the
state­
recommended
South
Coast
nonattainment
area.
Imperial
County
to
the
east
is
under
the
jurisdiction
of
the
Imperial
County
Air
Pollution
Control
District.
Imperial
County
contributes
minimally
if
at
all
to
PM2.5
air
quality
in
San
Diego
County
because
of
the
distance
between
the
San
Diego
urban
area
and
Imperial
County
and
the
Laguna
Mountain
range
which
effectively
separates
the
San
Diego
urban
area
from
Imperial
County.

EPA
concludes
that
analysis
of
this
factor
supports
designating
San
Diego
County
as
the
nonattainment
area
for
the
San
Diego
Metropolitan
Area.

Factor
9:
Level
of
control
of
emissions
sources
Imperial
County
does
not
contribute
to
violations
in
San
Diego
County
because
of
the
low
level
of
emissions
in
the
western
half
of
Imperial
County,
the
intervening
mountains
(
extending
to
over
4000
ft.
in
height),
and
the
prevailing
westerly
winds.
There
is
no
significant
commute
pattern
linking
the
two
areas,
since
the
urbanized
portions
of
San
Diego
and
Imperial
County
are
separated
by
more
than
100
miles
of
relatively
sparsely
populated
mountains
and
desert
(
the
highway
distance
from
San
Diego
to
El
Centro
is
117
miles).
The
two
counties
are
under
separate
air
quality
jurisdictions
(
San
Diego
County
Air
Pollution
Control
District
and
Imperial
County
Air
Pollution
Control
District)
and
in
separate
State
air
basin
planning
areas
(
San
Diego
Air
Basin
and
Salton
Sea
Air
Basin).
While
the
coastal
portion
of
San
Diego
County
is
highly
urbanized
with
a
population
of
approximately
3,000,000,
the
entire
Imperial
County
is
rural
and
primarily
agricultural,
with
a
total
County
population
of
approximately
150,000
(
population
density
of
35
per
square
mile).
San
Diego's
average
daily
VMT
is
over
75,000,000,
compared
to
Imperial
County's
average
daily
VMT
of
approximately
4,215,000.

6.9.1.3
San
Joaquin
Valley
Area
For
the
San
Joaquin
Valley,
California
recommended
the
San
Joaquin
Valley
(
SJV)
as
the
PM2.5
nonattainment
area.

This
area
includes
the
SJV
Air
Basin
portion
of
Kern
County,
and
all
of
Fresno,
Kings,
Madera,
Merced,
San
Joaquin,
Stanislaus
and
Tulare
counties.

The
presumptive
nonattainment
area
includes
the
MSA's
that
have
violations
of
the
PM2.5
NAAQS.
These
include
the
following
MSA's:
Bakersfield
(
Kern
County),
Fresno
(
Fresno
County),
Merced
(
Merced
County),
Modesto
(
Stanislaus
County),
and
Visalia­
Tulare­
Porterville
(
Tulare
County).

The
only
portion
of
the
presumptive
nonattainment
area
excluded
from
the
state's
SJV
recommendation
is
Eastern
Kern
County
(
EKC),
which
is
in
a
separate
air
basin
(
Mojave
Desert)
6­
361
and
is
separated
from
the
SJV
by
the
Sierra
Nevada
and
Tehachapi
Mountains
and
significant
distance.

The
seventeen
counties
adjacent
to
the
presumptive
area
and
excluded
from
the
state's
recommendation
(
Alameda,
Amador,
Calaveras,
Contra
Costa,
Inyo,
Los
Angeles,
Mariposa,
Mono,
Monterey,
Sacramento,
San
Benito,
San
Bernardino,
San
Luis
Obispo,
Santa
Barbara,
Santa
Clara,
Tuolumne,
Ventura)
are
not
in
the
SJV.
These
areas
are
either
mountainous,
separated
from
SJV
by
mountains,
separated
from
SJV
by
significant
distance
or
a
combination
of
all
of
three.
Thus,
this
indicates
that
these
counties
should
not
be
included
in
the
San
Joaquin
Valley
nonattainment
area.

Based
on
the
following
nine­
factor
analysis,
EPA
concurs
with
the
State's
recommendation
to
include
San
Joaquin
and
Kings
counties
and
to
exclude
that
portion
of
Kern
County
east
of
the
Tehachapi
and
Sierra
Nevada
Mountains.
The
excluded
portion
of
Kern
County
is
a
rural,
desert
area
in
a
separate
State
air
basin
(
Mojave
Desert)
from
the
San
Joaquin
Valley
(
SJV).
We
have
included
comments
on
each
factor
in
the
pages
following.

Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
6­
362
The
EKC
emissions
are
a
tiny
fraction
of
SJV
emissions,
as
shown
in
the
table
below.

Comparison
of
PM2.5
and
PM2.5
Precursor
Emissions
Eastern
Kern
County
vs.
San
Joaquin
Valley
Source:
California
Air
Resources
Board,
2004
California
Almanac
of
Emissions
&
Air
Quality,
2003
Estimated
Annual
Average
Emissions
in
Tons
per
Day
VOC
NOx
SO2
PM2.5
Eastern
Kern
County
13.2
37.9
3.9
9.5
San
Joaquin
Valley
396.7
504.9
26.6
150.5
California's
recommended
PM2.5nonattainment
area
only
excludes
the
EKC
which
contributes
only
a
tiny
fraction
of
the
emissions
in
the
presumptive
nonattainment
area.
This
excluded
area
is
separated
from
the
SJV
by
the
Tehachapi
and
Sierra
Nevada
mountains.
Thus,
the
excluded
area
does
not
cause
violations
of
the
NAAQS
in
the
SJV.

Counties
adjacent
to
the
presumptive
area
and
excluded
from
the
state's
recommendation
are
separated
from
the
SJV
by
topography
and/
or
distance.
Based
on
their
location
and
this
factor,
these
counties
should
not
be
included
in
the
San
Joaquin
Valley
nonattainment
area.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
SJV
as
the
nonattainment
area
for
PM2.5.

Factor
2:
Air
Quality
in
potentially
included
versus
excluded
areas
California's
recommended
PM2.5
nonattainment
area,
the
SJV,
contains
all
violating
monitors.
Thus,
violations
are
not
occurring
in
the
excluded
portions
of
the
metropolitan
statistical
area.

With
respect
to
adjacent
counties,
the
only
monitors
that
violate
the
NAAQS
in
an
adjacent
county
are
in
counties
that
have
been
recommended
as
part
of
the
Los
Angeles
nonattainment
area
and
are
separated
from
the
SJV
by
mountains.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
SJV
as
the
nonattainment
area
for
PM2.5.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
population
of
the
EKC
is
approximately
120,000,
compared
to
the
SJV
population
of
approximately
3,500,000.
EKC
has
a
very
low
population
density
(
47
per
square
mile),
degree
of
urbanization,
and
projected
population
growth,
since
the
major
source
of
EKC
employment
is
the
military.

Counties
adjacent
to
the
presumptive
area
and
excluded
from
the
state's
recommendation
are
separated
from
the
San
Joaquin
Valley
by
topography
and/
or
distance.
Based
on
their
location
6­
363
and
this
factor,
these
counties
should
not
be
included
in
the
San
Joaquin
Valley
nonattainment
area.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
San
Joaquin
Valley
as
the
nonattainment
area
for
PM2.5.

Factor
4:
Traffic
and
commuting
patterns
Average
daily
VMT
for
EKC
is
approximately
4,200,000
compared
to
SJV
VMT
of
approximately
85,000,000.
There
is
an
insignificant
volume
of
daily
commute
traffic
between
EKC
and
SJV.

Counties
adjacent
to
the
presumptive
area
and
excluded
from
the
state's
recommendation
are
separated
from
the
SJV
by
topography
and/
or
distance.
Based
on
their
location
and
this
factor,
these
counties
should
not
be
included
in
the
SJV
nonattainment
area.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
SJV
as
the
nonattainment
area
for
PM2.5.

Factor
5:
Expected
growth
(
including
extent,
pattern
and
rate
of
growth)

Counties
adjacent
to
the
presumptive
area
and
excluded
from
the
state's
recommendation
are
separated
from
the
SJV
by
topography
and/
or
distance.
Based
on
their
location
and
this
factor,
these
counties
should
not
be
included
in
the
SJV
nonattainment
area.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
SJV
as
the
nonattainment
area
for
PM2.5.

Factor
6:
Meteorology
(
weather/
transport
patterns)

There
are
typically
westerly
winds
in
the
southern
SJV,
which
have
the
potential
to
carry
some
levels
of
PM2.5
precursors
from
SJV
to
EKC,
although
the
mountains
(
elevations
from
4,064
ft.
at
the
Tehachapi
Pass
in
the
south
to
9,875
ft.
at
Sunday
Peak
in
the
north)
serve
as
a
barrier
to
transport.
Attainment
of
the
PM2.5
and
8­
hour
ozone
NAAQS
within
SJV
will
require
adoption
of
Statewide
and
SJV
controls
at
a
level
of
stringency
sufficient
to
ensure
that
transport
from
SJV
to
EKC
will
be
further
minimized.
Transport
from
EKC
to
SJV
is
insignificant,
because
of
the
high
mountains,
the
prevailing
wind
direction,
and
the
insignificant
level
of
emissions
in
EKC.

