Air Plan Approval; California; Los Angeles-South Coast Air Basin

On behalf of the Center for Biological Diversity and its thousands of members and supporters who are adversely impacted by PM2.5 in the South Coast, I am writing to comment on the contingency measures. We would first like to thank EPA and South Coast for not relying on already implemented measures. If the Biden Administration actually wanted to live up to its talk about caring about environmental justice communities and transitioning off fossil fuels, EPA would reject already implemented contingency measures throughout the nation. As to the South Coast measures, EPA needs to consider the air pollution impacts of the alternative sources of heat people use when they curtail their wood burning devices. It is arbitrary to assume that people will simply go without heat when they curtail their wood burning devices. Most likely people will use very inefficient heat devices like electric or propane space heaters when they curtail their wood burning devices. EPA must consider the PM2.5 emissions this substitute heating will cause when qualifying the PM2.5 reductions from this contingency measure, that is EPA must rely on the net savings, (reductions from wood stove curtailment - increase from replacement heat = reductions from the contingency measures). In addition, EPA must consider all of the air pollution from the replacement heating in its Clean Air Act 110(l) analysis. For example, will the increased electric demand from electric replacement heat cause or contribute to additional NOx NAAQS violations near the fossil fuel burning peaking plants meeting this increased demand. Relying on monitoring data to say their is no NOx problem would be arbitrary as the NOx ambient monitoring network is woefully inadequate to determine if peaking fossil plants are causing NOx NAAAQS violations. Sincerely, Robert Ukeiley