As warehousing spreads across the Inland Empire, San Joaquin Valley, Southern California and elsewhere, it presents a new version of an age-old problem: How can regulators enforce regional air quality standards under the Clean Air Act while at the same time reduce effects at the neighborhood scale?<\/p>\n
The San Diego County Air Pollution Control District\u00a0is the latest to respond to this\u00a0challenge\u00a0in its recent\u00a0report,\u00a0Options and Considerations for Reducing Indirect Source Emissions at Warehouses, Distribution Centers, and Ports<\/a>. So far, its actions are not encouraging. They read as an exercise in compliance with\u00a0Assembly Bill 423<\/a> \u2014 a 2019 law that requires the district to \u201cconsider\u201d adopting indirect source rules \u2014 rather than a good-faith attempt to advance its obligations to protect all people, including the region\u2019s most vulnerable, from the impacts of goods movement.<\/p>\n Among the first to grapple with the cumulative impacts of warehousing, which stretch far beyond diesel particulate matter and other air pollutants, are communities covered by Assembly Bill 617, enacted in 2017<\/a>. They include portside communities, where 84%<\/a> of cancer risk from air pollution is attributable to diesel particulate matter emissions from the Port of San Diego, freight and rail facilities, and industry; and international border communities, where the PM2.5 and traffic burden in San Ysidro are 95% and 100%<\/a>\u00a0higher than in other California\u00a0census tracts, respectively.<\/p>\n AB 617\u00a0marked an admission, by the California State Legislature as well as the\u00a0California Air Resources Board, that standard approaches to regulating\u00a0emissions in disadvantaged communities, including \u201cexpensive, regulatory-grade monitoring systems\u00a0in place today<\/a>,\u201d fail to target and redress the disparate impacts of air pollution in low-income and minority communities. In addition, the Clean Air Act\u2019s ambient air quality standards, which Air Pollution Control District strives to achieve on a regional basis through air quality planning, were not designed to address what the California Air Resources Board calls \u201clocalized\u201d sources of air toxics near \u201cports, rail yards, warehouses and freeways\u201d and other sources.<\/p>\n In response, AB 617 created an air monitoring and emissions reduction planning process that is labor-intensive and, for residents of disadvantaged communities, exhausting. For hundreds of hours,\u00a0portside<\/a>\u00a0and\u00a0international border<\/a> community residents served on AB 617 steering committees and produced detailed recommendations for how localized emissions should be identified and mitigated.<\/p>\n Portside AB 617 communities include Barrio Logan, Logan Heights, Sherman Heights and west National City. At the moment, Barrio Logan has\u00a0<\/strong>220 warehouses<\/a> across roughly 5 square miles. Similarly, west National City has 201\u00a0warehouses<\/a> within its borders. Roughly three-quarters of these warehouses are smaller than 20,000 square feet. Zoom in further and so does the intensity of land use. For example, Barrio Senior Villas, an affordable housing complex that is home to residents over the age of 75, is located within 1,000 feet of over 35 warehouses<\/a>.<\/p>\n Such conditions led the Portside Environmental Justice Neighborhoods\u2019 Community Emissions Reduction Plan<\/a> under AB 617 to include \u201creduc[ing] emissions from heavy-duty and medium-duty trucks servicing indirect sources by 100% five years in advance of [existing] regulatory requirements\u201d and \u201creduc[ing] Diesel PM from 2018 levels by 80% in ambient air at all Portside Community locations\u201d as two among the plan\u2019s seven goals.<\/p>\n The San Diego County Air Pollution Control District\u2019s report\u00a0(and\u00a0recent supplement<\/a>) does a disservice to communities\u00a0who contributed, in good faith, to what they believed was\u00a0a roadmap to\u00a0finally address\u00a0the cumulative impacts\u00a0that they face. It gives\u00a0short shrift to the place of additional regulations within\u00a0an evolving suite of air pollution control options, ignores\u00a0the\u00a0full range<\/a>\u00a0of regulatory and compliance options that can be included in an indirect source regulatory\u00a0program, fails\u00a0to fully consider the emissions and air quality impacts of California\u2019s decision to\u00a0withdraw<\/a>\u00a0a waiver request to the Environmental Protection Agency for its Advanced Clean Fleets regulation, and paints\u00a0a less-than-comprehensive picture of the public health benefits of such rules.<\/p>\n More importantly, by focusing on regional emissions reductions and aggregate compliance cost and cost-effectiveness calculations rather than localized benefits, the Air Pollution Control District shows a lack of consideration of years of work by environmental justice communities, through AB 617\u00a0and otherwise, to carefully determine how air districts should balance regional air quality and conditions on the ground. Greater care should be taken to acknowledge and engage with their findings.<\/p>\n Macey is director of the Center for Land, Environment and Natural Resources at UC Irvine School of Law and lives in Irvine. Rilli is conservation program manager of Sierra Club San Diego Chapter and lives in San Diego.\u00a0<\/p>\n","protected":false},"excerpt":{"rendered":"As warehousing spreads across the Inland Empire, San Joaquin Valley, Southern California and elsewhere, it presents a new…\n","protected":false},"author":3,"featured_media":179775,"comment_status":"","ping_status":"","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[5134],"tags":[5229,1582,276,11890,1269,3549,7264,67,586,132,5230,68,2969],"class_list":{"0":"post-179774","1":"post","2":"type-post","3":"status-publish","4":"format-standard","5":"has-post-thumbnail","7":"category-san-diego","8":"tag-america","9":"tag-ca","10":"tag-california","11":"tag-commentary","12":"tag-opinion","13":"tag-san-diego","14":"tag-sandiego","15":"tag-united-states","16":"tag-united-states-of-america","17":"tag-unitedstates","18":"tag-unitedstatesofamerica","19":"tag-us","20":"tag-usa"},"share_on_mastodon":{"url":"https:\/\/pubeurope.com\/@us\/115100890091772369","error":""},"_links":{"self":[{"href":"https:\/\/www.europesays.com\/us\/wp-json\/wp\/v2\/posts\/179774","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.europesays.com\/us\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.europesays.com\/us\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.europesays.com\/us\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/www.europesays.com\/us\/wp-json\/wp\/v2\/comments?post=179774"}],"version-history":[{"count":0,"href":"https:\/\/www.europesays.com\/us\/wp-json\/wp\/v2\/posts\/179774\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/www.europesays.com\/us\/wp-json\/wp\/v2\/media\/179775"}],"wp:attachment":[{"href":"https:\/\/www.europesays.com\/us\/wp-json\/wp\/v2\/media?parent=179774"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.europesays.com\/us\/wp-json\/wp\/v2\/categories?post=179774"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.europesays.com\/us\/wp-json\/wp\/v2\/tags?post=179774"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}