Counties
adjacent
to
the
presumptive
area
and
excluded
from
the
state's
recommendation
are
separated
from
the
SJV
by
topography
and/
or
distance.
Based
on
their
location
and
this
factor,
these
counties
should
not
be
included
in
the
SJV
nonattainment
area.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
SJV
as
the
nonattainment
area
for
PM2.5.
6­
364
Factor
7:
Geography/
topography
(
mountain
ranges
or
other
air
basin
boundaries)

California's
recommended
PM2.5
nonattainment
area,
the
SJV,
is
bounded
on
the
west
by
the
Coast
Ranges,
on
the
south
by
the
Tehachapi
mountains,
and
on
the
east
by
the
Sierra
Nevada
mountains.
These
mountains
act
as
a
barrier
to
pollution.
Violations
of
the
PM2.5
NAAQS
are
not
caused
by
areas
outside
the
SJV.

Counties
adjacent
to
the
presumptive
area
and
excluded
from
the
state's
recommendation
are
separated
from
the
SJV
by
topography
and/
or
distance.
Based
on
their
location
and
this
factor,
these
counties
should
not
be
included
in
the
SJV
nonattainment
area.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
SJV
as
the
nonattainment
area
for
PM2.5.

Factor
8:
Jurisdictional
boundaries
(
e.
g.,
counties,
air
districts,
Reservations,
etc.)

The
EKC
is
excluded
from
the
SJV
nonattainment
area
because
it
is
under
the
jurisdiction
of
the
Kern
County
Air
Pollution
Control
District,
and
in
a
separate
air
basin,
The
Mojave
Desert
Air
Basin.
SJV
nonattainment
areas
are
in
the
same
separate
air
basin
and
are
all
under
the
jurisdiction
of
the
SJV
Unified
Air
Pollution
Control
District.
The
California
Air
Resources
Board
coordinates
Statewide
planning,
oversees
implementation
of
intra­
state
planning
requirements
(
including
transport
mitigation),
and
coordinates
inter­
basin
planning,
to
the
extent
necessary.

Counties
adjacent
to
the
presumptive
area
and
excluded
from
the
state's
recommendation
are
separated
from
the
SJV
by
topography
and/
or
distance.
Based
on
their
location
and
this
factor,
these
counties
should
not
be
included
in
the
SJV
nonattainment
area.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
SJV
as
the
nonattainment
area
for
PM2.5.

Factor
9:
Level
of
control
of
emissions
sources
Both
EKC
and
SJV
are
designated
nonattainment
for
the
8­
hour
ozone
NAAQS
(
with
the
exception
of
the
extreme
northeastern
corner
of
EKC,
which
is
designated
attainment).
Control
measures
developed
to
attain
the
8­
hour
ozone
NAAQS
in
both
the
EKC
and
SJV
will
likely
focus
on
coordinated
State
initiatives
to
reduce
precursor
emissions
from
mobile
sources.
The
State
also
is
aggressively
pursuing
Statewide
controls
on
primary
PM
emitted
by
mobile
sources
as
part
of
a
diesel
risk
reduction
initiative.

Counties
adjacent
to
the
presumptive
area
and
excluded
from
the
state's
recommendation
are
separated
from
the
SJV
by
topography
and/
or
distance.
Based
on
their
location
and
this
factor,
these
counties
should
not
be
included
in
the
SJV
nonattainment
area.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
SJV
as
the
nonattainment
area
for
PM2.5.
6­
365
6.9.1.4
South
Coast
Air
Basin
Area
For
the
Los
Angeles
nonattainment
area,
California
recommended
the
South
Coast
Air
Basin
as
the
PM2.5
nonattainment
area.
This
area
includes
the
South
Coast
Air
Basin
portions
of
Los
Angeles,
Orange,
Riverside
and
San
Bernardino
counties.

The
presumptive
nonattainment
area
is
the
Los
Angeles
CMSA,
which
includes
the
counties
of
Los
Angeles,
Orange,
Riverside,
San
Bernardino
and
Ventura.

Based
on
EPA's
preliminary
nine­
factor
analysis
of
California's
recommendation,
the
presumptive
nonattainment
area
and
all
adjacent
counties,
EPA
agrees
that
California's
recommendation
is
an
appropriate
nonattainment
area
for
the
Los
Angeles
area
(
note:
The
"
Los
Angeles"
area
consists
of
the
urban
areas
of
the
city
of
Los
Angeles
and
surrounding
developed
areas
within
the
Los
Angeles
basin).
We
have
included
comments
on
each
factor
in
the
pages
following.
6­
366
6­
367
6­
368
Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
PM
SO2
NOX
VOC
Amm
Carbon
Crustal
SO2
­
Ex
Pt
NOx
­
Ex
P
t
LScore
Cumulative
L­
Score
C/
MSA
T
otal
69,872
22,119
530,780
465,495
61,094
41,151
23,840
10,900
476,347
CA
Los
Angeles
28,855
16,629
276,002
251,469
14,252
19,365
7,097
7,460
254,668
53.4
53.4
CA
San
Bernardino
17,741
3,246
109,488
50,278
21,541
8,147
8,022
1,602
81,597
19.7
73.1
CA
Orange
8,585
1,129
73,846
89,987
7,330
5,714
2,466
974
71,374
12.7
85.8
CA
Riverside
10,476
674
52,809
46,232
16,164
5,280
4,921
575
51,315
10.0
95.8
CA
Ventura
4,215
441
18,635
27,529
1,807
2,645
1,334
289
17,393
4.2
100.0
NV
Clark
13,408
48,089
76,295
50,366
2,362
3,897
8,880
4,583
45,594
40.5
CA
Kern
13,712
5,468
71,174
41,469
11,496
7,469
5,296
1,651
54,604
16.5
CA
San
Diego
12,683
2,007
76,341
95,358
6,015
7,297
4,827
1,748
73,046
14.8
CA
Santa
Barbara
4,201
1,301
14,919
24,755
2,032
2,764
1,292
280
13,355
4.5
CA
Imperial
4,931
264
16,683
11,254
8,473
2,151
2,523
195
15,887
3.6
AZ
Mohave
3,037
695
12,691
12,837
1,231
2,021
959
688
11,935
3.3
CA
Inyo
2,764
394
1,694
3,247
747
2,133
564
173
1,424
2.0
AZ
La
Paz
810
142
3,100
2,407
503
319
483
142
3,062
0.7
Area
Total
125,418
80,479
803,677
707,188
93,953
69,202
48,664
20,360
695,254
ST
COU
Total
Emissions,
2001
(
tons)
Weighted
Emisssions
6­
369
2003
Estimated
Non­
Natural
Emissions
(
tons
per
day)

County
South
Coast
Air
Basin
portion
of
Los
Angeles
CMSA
(
area
included
in
nonattainment
area)
non­
South
Coast
Air
Basin
portion
of
Los
Angeles
CMSA
(
area
excluded
from
nonattainment
area)
Emissions
(
included
area)
Emissions
(
excluded
area)
ROG*
NOX
SOX
PM2.5
ROG*
NOX
SOX
PM2.5
Los
Angeles
480.80
630.10
52.00
55.90
20.90
26.90
0.60
8.90
(
As
a
percentage)
48.8%
48.0%
71.5%
34.7%
2.1%
2.0%
0.8%
5.5%

Orange
159.40
174.10
6.90
17.80
(
As
a
percentage)
16.2%
13.3%
9.5%
11.0%

Riverside
79.00
125.00
1.90
16.00
17.20
29.90
0.40
7.40
(
As
a
percentage)
8.0%
9.5%
2.6%
9.9%
1.7%
2.3%
0.6%
4.6%

San
Bernardino
85.00
115.50
2.20
16.00
87.30
160.90
7.40
28.40
(
As
a
percentage)
8.6%
8.8%
3.0%
9.9%
8.9%
12.3%
10.2%
17.6%

Ventura
(
land
area)
54.71
50.75
1.31
10.80
(
As
a
percentage)
5.6%
3.9%
1.8%
6.7%

Total
804.20
1044.70
63.00
105.70
180.11
268.45
9.71
55.50
(
As
a
percentage)
81.7%
79.6%
86.6%
65.6%
18.3%
20.4%
13.4%
34.4%

*(
excluding
non­
anthropogenic,
aka
"
natural"
emissions)
ROG
is
defined
as
"
Reactive
Organic
Gas"

Factor
1
(
continued):
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
In
the
review
of
this
factor,
data
from
EPA's
Emission
Inventory
and
California
Air
Resources
Board
(
CARB)
has
been
used.
This
data
is
displayed
in
Figures
1.1
and
1.2.
The
CARB
data
was
useful
because
it
allowed
calculation
of
included
and
excluded
areas'
emission
inventories.
Also,
EPA
produced
a
weighted
emission
index,
referred
to
as
an
"
L­
score"
for
each
county,
which
is
another
method
of
examining
emission
levels
in
various
counties.

California's
recommended
PM2.5
nonattainment
area,
the
South
Coast
Air
Basin,
contains
most
of
the
anthropogenic
emissions
in
the
Los
Angeles
CMSA.
The
only
excluded
areas
with
significant
emissions
are
population
centers
(
Palm
Springs,
Lancaster­
Palmdale
and
Victorville­
Apple
Valley­
Hesperia)
significantly
north
or
east
of
Los
Angeles.
These
areas
are
separated
from
the
Los
Angeles
area
by
the
San
Gabriel,
San
Bernardino
and
San
Jacinto
mountain
ranges,
6­
370
which
contain
the
Los
Angeles
PM2.5
problem
to
the
Los
Angeles
area.
It
is
not
a
problem
in
the
excluded
areas
and
prevailing
winds
in
the
excluded
areas
are
generally
away
from
the
Los
Angeles
area.
Thus,
emissions
in
the
excluded
areas
are
not
causing
or
contributing
to
violations
in
the
Los
Angeles
area.

The
other
excluded
area
is
Ventura
County,
which
produces
a
small
portion
of
the
emissions
in
the
Los
Angeles
CMSA.
Most
of
the
development
and
population
in
Ventura
County
is
located
away
from
the
Los
Angeles
area
and
much
of
the
county
is
separated
from
the
Los
Angeles
area
by
mountains.

Six
counties
adjacent
to
the
Los
Angeles
CMSA
(
Clark,
NV;
Imperial,
CA;
Inyo,
CA;
La
Paz,
AZ;
Mohave,
AZ;
and
Santa
Barbara,
CA)
are
separated
from
the
Los
Angeles
area
by
great
distance,
mountain
ranges,
desert
or
a
combination
of
all
three.
Thus,
this
indicates
that
these
counties
should
not
be
included
in
the
Los
Angeles
nonattainment
area.

Two
counties
adjacent
to
the
Los
Angeles
CMSA
are
in
separate
nonattainment
areas
(
e.
g.,
Kern,
San
Diego)
and
are
separated
from
the
Los
Angeles
area
by
mountain
ranges.
Thus,
they
are
not
included
in
the
Los
Angeles
nonattainment
area
for
those
reasons.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
South
Coast
Air
Basin
as
the
nonattainment
area
for
the
Los
Angeles
Metropolitan
Area.

Factor
2:
Air
Quality
in
potentially
included
versus
excluded
areas
C/
MSA
T
otal
27.4
NA
28.9
NA
29.8
NA
CA
Los
Angeles
22.8
NA
24.4
NA
25.9
NA
CA
San
Bernardino
24.5
NA
25.9
NA
25.8
NA
CA
Orange
18.6
NA
20.3
NA
22.4
NA
CA
Riverside
27.4
NA
28.9
NA
29.8
NA
CA
Ventura
14.5
A
14.8
A
14.5
A
NV
Clark
11.0
A
10.9
A
11.0
A
CA
Kern
21.8
NA
22.8
NA
23.7
NA
CA
San
Diego
15.9
NA
16.4
NA
17.1
NA
CA
Santa
Barbara
9.5
A
9.9
A
13.0
a
CA
Imperial
9.1
A
15.6
NA
15.7
NA
AZ
Mohave
CA
Inyo
6.2
A
7.8
a
7.6
a
AZ
La
Paz
Area
Total
27.4
NA
28.9
NA
29.8
NA
'
00­'
02
'
99­'
01
'
01­'
03
ST
COU
Design
Values
California's
recommended
PM2.5
nonattainment
area,
the
South
Coast
Air
Basin,
contains
all
violating
monitors
of
the
Los
Angeles
CMSA.
Thus,
violations
are
not
occurring
in
the
excluded
6­
371
portions
of
the
metropolitan
area.
With
respect
to
adjacent
counties,
the
only
monitor
that
violates
in
an
adjacent
county
is
in
Kern
County
which
will
be
part
of
the
SJV
nonattainment
area.
This
area
is
separated
from
the
Los
Angeles
area
by
two
mountain
ranges.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
South
Coast
Air
Basin
as
the
nonattainment
area
for
the
Los
Angeles
Metropolitan
Area
Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
Population
and
Population
Density
County
South
Coast
Air
Basin
portion
of
Los
Angeles
CMSA
(
area
included
in
nonattainment
area)
non­
South
Coast
Air
Basin
portion
of
Los
Angeles
CMSA
(
area
excluded
from
nonattainment
area)
Population
(
included
area)
Population
Density
(
included
area)
Population
(
excluded
area)
Population
Density
(
excluded
area)

Los
Angeles
*
9,222,000
*
3,693
*
298,000
*
190
Orange
2,846,289
3,607
­­­
­­­

Riverside
*
1,199,000
*
544
*
347,000
*
68
San
Bernardino
*
1,330,000
*
1,057
*
379,000
*
20
Ventura
­­­
­­­
753,197
425
Total
*
14,596,289
*
2,164
*
1,777,000
*
65
Source:
U.
S.
Census,
2000
*
figure
based
on
estimate
of
partial
county
population
and/
or
population
density
California's
recommended
nonattainment
area
has
a
population
density
of
2164
persons
per
square
mile.
The
excluded
portion
of
the
Los
Angeles
C/
MSA
has
a
population
density
of
65
persons
per
square
mile.
The
recommended
nonattainment
area
contains
the
densely
populated
portions
of
the
Los
Angeles
C/
MSA.
It
also
contains
89%
of
the
C/
MSA's
population.
Furthermore,
the
excluded
areas
consist
of
areas
separated
from
the
included
areas
by
topography
and/
or
sparsely
populated
deserts.

Counties
adjacent
to
the
C/
MSA
are
separated
from
the
Los
Angeles
area
by
deserts
and
great
distance
and
are
not
included
in
the
nonattainment
area
for
that
reason.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
South
Coast
Air
Basin
as
the
nonattainment
area
for
the
Los
Angeles
Metropolitan
Area.
6­
372
Factor
4:
Traffic
and
commuting
patterns
Vehicle
Miles
Traveled
County
South
Coast
Air
Basin
portion
of
Los
Angeles
CMSA
(
area
included
in
nonattainment
area)
Non­
South
Coast
Air
Basin
portion
of
Los
Angeles
CMSA
(
area
excluded
from
nonattainment
area)
Average
Daily
Vehicle
Miles
Traveled
(
included
area)
VMT
as
a
percentage
of
LA
CMSA
(
included
area)
Average
Daily
Vehicle
Miles
Traveled
(
excluded
area)
VMT
as
a
percentage
of
LA
CMSA
(
excluded
area)
Los
Angeles
179,875,902
47.5
3,935,115
1.0
Orange
67,855,304
17.9
­­­
­­­

Riverside
37,266,851
9.8
18,478,676
4.9
San
Bernardino
35,448,320
9.4
17,872,337
4.7
Ventura
­­­
­­­
18,215,281
4.8
Total
320,446,377
84.6
58,501,409
15.4
Appendix
C:
Surface
Area,
Population,
and
Average
Daily
Vehicle
Miles
Traveled.

California's
recommended
PM2.5nonattainment
area,
the
South
Coast
Air
Basin,
contains
most
(
84.6%)
of
the
Vehicle
Miles
Traveled
(
VMT)
for
the
Los
Angeles
C/
MSA.

Other
portions
of
the
Los
Angeles
C/
MSA
outside
the
South
Coast
Air
Basin
account
for
15.4%
of
the
VMT
for
the
Los
Angeles
CMSA.
The
areas
outside
the
South
Coast
Air
Basin
in
Los
Angeles,
Riverside
and
San
Bernardino
counties
account
for
10.6%
of
the
VMT
in
the
Los
Angeles
CMSA,
however,
these
areas
are,
for
the
most
part,
only
sparsely
populated
desert
areas
separated
from
the
Los
Angeles
area
by
the
San
Gabriel,
San
Bernardino,
and
San
Jacinto
Mountains.
The
area
outside
the
South
Coast
Air
Basin
in
Ventura
County
accounts
for
4.8%
of
the
VMT
in
the
Los
Angeles
CMSA.
Most
of
the
population
in
Ventura
County
is
in
the
Ventura­
Oxnard
area.
We
believe
that
the
distribution
of
VMT
in
Ventura
County
is
similar
to
population,
and
thus
that
most
of
the
VMT
in
Ventura
County
is
in
the
Ventura­
Oxnard
area.
This
area
is
approximately
35
miles
from
the
nearest
violating
monitor
in
the
Los
Angeles
area
and
is
separated
from
the
Los
Angeles
area
by
the
Santa
Monica
Mountains
and
Simi
Hills
and
thus
does
not
contribute
to
violations
in
the
Los
Angeles
area.
The
Ventura
County
community
closest
to
Los
Angeles
county
is
Simi
Valley;
however,
its
population
is
only
15%
of
the
entire
county
and
is
separated
from
the
Los
Angeles
area
by
the
Santa
Susana
mountains,
Simi
Hills
and
other
topography
in
the
area.
We
believe
that
a
similarly
small
proportion
of
Ventura
County
VMT
is
in
Simi
Valley.
Based
on
VMT
data
for
Ventura
County,
we
believe
that
this
factor
does
not
show
that
Ventura
areas
are
causing
violations
in
the
Los
Angeles
area.

There
are
several
counties
adjacent
to
the
Los
Angeles
CMSA
(
Clark,
NV;
Imperial,
CA;
Inyo,
CA;
Kern,
CA;
La
Paz,
AZ;
Mohave,
AZ;
Santa
Barbara,
CA;
San
Diego,
CA).
None
of
these
counties
will
be
included
in
the
Los
Angeles
nonattainment
area
based
on
this
factor
because
6­
373
these
areas
are
too
distant
from
the
Los
Angeles
area,
there
is
little,
if
any,
commuting
to
the
Los
Angeles
area
from
these
counties,
and
they
are
separated
by
geography
from
the
Los
Angeles
area.
With
respect
to
this
factor,
these
areas
do
not
cause
or
contribute
to
violations
in
the
Los
Angeles
area.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
South
Coast
Air
Basin
as
the
nonattainment
area
for
the
Los
Angeles
Metropolitan
Area.
6­
374
Factor
5:
Expected
growth
(
including
extent,
pattern
and
rate
of
growth)

2002
Area
(
sq
miles)
Density
'
02
Growth
'
90­

'
00
Pct
chng
'
90­

'
00
1990
2000
Growth
'
02­'
10
Pct
chng
'
02­'
10
C/
MSA
T
ota
l
17,044,188
33,966
502
1,842,116
13
14,531,529
16,373,645
1891964
11
CA
Los
Ange
le
s
9,806,577
4,060
2,415
656,174
7
8,863,164
9,519,338
797875
8
CA
Sa
n
Be
rna
rdino
1,816,072
20,062
91
291,054
21
1,418,380
1,709,434
371735
20
CA
Ora
nge
2,938,507
790
3,720
435,733
18
2,410,556
2,846,289
225269
8
CA
Rive
rside
1,699,112
7,208
236
374,974
32
1,170,413
1,545,387
426425
25
CA
Ve
ntura
783,920
1,846
425
84,181
13
669,016
753,197
70660
9
NV
Clark
1,522,164
7,911
192
634,306
86
741,459
1,375,765
447184
29
CA
Kern
694,059
8,142
85
118,168
22
543,477
661,645
165759
24
CA
San
Diego
2,906,660
4,205
691
315,817
13
2,498,016
2,813,833
534776
18
CA
Santa
Barbara
403,084
2,739
147
29,739
8
369,608
399,347
65373
16
CA
Imperial
146,248
4,175
35
33,058
30
109,303
142,361
75337
52
AZ
Mohave
165,593
13,312
12
61,535
66
93,497
155,032
28810
17
CA
Inyo
18,214
10,192
2
­
336
­
2
18,281
17,945
1233
7
AZ
La
Paz
19,517
4,500
4
5,871
42
13,844
19,715
5579
29
Area
Total
22,919,727
89,142
257
3,040,274
16
18,919,014
21,959,288
3216015
14
Additional
Population
Info
Population
&
Area
ST
COU
6­
375
California's
recommended
PM2.5
nonattainment
area,
the
South
Coast
Air
Basin,
contains
most
of
the
expected
growth
for
the
Los
Angeles
C/
MSA.
The
areas
in
the
Los
Angeles
C/
MSA
experiencing
the
greatest
population
growth
during
the
1990'
s
were
Riverside
and
San
Bernardino
counties
with
growth
rates
of
21%
and
32%
respectively.
This
high
rate
of
growth
is
expected
to
continue
in
these
counties.
The
recommended
nonattainment
area
contains
the
portions
of
these
counties
on
the
edge
and
beyond
the
Los
Angeles
suburbs,
so
likely
growth
and
expansion
of
the
populated
areas
will
occur
within
the
recommended
nonattainment
area.

Ventura
County
is
outside
the
recommended
area,
but
inside
the
Los
Angeles
C/
MSA.
Ventura's
growth
rate
is
projected
to
be
9%
through
2010
compared
to
the
slowest
growth
areas,
Los
Angeles
and
Orange
counties
where
growth
rates
of
8%
are
projected.
Furthermore,
Simi
Valley,
the
area
of
Ventura
in
closest
proximity
to
Los
Angeles,
has
experienced
a
slowing
of
growth
and
appears
to
be
largely
built
out.
Thus,
we
do
not
expect
high
rates
of
growth
in
this
area
either.

Some
counties
adjacent
to
the
C/
MSA
have
high
rates
of
growth
and/
or
are
projected
to;
however,
these
counties
are
separated
from
the
Los
Angeles
area
and
its
suburbs
by
some
or
all
of
the
following:
great
distances,
mountain
ranges,
deserts
and
sparsely
populated
areas
and
thus
do
not
contribute
or
cause
violations
in
the
Los
Angeles
area.

Based
on
analysis
of
this
factor,
the
recommended
area
includes
the
Los
Angeles
area
and
nearby
areas
of
expected
growth,
so
the
recommended
area
is
appropriate.
EPA
concludes
that
analysis
of
this
factor
supports
designating
the
South
Coast
Air
Basin
as
the
nonattainment
area
for
the
Los
Angeles
Metropolitan
Area.

Factor
6:
Meteorology
(
weather/
transport
patterns)

California's
recommended
PM2.5
nonattainment
area,
the
South
Coast
Air
Basin,
experiences
high
PM2.5
concentrations
throughout
the
area
and
these
concentrations
may
occur
any
time
of
year.
Generally,
the
highest
concentrations
occur
when
winds
are
light
and
the
atmosphere
is
stable.

Based
on
an
analysis
of
wind
strength
and
direction
associated
with
PM2.5
concentrations,
high
concentrations
are
found
throughout
the
South
Coast
Air
Basin,
and
they
tend
to
occur
when
winds
are
light,
especially
when
the
average
wind
speed
is
below
4
mph.
At
most
monitors,
high
PM2.5
concentrations
can
occur
regardless
of
the
wind
direction;
in
fact,
most
monitors
have
a
bi­
modal
distribution
of
high
PM2.5
concentrations
with
respect
to
wind
direction.
Most
of
these
monitors
have
the
same
bi­
modal
distribution
of
average
winds
as
well,
generally
from
the
west
to
northwest
and
also
from
the
southeast.
It
appears
that
calm
to
light
winds
are
a
more
important
factor
than
the
direction
from
which
those
winds
originate.

The
abundance
of
sources
in
the
South
Coast
Air
Basin
and
widespread
distribution
of
high
PM2.5
concentrations,
dependent
upon
calm­
to­
light
winds
and
not
as
dependent
upon
wind
direction
suggests
that
there
is
enough
activity
within
the
basin
to
generate
high
PM2.5
concentrations
under
many
conditions
and
that
high
concentrations
are
not
being
caused
by
adjacent
areas.
6­
376
Because
mountains
nearly
surround
the
South
Coast
Air
Basin,
and
high
PM2.5
concentrations
occur
during
periods
of
calm­
to­
light
wind
conditions,
the
source
of
the
high
PM2.5
concentrations
is
likely
within
South
Coast
Air
Basin
itself.
Under
these
conditions,
it
is
unlikely
that
transport
is
bringing
precursors
into
the
basin
in
levels
significant
enough
to
cause
violations
there.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
South
Coast
Air
Basin
as
the
nonattainment
area
for
the
Los
Angeles
Metropolitan
Area.

Factor
7:
Geography/
topography
(
mountain
ranges
or
other
air
basin
boundaries)

California's
recommended
PM2.5
nonattainment
area,
the
South
Coast
Air
Basin,
is
bounded
on
the
southwest
by
the
Pacific
Ocean,
on
the
west
by
the
Santa
Monica,
Santa
Susana
Mountains
and
Simi
Hills,
on
the
north
by
the
San
Gabriel
Mountains,
on
the
northeast
by
the
San
Bernardino,
on
the
east
by
the
San
Jacinto
Mountains
and
on
the
south
by
the
Santa
Ana
and
coast
range
mountains.
These
hills
and
mountain
ranges
have
elevations
of
2,000
to
well
over
10,000
feet
and
act
as
barriers
to
pollution.
Thus,
violations
in
the
Los
Angeles
area
are
not
caused
or
contributed
to
by
areas
outside
the
South
Coast
Air
Basin.

The
excluded
areas
of
the
Los
Angeles
CMSA
are
separated
from
the
Los
Angeles
area
by
the
aforementioned
mountains
and
also
great
distances,
and/
or
deserts.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
South
Coast
Air
Basin
as
the
nonattainment
area
for
the
Los
Angeles
Metropolitan
Area.

Factor
8:
Jurisdictional
boundaries
(
e.
g.,
counties,
air
districts,
Reservations,
etc.)

The
five
counties
of
the
Los
Angeles
CMSA
comprise
33,954
square
miles.
This
area
is
equivalent
to
a
square
that
is
184
miles
long
and
184
miles
wide.
The
Los
Angeles
metropolitan
and
urbanized
areas,
although
large,
are
only
a
small
fraction
of
the
entire
Los
Angeles
CMSA,
however,
since
Los
Angeles'
development
occupies
small
portions
of
the
area's
very
large
counties,
especially
Riverside,
San
Bernardino
and
Ventura
counties,
and
because
CMSA's
are
comprised
of
units
no
smaller
than
counties
(
except
in
New
England),
this
CMSA
is
much
larger
than
the
Los
Angeles
area.
Although
this
is
the
presumptive
nonattainment
area,
it
is
much
larger
than
the
Los
Angeles
area.
Furthermore,
it
is
much
larger
than
the
area
with
PM2.5
NAAQS
violations
and
its
accompanying
source
areas.

The
CMSA
encompasses
fully
five
different
counties,
four
different
local
air
districts,
coastal
regions,
alpine
mountain
regions
as
well
as
both
low
and
high
deserts.

California's
recommended
PM2.5
nonattainment
area,
the
South
Coast
Air
Basin,
is
under
the
jurisdiction
of
the
South
Coast
Air
Quality
Management
District
and
includes
Los
Angeles
and
its
adjacent
urban
areas,
including
those
in
other
counties.
6­
377
The
other
air
districts
within
the
Los
Angeles
C/
MSA
are
separate
agencies
that
due
to
geography
and
distance
from
Los
Angeles,
are
not
included
in
the
Los
Angeles
nonattainment
area.

To
the
west
of
the
South
Coast
Air
Basin
is
the
Ventura
County
Air
Pollution
Control
District,
which
has
been
a
separate
air
quality
planning
entity,
with
its
own
board
of
elected
officials
and
distinct
responsibilities
for
all
air
quality
planning,
regulatory
development,
enforcement,
and
public
participation
activities,
with
the
exception
of
those
programs
that
are
conducted
under
the
jurisdiction
of
a
State
agency
(
mobile
source
standards,
consumer
products,
pesticides,
motor
vehicle
inspection
and
maintenance,
etc.).
Because
of
the
long
history
of
effective
statewide
planning
and
independent
agency
planning
and
because
of
differences
in
structure
and
approach
between
the
air
pollution
control
boards
of
the
Ventura
and
South
Coast,
it
is
likely
that
compelling
the
two
areas
to
share
jurisdictional
responsibility
for
air
quality
planning
in
an
expanded
nonattainment
area
would
interfere
with,
rather
than
promote,
harmonious
and
efficient
air
quality
planning.
Ventura
County,
although
given
an
attainment
designation
for
PM2.5,
would
nonetheless
continue
its
efforts
to
reduce
direct
and
indirect
emissions,
as
explained
further
in
the
analysis
of
Factor
9.

To
the
northeast
of
South
Coast
Air
Basin
are
the
Antelope
Valley
Air
Pollution
Control
District
and
the
Mojave
Desert
Air
Quality
Management
District.
These
areas,
although
part
of
the
Los
Angeles
CMSA,
are
separated
from
the
Los
Angeles
area
by
the
San
Gabriel
and
San
Bernardino
mountain
ranges,
which
have
elevations
over
10,000
feet.
For
that
reason,
these
areas
should
not
be
included
in
the
Los
Angeles
nonattainment
area.

Moreover,
the
South
Coast
AQMD
has
a
long
history
of
analyzing
and
addressing
existing
and
potential
transport
problems
affecting
downwind
jurisdictions.
Finally,
coordinated
rule
development
and
transport
mitigation
occurs
throughout
California
because
of
various
provisions
of
the
California
Clean
Air
Act
and
subsequent
legislation,
along
with
the
activities
of
the
California
Air
Pollution
Control
Officers
Association.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
South
Coast
Air
Basin
as
the
nonattainment
area
for
the
Los
Angeles
Metropolitan
Area.

Factor
9:
Level
of
control
of
emissions
sources
California's
recommended
PM2.5
nonattainment
area,
the
South
Coast
Air
Basin,
has
an
extreme
designation
for
the
1­
hour
ozone
standard.
It
has
also
been
designated
`
severe­
17'
for
the
8­
hour
ozone
standard.
The
area
has
some
of
the
most
stringent
controls
in
the
nation.

This
factor
is
not
relevant
for
other
Los
Angeles
C/
MSA
areas
in
the
Mojave
Desert
because
they
are
separated
from
the
Los
Angeles
area
by
mountains.

Ventura
County
is
also
in
large
part,
separate
from
the
Los
Angeles
area
by
topography
and
distance,
with
just
one
community
near
Los
Angeles
County
(
although
this
area,
Simi
Valley,
is
also
separated
from
Los
Angeles
by
a
mountain
pass).
Nevertheless,
the
level
of
control
of
emissions
sources
in
Ventura
County
is
already
high
and
expected
to
become
more
stringent,
6­
378
even
without
a
nonattainment
designation
in
Ventura
County.
The
nature
of
this
control
is
summarized
below:

(
1)
Ventura
County
APCD
and
South
Coast
AQMD
already
have
a
very
high
level
of
control
of
PM
precursor
emissions,
and
the
agencies
are
undertaking
further
progressive
control
strategy
development
activities
to
achieve
further
control
as
needed
to
attain
and
maintain
the
NAAQS.
(
2)
Although
it
is
not
proposed
to
be
designated
nonattainment
for
the
federal
PM2.5
NAAQS,
Ventura
is
designated
nonattainment
for
the
extremely
stringent
California
PM10
NAAQS
and
must
therefore
pursue
feasible
controls
to
reduce
PM
concentrations.
(
3)
The
County
is
also
classified
as
a
moderate
nonattainment
area
for
the
Federal
8­
hour
ozone
NAAQS.
Since
the
two
principal
ozone
precursors
are
also
PM
precursors
in
Ventura,
the
Ventura
County
APCD
must
continue
to
pursue
stringent
controls
of
NOx
and
VOC
in
order
to
attain
the
8­
hour
ozone
NAAQS
and
these
controls
will
benefit
PM
concentrations.
(
4)
A
large
part
of
the
PM
precursors
are
under
the
State's
jurisdiction,
and
the
involved
State
agencies
are
planning
to
adopt
additional
stringent
emission
controls
on
a
Statewide
basis.
(
5)
Attaining
the
PM2.5
NAAQS
is
expected
to
require
the
South
Coast
AQMD
and
the
State
to
adopt
a
level
of
emissions
control
far
in
excess
of
what
would
be
needed
to
ensure
continued
maintenance
in
Ventura
County.

Thus,
designating
Ventura
County
as
part
of
the
South
Coast
PM2.5
nonattainment
area
is
not
likely
to
affect
the
level
of
emissions
control
applicable
in
the
area
or
upwind
in
the
South
Coast.

EPA
concludes
that
analysis
of
this
factor
supports
designating
the
South
Coast
Air
Basin
as
the
nonattainment
area
for
the
Los
Angeles
Metropolitan
Area.
6­
379
6.9.2
Justifications
for
Changes
to
EPA
Recommendations
Contained
in
the
June
29,
2004
Letters
to
States
TECHNICAL
SUPPORT
DOCUMENT
U.
S.
EPA
Region
9
Unclassifiable/
Attainment
Designation
for
Certain
Areas
in
Southeastern
San
Diego
County
for
The
PM2.5
NAAQS
Includes
the
Tribal
Areas
of
The:

Campo
Band
of
Kumeyaay
Indians
Cuyapaipe
Band
of
Kumeyaay
Indians
La
Posta
Band
of
Mission
Indians
and
Manzanita
Tribal
Lands
6­
380
Southeastern
San
Diego
County
Unclassifiable/
Attainment
Areas
for
the
PM2.5
NAAQS:
Southeastern
San
Diego
County
Indian
Reservations
[
Note:
The
non­
tribal
areas
in
the
vicinity
of
the
designated
unclassifiable/
attainment
areas
are
under
California's
jurisdiction
and
are
part
of
a
county­
based
area
that
we
are
designating
as
nonattainment.
The
State
of
California
recommended
designating
all
of
San
Diego
County
as
a
single
PM2.5
nonattainment
area.
This
recommendation
is
consistent
with
presumptions
that
follow
our
guidance
on
designating
PM2.5
nonattainment
areas.
EPA
agrees
with
the
State
of
California's
recommendation.]

This
section
applies
to
the
portion
of
San
Diego
County
listed
below1:

La
Posta
Areas
#
1
and
#
2
Cuyapaipe
Area
Manzanita
Area
Campo
Areas
#
1
and
#
2
The
four
tribes
that
occupy
these
six
areas
did
not
submit
recommendations
to
EPA.

These
areas,
which
approximate
the
boundaries
of
the
reservations
of
the
four
Tribes
in
southeastern
San
Diego
County,
are
designated
unclassifiable/
attainment.
Based
on
their
location
and
other
factors,
we
have
determined
that
these
areas
do
not
violate
the
PM2.5
National
Ambient
Air
Quality
Standards
(
NAAQS).
We
also
believe
that
these
areas
do
not
contribute
to
PM2.5
in
other
areas.

Although
the
areas
are
surrounded
by
a
countywide
nonattainment
area,
the
United
States
has
a
unique
legal
relationship
with
tribal
governments
which
derives
from
the
United
States
Constitution,
treaties,
statutes,
Executive
Orders
and
court
decisions,
and
is
commonly
referred
to
as
the
Federal
government's
trust
relationship
with
Tribes.
Guidelines
for
EPA's
role
in
this
relationship
are
outlined
in
the
EPA
Policy
for
the
Administration
of
Environmental
Programs
on
Indian
Reservations
("
1984
Indian
Policy")
which
was
issued
in
1984
and
has
been
reaffirmed
by
successor
administrations.

The
1984
Indian
Policy
states
that
in
the
course
of
protecting
human
health
and
the
environment,
EPA
should
recognize
tribal
governments
as
sovereign
entities
with
primary
authority
and
responsibility
for
their
members,
and
in
keeping
with
this
principle
of
tribal
self­
government,
view
tribal
governments
as
the
appropriate
non­
federal
parties
for
making
decisions
and
carrying
out
program
responsibilities
affecting
their
reservations
and
their
members.
Where
tribes
have
not
assumed
delegable
programs,
EPA
retains
responsibility
for
managing
federal
programs
on
reservations.
Correspondingly,
as
a
matter
of
federal
case
law,
absent
an
express
delegation
of
authority
by
Congress
to
a
State,
States
lack
civil
regulatory
jurisdiction
over
tribes.
Respect
for,
and
protection
of,
this
division
of
jurisdiction
is
an
integral
part
of
the
federal
trust
responsibility.

1
See
"
Southeastern
San
Diego
County
Unclassifiable/
Attainment
Areas
For
The
PM2.5
NAAQS"
and
"
Southeastern
San
Diego
County
Unclassifiable/
Attainment
Area
Descriptions"
in
this
document
for
further
description
of
these
areas.
6­
381
Based
on
EPA's
own
evaluation
of
the
nine
factors
for
these
four
tribes
in
southeastern
San
Diego
County,
EPA
believes
that
a
designation
of
unclassifiable/
attainment
is
appropriate
and
is
consistent
with
the
definition
of
nonattainment
in
§
107(
d)(
1)
of
the
Clean
Air
Act.

The
justification
for
this
designation
is
that
these
tribal
areas
are
small
in
area,
population
and
commercial
development,
and
are
located
approximately
40
miles
from
San
Diego
and
are
separated
from
San
Diego
by
mountain
ranges,
deserts
and
uninhabited
land.
Based
on
the
nine­
factor
analysis
presented
below,
EPA
has
concluded
that
activities
within
these
tribal
lands
do
not
cause
or
contribute
to
PM2.5
in
San
Diego
County,
and
thus
are
appropriately
excluded
from
the
surrounding
San
Diego
County
PM2.5
nonattainment
area
and
designated
as
individual
unclassifiable/
attainment
areas
for
the
PM2.5
NAAQS.
We
also
note
that
our
decision
to
exclude
these
areas
from
the
surrounding
County­
wide
PM2.5
nonattainment
area
is
consistent
with
the
designations
we
recently
made
for
these
same
areas
for
the
8­
hour
ozone
NAAQS.

Nine­
Factor
Analysis:
Southeastern
San
Diego
Unclassifiable/
Attainment
Areas
for
the
PM2.5
NAAQS
Factor
1:
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area
The
Campo,
Cuyapaipe,
La
Posta,
Manzanita
tribal
areas
are
designated
as
unclassifiable/
attainment
areas
because
their
small
size
and
eastern
geographical
position
make
them
unlikely
causes
or
recipients
of
San
Diego
area
PM2.5
exceedances.

The
tribal
areas
are
small
and
have
very
low
emissions;
they
are
also
in
the
southeastern
corner
of
the
county,
generally
downwind
of
areas
with
high
observed
annual
PM2.5
levels.
Therefore,
they
are
not
contributors
to
San
Diego
area
PM2.5
exceedances.

Nor
are
the
proposed
tribal
unclassifiable/
attainment
areas
likely
recipients
of
PM2.5
from
the
San
Diego
area.
They
are
higher
than
the
locations
that
experience
high
PM2.5,
and
east
of
blocking
mountain
ranges.

Overall,
PM2.5
formation
is
less
well
understood
than
ozone.
In
addition,
since
we
are
concerned
here
with
the
annual
standard,
one
could
not
just
examine
a
few
extreme
episodes,
but
instead
must
look
at
multiple
conditions
throughout
the
year.
A
fuller
understanding
may
not
be
available
until
an
attainment
plan
and
modeling
are
developed.
So,
for
purposes
of
determining
the
appropriate
designation
status
for
these
tribal
areas,
this
discussion
will
focus
on
the
different
potentials
for
pollutant
transport
to
the
areas
during
summer
and
winter.

When
monthly
average
PM2.5
exceeds
15
µ
g/
m3,
that
month
contributes
to
an
annual
average
over
15,
and
hence
to
exceedances
of
the
standard.
While
this
can
occur
in
May
or
June,
concentrations
exceed
15
more
frequently
and
by
a
greater
amount
during
the
winter
or
wet
season,
roughly
October
through
March.
This
is
consistent
with
the
expected
enhancement
of
6­
382
PM2.5
levels
during
conditions
of
high
humidity
due
to
the
sulfate
formation
in
the
aqueous
phase.

As
was
described
in
EPA's
designation
for
8­
hour
ozone2
page
34
(
2004),
summer
temperature
inversions,
which
restrict
vertical
dispersion
and
hence
lead
to
high
pollution
levels,
typically
occur
below
or
about
equal
to
the
elevation
of
Alpine,
2000
feet.
This
finding
is
based
on
meteorological
modeling
and
analyses
performed
by
the
San
Diego
County
Air
Pollution
Control
District
(
APCD),
as
well
as
on
ozone
measurements
that
showed
ozone
confined
to
a
layer
at
about
this
elevation.
Unfortunately
there
is
no
PM2.5
data
available
from
Alpine,
but
using
similar
reasoning
as
for
ozone,
this
elevation
limitation
prevents
significant
transport
of
pollutants
to
the
four
tribal
areas,
which
are
12
miles
further
inland,
and
range
from
600
to
1300
feet
higher.
If
a
polluted
layer
were
very
thick,
it
could
conceivably
reach
the
lowest
area,
Campo
#
2,
by
way
of
the
canyon
containing
Cottonwood
Hauser
Creek.
However,
the
Campo
areas
are
sheltered
from
the
west
by
a
westward
spur
of
the
Laguna
Mountains,
with
accompanying
complex
terrain.
Thus
for
the
summer
months,
the
tribal
areas
are
unlikely
to
receive
elevated
PM2.5
levels.

For
the
winter
months,
when
PM2.5
levels
are
higher,
inversions
occur
more
often
at
the
surface
than
aloft,
and
tend
to
be
less
intense
than
in
summer.
The
inversions
aloft
also
tend
to
have
a
base
at
greater
height
above
the
ground,
and
so
to
be
less
constraining
of
pollutant
dispersion.
3
Surface­
based
inversions
could
hold
pollutants
near
the
ground.
But
in
order
for
pollution
generated
in
the
more
urban
portions
of
San
Diego
County
to
reach
the
tribal
areas,
they
must
be
transported
far
inland
and
uphill.

While
winter
winds
are
predominantly
from
the
northwest,
as
in
summer,
they
are
slower.
Under
some
conditions,
flow
can
even
be
from
the
northeast,
down
the
canyons
instead
of
up,
due
to
the
Great
Basin
high
pressure
system
that
persists
during
winter
(
a
strong
version
of
this
is
the
"
Santa
Ana"
winds).
Thus
there
is
less
tendency
for
pollution
to
be
transported
inland.
Upslope
flow
that
occurs
due
to
surface
heating
could
lead
to
pollutant
transport
uphill,
but
it
is
unlikely
to
extend
to
the
tribal
areas.
The
Great
Basin
high
just
mentioned
would
tend
to
weaken
the
upslope
flow.
In
addition,
in
comparison
to
summer
there
is
simply
less
heating
to
drive
the
flow.
Finally,
the
position
of
the
tribal
areas
essentially
at
the
mountain
range
crest
means
that
there
is
comparatively
little
slope
to
convert
the
expansion
from
heating
into
horizontal
movement
of
polluted
air
upslope.
Upslope
flow
from
the
east
side
of
the
range
would
also
tend
to
retard
upslope
flow
from
the
west.
Therefore,
during
winter
it
is
unlikely
that
elevated
PM2.5
levels
would
reach
these
tribal
areas.

One
final
piece
of
evidence
to
consider
is
the
attaining
air
quality
of
Imperial
County
to
the
east.
The
nearest
monitor
east
of
the
tribal
areas
is
at
El
Centro,
where
the
annual
design
value
is
9.1
µ
g/
m3,4
well
below
the
standard.
While
not
completely
conclusive
due
to
the
distance
involved,

2
U.
S.
EPA.,
"
8­
hour
Ozone
Designation,
Technical
Support
Document",
Chapter
3,

3
California
Air
Resources
Board,
"
Climate
of
the
San
Diego
Air
Basin,"
December
1974.

4
U.
S.
EPA,
Air
Quality
Subsystem
(
AQS),
2001­
2003.
6­
383
this
reading
is
consistent
with
the
idea
that
the
mountain
range
central
to
San
Diego
County
is
a
barrier
to
the
movement
PM2.5
from
the
urbanized
western
portion
of
the
county,
and
that
the
tribal
areas
should
not
be
part
of
the
nonattainment
area.

Factor
2:
Air
Quality
in
potentially
included
versus
excluded
areas:

To
the
west,
the
monitor
nearest
these
tribal
areas
is
El
Cajon
located
approximately
30
miles
west,
which
has
a
design
value
slightly
above
the
PM2.5
NAAQS
at
15.7
µ
g/
m3.5
To
the
east,
the
monitor
nearest
these
tribal
areas
is
El
Centro
located
approximately
45
miles
east,
which
has
a
design
value
well
below
the
PM2.5
NAAQS,
at
9.1
µ
g/
m3.6
EPA
believes
the
air
quality
in
these
tribal
areas
attains
the
PM2.5
NAAQS
because
there
are
few
sources
in
the
area
and
it
is
separated
from
the
violating
monitors
by
both
distance
and
topography.

The
violating
monitor
at
El
Cajon
is
at
approximately
435
feet
elevation
and
is
separated
from
these
tribal
areas
by
the
Laguna
Mountains.
Between
El
Cajon
and
these
tribal
areas,
the
Laguna
Mountains
have
elevations
generally
in
the
3000­
6000
foot
range.
The
mountains
nearest
to
the
tribal
areas
are
generally
in
the
4000­
6000
foot
range.

Factor
3:
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas
The
tribal
areas
are
not
urbanized
and
are
sparsely
populated.
Nearly
all
of
the
tribal
lands
discussed
here
have
a
population
density
of
less
than
50
persons
per
square
mile.
The
maximum
population
density
on
these
tribal
lands
is
less
than
500
persons
per
square
mile,
and
even
these
areas
account
for
only
a
negligible
portion
of
the
total
tribal
lands.

In
addition
to
its
sparse
population,
this
area
is
at
least
20
to
25
miles
from
areas
with
greater
than
1000
persons
per
square
mile.
7
Factor
4:
Traffic
and
commuting
patterns
These
tribal
areas
have
little
population
and
commuting
data
indicates
that
the
average
commuting
time
to
work
is
15­
21
minutes.
This
data
indicates
that
the
average
commuter
from
these
tribal
areas
does
not
commute
daily
to
the
San
Diego
area.

This
area
includes
rural
portions
of
Interstate
8;
however,
there
is
little
traffic
on
these
portions
of
the
highway
compared
to
the
San
Diego
area.
Also,
nearly
all
of
this
interstate
is
outside
these
tribal
lands
and
thus
out
of
tribal
jurisdiction.
8
5
AQS
2001­
2003.

6
AQS
2001­
2003.

7
U.
S.
Census,
2000.
6­
384
Factor
5:
Expected
growth
(
including
extent,
pattern
and
rate
of
growth)

These
areas
are
separated
from
the
urbanized
portions
of
San
Diego
County
by
distance
and
mountains.
They
are
sparsely
and
lightly
populated.
There
is
no
suburban
or
exurban
growth
on
these
tribal
lands
and
there
is
a
separation
of
20
to
25
miles
from
these
tribal
areas
to
areas
with
population
density
of
1000
persons
per
square
mile
or
greater.
Because
of
this
separation,
expansion
of
the
San
Diego
area
and
suburbs
will
not
impact
these
areas
in
the
near
future.
Because
the
population
of
these
areas
comprises
such
a
small
proportion
of
San
Diego
County
as
a
whole,
growth
of
these
areas
would
account
for
only
a
negligible
portion
of
the
overall
growth
in
San
Diego
County.
9
Factor
6:
Meteorology
(
weather/
transport
patterns)

[
See
discussion
in
Factor
1
for
discussion
of
Meteorology
(
weather/
transport
patterns)]

Factor
7:
Geography/
topography
(
mountain
ranges
or
other
air
basin
boundaries)

These
tribal
areas
are
located
20
to
25
miles
from
the
populated
exurbs
of
San
Diego.
Within
those
20
to
25
miles
are
the
Laguna
Mountains.
The
presence
of
these
mountains
separate
these
areas
from
the
growing
exurbs
of
the
San
Diego
area.
The
elevations
of
the
Laguna
Mountains
are
generally
3000
to
6000
feet,
with
the
higher
peaks
immediately
adjacent
to
these
tribal
lands.
These
mountains
form
a
barrier
to
air
pollution
and
transport
from
the
San
Diego
area
to
this
region.
These
areas
are
not
a
significant
source
of
emissions
within
the
county,
but
due
to
their
distance
from
the
urbanized
portions
of
San
Diego
County
and
the
presence
of
the
mountains
between
the
two,
any
effect
on
the
urbanized
areas
of
the
county
from
emissions
generated
by
activities
occurring
on
these
tribal
lands
would
be
de
minimis.

Factor
8:
Jurisdictional
boundaries
(
e.
g.,
counties,
air
districts,
Reservations,
etc.)

These
tribal
areas
are
outside
the
jurisdiction
of
the
State
of
California
and
San
Diego
County.

Factor
9:
Level
of
control
of
emissions
sources
EPA
does
not
believe
that
there
are
any
sources
of
concern
in
these
tribal
areas.
With
no
sources
of
concern,
the
level
of
control
in
this
area
is
not
currently
relevant
and
does
not
affect
PM2.5
in
San
Diego.

8
U.
S.
Census,
"
Profile
of
General
Demographic
Characteristics:
2000"
(
for
Campo,
Cuyapaipe,
and
Manzanita
Reservations;
profile
not
available
for
La
Posta
Reservation,
2000.

9
U.
S.
Census,
2000.
6­
385
APPENDIX
A
PM2.5
Design
Values
for
San
Diego
and
Imperial
Counties
PM2.5
Design
Values
10
note:
all
values
are
annual
mean
with
units
µ
g/
m3
San
Diego
County
AQS
ID
LOCATION
ANNUAL
MEAN
2001­
03
06­
073­
1002
Escondido
15.9
µ
g/
m3
06­
073­
1007
San
Diego­
12th
St.
15.9
06­
073­
0003
El
Cajon
15.7
06­
073­
0001
Chula
Vista
14.6
06­
073­
0006
San
Diego­
Overland
12.8
Imperial
County
AQS
ID
LOCATION
ANNUAL
MEAN
2001­
03
06­
025­
1003
El
Centro
9.1
06­
025­
0005
Calexico
14.4
(
incomplete
data)
06­
025­
0003
Brawley
10.6
(
incomplete
data)

10
U.
S.
EPA,
Air
Quality
Subsystem
(
AQS),
2001­
2003
6­
386
APPENDIX
B
Description:
Southeastern
San
Diego
County
Unclassifiable/
Attainment
Areas
for
the
PM2.5
NAAQS
List
of
Areas:
Campo
unclassifiable/
attainment
areas
#
1
and
#
2,
Cuyapaipe
unclassifiable/
attainment
area,
La
Posta
unclassifiable/
attainment
areas
#
1
and
#
2,
and
Manzanita
unclassifiable/
attainment
area.
11
[
Note:
Longitude
coordinates
listed
are
in
degrees
west;
Latitude
coordinates
are
in
degrees
north]

CAMPO
Unclassifiable/
attainment
AREAS
#
1
AND
#
2
CAMPO
Unclassifiable/
attainment
AREA
#
1
Degrees
Degrees
Longitude
Latitude
­
116.3938522
32.6008873
­
116.3938522
32.6021004
­
116.3938370
32.6023903
­
116.3938065
32.6084938
­
116.3938217
32.6146011
­
116.3938141
32.6168747
­
116.3937836
32.6211510
­
116.3938065
32.6246223
­
116.3938141
32.6250572
­
116.3938446
32.6293945
­
116.3938599
32.6313171
­
116.3938141
32.6434937
­
116.3938370
32.6458054
­
116.3938599
32.6528740
­
116.3938599
32.6603432
­
116.3938370
32.6705208
­
116.3937683
32.6748314
­
116.3937302
32.6833992
­
116.3937073
32.6893730
­
116.3891220
32.6893845
11
The
boundaries
for
these
designated
areas
are
based
on
coordinates
of
latitude
and
longitude
derived
from
EPA
Region
9'
s
GIS
database
and
are
illustrated
in
a
map
entitled
"
Southeastern
San
Diego
County
Unclassifiable/
Attainment
Areas
for
the
PM­
2.5
NAAQS,"
included
in
the
Technical
Support
Document
for
the
2004
PM2.5
Designations.
The
map
and
this
set
of
coordinates
are
available
at
EPA's
Region
9
Air
Division
office.
The
designated
areas
roughly
approximate
the
boundaries
of
the
reservations
for
these
tribes,
but
their
inclusion
in
this
table
is
intended
for
Clean
Air
Act
planning
purposes
only
and
is
not
intended
to
be
a
federal
determination
of
the
exact
boundaries
of
the
reservations.
Also,
the
specific
listing
of
these
tribes
in
this
table
does
not
confer,
deny,
or
withdraw
Federal
recognition
of
any
of
the
tribes
so
listed
nor
any
of
the
tribes
not
listed.
6­
387
­
116.3851318
32.6893387
­
116.3819046
32.6893616
­
116.3761826
32.6893501
­
116.3758469
32.6892662
­
116.3734131
32.6892815
­
116.3683548
32.6892548
­
116.3672028
32.6892776
­
116.3624268
32.6892624
­
116.3624496
32.6958275
­
116.3625107
32.7037697
­
116.3624420
32.7122650
­
116.3623810
32.7183075
­
116.3623810
32.7192383
­
116.3623886
32.7198639
­
116.3624191
32.7258682
­
116.3624344
32.7294846
­
116.3624420
32.7343102
­
116.3610229
32.7343369
­
116.3530502
32.7343521
­
116.3438492
32.7343788
­
116.3372269
32.7344055
­
116.3266830
32.7344131
­
116.3175354
32.7343712
­
116.3093948
32.7343826
­
116.3092957
32.7306824
­
116.3092194
32.7265244
­
116.3106918
32.7265053
­
116.3115997
32.7265167
­
116.3116150
32.7219543
­
116.3116837
32.7182999
­
116.3116531
32.7167130
­
116.3116837
32.7110214
­
116.3117752
32.7053833
­
116.3117752
32.7037506
­
116.3117981
32.6973648
­
116.3118744
32.6903038
­
116.3119049
32.6893005
­
116.3183517
32.6893005
­
116.3274918
32.6892776
­
116.3325958
32.6892509
­
116.3326569
32.6920052
­
116.3326645
32.6923180
­
116.3333893
32.6923409
­
116.3339844
32.6923256
­
116.3360519
32.6923256
­
116.3398743
32.6923218
6­
388
­
116.3409500
32.6923447
­
116.3409805
32.6901436
­
116.3410263
32.6892700
­
116.3452530
32.6892471
­
116.3511810
32.6892128
­
116.3511658
32.6824760
­
116.3511353
32.6747093
­
116.3511200
32.6681786
­
116.3511276
32.6616478
­
116.3511276
32.6602020
­
116.3511276
32.6548462
­
116.3511581
32.6485939
­
116.3511963
32.6456985
­
116.3512039
32.6400795
­
116.3511963
32.6340599
­
116.3511734
32.6310959
­
116.3511658
32.6280823
­
116.3511658
32.6251755
­
116.3511658
32.6250687
­
116.3511353
32.6204147
­
116.3510742
32.6167946
­
116.3511276
32.6139297
­
116.3511353
32.6067390
­
116.3511581
32.6043663
­
116.3629379
32.6033897
­
116.3682709
32.6029549
­
116.3682632
32.6114883
­
116.3682709
32.6169205
­
116.3741760
32.6169586
­
116.3758469
32.6170387
­
116.3843842
32.6170082
­
116.3852768
32.6169930
­
116.3852615
32.6113052
­
116.3852692
32.6029587
­
116.3852692
32.6024170
­
116.3852921
32.6020126
­
116.3852997
32.6016350
­
116.3921661
32.6010284
­
116.3938522
32.6008873
EXCLUDING:
Degrees
Degrees
Longitude
Latitude
­
116.3432693
32.6991501
­
116.3452988
32.6991692
­
116.3474503
32.6991806
6­
389
­
116.3474350
32.7004051
­
116.3474579
32.7027702
­
116.3497925
32.7027740
­
116.3511810
32.7027893
­
116.3514023
32.7027893
­
116.3517685
32.7027740
­
116.3517227
32.7033768
­
116.3517151
32.7038116
­
116.3517075
32.7044868
­
116.3516922
32.7075272
­
116.3516846
32.7100334
­
116.3511581
32.7100220
­
116.3496399
32.7100334
­
116.3474045
32.7100410
­
116.3474121
32.7089043
­
116.3474197
32.7064056
­
116.3431625
32.7063751
­
116.3431473
32.7055168
­
116.3431702
32.7037964
­
116.3431931
32.7003136
­
116.3432007
32.6993828
­
116.3432693
32.6991501
CAMPO
Unclassifiable/
attainment
AREA
#
2
Degrees
Degrees
Longitude
Latitude
­
116.4757996
32.6338768
­
116.4758072
32.6354027
­
116.4758301
32.6374321
­
116.4777145
32.6373940
­
116.4801788
32.6373405
­
116.4801559
32.6390724
­
116.4801559
32.6419983
­
116.4801559
32.6445580
­
116.4801865
32.6460190
­
116.4801788
32.6482124
­
116.4778137
32.6482468
­
116.4711609
32.6484070
­
116.4685593
32.6484604
­
116.4628830
32.6485977
­
116.4628677
32.6481361
­
116.4628983
32.6449471
­
116.4628830
32.6435204
­
116.4628677
32.6412926
­
116.4610519
32.6413460
­
116.4585495
32.6413803
6­
390
­
116.4585419
32.6399918
­
116.4585495
32.6376915
­
116.4623947
32.6376266
­
116.4672012
32.6376038
­
116.4671707
32.6364365
­
116.4671631
32.6339645
­
116.4698563
32.6339149
­
116.4715118
32.6338959
­
116.4757996
32.6338768
CUYAPAIPE
Unclassifiable/
attainment
AREA
Degrees
Degrees
Longitude
Latitude
­
116.3594589
32.8148613
­
116.3758469
32.8149872
­
116.3773727
32.8149681
­
116.3773575
32.8186951
­
116.3758545
32.8187332
­
116.3730850
32.8187523
­
116.3731766
32.8223953
­
116.3758469
32.8224297
­
116.3773727
32.8223877
­
116.3945618
32.8223038
­
116.3948517
32.8368340
­
116.4123306
32.8367386
­
116.4123688
32.8439903
­
116.4124451
32.8530045
­
116.4124527
32.8585320
­
116.4125443
32.8618469
­
116.4126282
32.8657188
­
116.4084244
32.8657303
­
116.4024582
32.8657722
­
116.3950500
32.8658104
­
116.3777466
32.8657455
­
116.3774643
32.8585205
­
116.3758469
32.8586006
­
116.3601303
32.8584747
­
116.3596268
32.8445740
­
116.3596115
32.8438034
­
116.3597107
32.8406830
­
116.3598175
32.8368759
­
116.3596649
32.8295746
­
116.3594971
32.8182030
­
116.3594589
32.8148613
6­
391
EXCLUDING:
Degrees
Degrees
Longitude
Latitude
­
116.3774490
32.8331528
­
116.3817902
32.8331566
­
116.3818512
32.8404427
­
116.3775253
32.8404121
­
116.3774490
32.8331528
LA
POSTA
Unclassifiable/
attainment
AREAS
#
1
AND
#
2
LA
POSTA
Unclassifiable/
attainment
AREA
#
1
Degrees
Degrees
Longitude
Latitude
­
116.4124756
32.7194672
­
116.4124603
32.7229614
­
116.4124603
32.7262383
­
116.4124680
32.7283859
­
116.4124603
32.7296181
­
116.4124451
32.7304344
­
116.4123917
32.7310486
­
116.4122467
32.7324371
­
116.4121933
32.7330780
­
116.4121475
32.7335663
­
116.4121094
32.7337990
­
116.4120789
32.7339172
­
116.4119797
32.7340736
­
116.4119339
32.7342529
­
116.4119034
32.7344437
­
116.4118958
32.7346458
­
116.4119186
32.7357597
­
116.4119110
32.7375832
­
116.4073563
32.7376099
­
116.4073334
32.7377701
­
116.4073029
32.7429504
­
116.4073029
32.7447739
­
116.4031143
32.7447662
­
116.4030533
32.7484016
­
116.4019165
32.7483749
­
116.4008408
32.7483826
­
116.3992996
32.7483826
­
116.3983383
32.7483864
­
116.3969803
32.7483940
­
116.3963089
32.7483864
­
116.3946991
32.7483940
­
116.3935699
32.7484093
6­
392
­
116.3924103
32.7484550
­
116.3907318
32.7484818
­
116.3884659
32.7485428
­
116.3858948
32.7486076
­
116.3828659
32.7486839
­
116.3806458
32.7487526
­
116.3797913
32.7487869
­
116.3791351
32.7488022
­
116.3774567
32.7488289
­
116.3774719
32.7461090
­
116.3758469
32.7461319
­
116.3734589
32.7461510
­
116.3734436
32.7488289
­
116.3675156
32.7488518
­
116.3610306
32.7488747
­
116.3609924
32.7480240
­
116.3610306
32.7452621
­
116.3734741
32.7452507
­
116.3734512
32.7415466
­
116.3669434
32.7415543
­
116.3609619
32.7415657
­
116.3610306
32.7411308
­
116.3610229
32.7343369
­
116.3624496
32.7343407
­
116.3624344
32.7294846
­
116.3624191
32.7258682
­
116.3623886
32.7198639
­
116.3708572
32.7197227
­
116.3758316
32.7196426
­
116.3784943
32.7196579
­
116.3839035
32.7196350
­
116.3875351
32.7196198
­
116.3911743
32.7196007
­
116.3941879
32.7195473
­
116.3970032
32.7195587
­
116.3989334
32.7195625
­
116.4012909
32.7195511
­
116.4023514
32.7195320
­
116.4040070
32.7195320
­
116.4072418
32.7195053
­
116.4124756
32.7194672
6­
393
LA
POSTA
Unclassifiable/
attainment
AREA
#
2
Degrees
Degrees
Longitude
Latitude
­
116.4203491
32.7591209
­
116.4203339
32.7655792
­
116.4203262
32.7699738
­
116.4160233
32.7700539
­
116.4160538
32.7664719
­
116.4117279
32.7666054
­
116.4117584
32.7629204
­
116.4117889
32.7593193
­
116.4203491
32.7591209
MANZANITA
Unclassifiable/
attainment
AREA
Degrees
Degrees
Longitude
Latitude
­
116.3610229
32.7343369
­
116.3610306
32.7411308
­
116.3609619
32.7415657
­
116.3607101
32.7415619
­
116.3605652
32.7415695
­
116.3605957
32.7435303
­
116.3606262
32.7452698
­
116.3610306
32.7452621
­
116.3609924
32.7480240
­
116.3610306
32.7488747
­
116.3610229
32.7496910
­
116.3609543
32.7500534
­
116.3608856
32.7587395
­
116.3608704
32.7631874
­
116.3608627
32.7672615
­
116.3609009
32.7709351
­
116.3564072
32.7709274
­
116.3466721
32.7708702
­
116.3436737
32.7708359
­
116.3390884
32.7708054
­
116.3270569
32.7707481
­
116.3264618
32.7707291
­
116.3184509
32.7708015
­
116.3171158
32.7707672
­
116.3171768
32.7670517
­
116.3171997
32.7631454
­
116.3172760
32.7569122
­
116.3173828
32.7511406
­
116.3173828
32.7501564
6­
394
­
116.3173828
32.7500610
­
116.3174362
32.7489281
­
116.3234787
32.7489281
­
116.3266678
32.7488899
­
116.3266449
32.7416649
­
116.3266830
32.7344131
­
116.3372269
32.7344055
­
116.3438492
32.7343788
­
116.3530502
32.7343521
­
116.3610229
32.7343369
EXCLUDING:
Degrees
Degrees
Longitude
Latitude
­
116.3388977
32.7581825
­
116.3431778
32.7581978
­
116.3431625
32.7613106
­
116.3431625
32.7631645
­
116.3431320
32.7654572
­
116.3387756
32.7654266
­
116.3346558
32.7654114
­
116.3346634
32.7644844
­
116.3346558
32.7631302
­
116.3346634
32.7619247
­
116.3346710
32.7581978
­
116.3388977
32.758182
6­
395
APPENDIX
C
Map:
Southeastern
San
Diego
County
Unclassifiable/
Attainment
Areas
for
the
PM2.5
NAAQS
