Industry
Reimagining the future of industry in Stockton
Every morning, instead of being greeted with crisp, cool morning air and hearing birds chirping or wind rustling through trees....
residents of Stockton wake up and hear the sound of ships, cranes, and zooming cars, and breathe in pollutant-filled smog.
Much of these emissions are from industrial sources: the Port of Stockton, DTE (a biomass energy production facility), a power plant, and other chemical and manufacturing facilities.
Historical Context
Stockton residents currently face some of the worst air pollution in California with National Ambient Air Quality Standard nonattainment in the categories of PM2.5 (particulate matter less than 2.5 microns in diameter) as well as ozone. These pollutants lead to a poor air quality index, with numerous health impacts for local community members, including disproportionately large asthma rates. According to Stockton residents, industrial emissions are one of the top areas of concern, following heavy duty trucks and motor vehicles.
On the right is a map of land use in Stockton. The legend is accessible in the bottom left corner. Orange mainly corresponds to residential areas, and blue corresponds with industrial ones. Within the southwest Stockton AB617 community, there is a significantly larger proportion of industrial land bordering residential areas when compared to north Stockton.
This map shows the impacts of redlining, a historical racist process in which certain groups of housing were determined to be lower quality. This map is taken from 1938, and depicts significantly lower grades (red and yellow) for those communities in south Stockton. This practice of redlining lead to property devaluation and obstacles to receiving bank loans that unfairly targeted minority communities, making it difficult to achieve economic growth.
When the redlining map is overlaid with the current land use map, the impacts are clear. Lower graded communities ended up nearer to industrial areas. This has caused southwest Stockton's air to be among the worst in the nation, negatively impacting health and community well-being.
Stockton's industry today
Shown here is a mindmap depicting the different elements in Stockton's industrial center. The port elements are in blue, and the other elements come from various manufacturing sources.
Shown here is the same map as before, but sized for PM 2.5 emissions in 2018. Out of the port emissions, ocean going vessels (OGVs) have the largest emissions, while DTE has the largest emissions of the various plants.
Port
The Port of Stockton, at the intersection of the San Joaquin River, I-5, and the Union Pacific RR, handles about 250 ships per year and trades with 55 countries.
Stockton is a major outlet for the Central Valley's agricultural exports and is the heart of much of the region's economy.
The primary cargo is bulk goods including grain, concrete, and fertilizer.
Breakdown of Stockton cargo by arrivals
Accommodating this cargo requires a wide array of equipment including tugboats, forklifts, rail pushers, and the ships themselves.
As such, the port is Stockton's largest emitter, specifically of PM 2.5, the specimen directly linked to health problems in residents.
The single largest source is ocean-going vessels (OGVs) running their engines while docked in a practice called "hotelling"
With money from the San Joaquin Valley Air District, the Port of Stockton has begun using two electric forklifts with plans for a fleet of 36 in the coming years.
They have also received one electric rail pusher train engine for yard work.
These efforts have amounted to a mere 4.6% emissions reduction. If real progress is to be made, the port needs to focus its efforts on its OGV traffic.
As of 2018, the PM2.5 emissions from one OGV while at berth equals that of 758.3 forklifts or 155.5 rail pushers.
While Stockton continues to pollute, other larger ports have seen the implementation of CARB's Regulatory Advisory 17 requiring an 80% reduction in at-berth emissions by 2020 with violators receiving up to a $75,000 fine.
These other ports have begun implementing "on-shore" power which allows ships to connect to the port's power grid so they can operate without running their onboard diesel engines. Additionally, Long Beach has begun electrifying its cargo cranes that were previously diesel powered via the same grid.
Regulatory Advisory 17 however, excludes the bulk cargo that Stockton primarily handles. These ships unload via on-board cranes which a) eliminates the possibility of electrified cranes and b) creates a larger need for at-berth power generation.
To make at-berth emissions reduction economically favorable via an avoided violations charge, bulk cargo needs to be included in Regulatory Advisory 17.
Once this happens, the Port of Stockton will need to electrify its berths to maintain the growth seen during the last decade. The Port of Long Beach spent $4.6 million on average to electrify each berth, but costs also ranged as low as $2.6 million.
Until the Port of Stockton is able to fully electrify its berths, a "band-aid" solution is one pioneered by the Port of Oakland: a barge-based "bonnet" to capture OGV emissions. This would enable ships to continue their operations while complying with the emissions limit.
Industry
Manufacturing plants are a large source of emissions in Stockton. The main polluters are shown on the map below.
PG&E McDonald Island Underground Storage Station
This is the largest of PG&E's three natural gas storage fields in California, with 87 wells for injection, extraction, and observation. Methane emissions are reported at 526 tons/year, larger than any other facility in the Stockton area. As a short-lived climate pollutant (SLCP), methane is of concern both locally with regards to air pollution and globally as a greenhouse gas many times more potent than carbon dioxide.
DTE
DTE energy is the largest industrial polluter of PM 2.5 in the area. It is a biomass power plant that was recently converted in 2014 from a coal fired power plant. The plant handles nearly 1000 tons of biomass per day, most of which is wood from Central Valley agriculture.
Alto Ingredients (formerly Pacific Ethanol)
Alto Ingredients's most recent emissions data indicates several pollutant types emitted, including volatile organic compounds (VOCs), nitrogen oxides (NOx), and particulate matter (PM). This ingredients manufacturer is located, like DTE, in the industrial area of the AB617 community, and thus contributes to the region's emissions.
Lodi Energy Center
The Lodi Energy Center has multiple pollutants of concern, principally NOx, PM, and total greenhouse gases. Like PG&E's McDonald Island, Lodi Energy Center is located upwind of the AB617 region. A 300 MW combined cycle natural gas power plant, this facility is operated by the Northern California Power Agency (NCPA) and supplies electricity to such entities as the state's Department of Water Resources (DWR) and the San Francisco Bay Area Rapid Transit District (BART).
DTE
DTE is the largest PM 2.5 emitter within the AB617 boundary, so our team chose to analyze the DTE plant to determine if there were potential areas for emissions reduction.
Shown on the right is a simplified diagram of the DTE process. Biomass is burned to heat steam which powers a generator and makes electricity. The vent gas mixture is then sent to a scrubber which partially removes hazardous gases and some particulate matter. The rest is vented to the atmosphere.
According to research done by students at Stanford, the permits for DTE expired in the fall of 2020 (Robertson and Song, 2021).
Currently, the control technology available for particulate matter emissions (both PM 2.5 and PM10) involves a scrubber, which sprays water over the vent emissions and an electrostatic precipitator, or an ESP, which uses high voltages to attract exhaust particles. However, this combination is not the most effective control strategy.
One potential solution to this problem is the implementation of a baghouse, which is able to capture nearly 99% of the particulate emissions from a power plant, although NOx would still need to be captured separately.
A baghouse works by feeding the dirty gas through fabric filter bags. The clean gas exits through the top and the particulates are shaken out and collected at the bottom.
Calculating the cost of this solution is difficult, as the amount of exhaust gas from the DTE plant is not known. However, an inital estimate puts the capital cost in a range from 0.9 to 4 million dollars. This is potentially within the AB617 budget and could provide significant emissions reduction. However, some drawbacks are that this is a temporary solution and would potentially lead to using community funds to bail out polluting facilities. If paid for mainly by the plant to meet new regulations though, this solution shows promise.
Regulations
Enforcement Actions
The air district takes formal enforcement actions for all violations of federal, state, and local rules and regulations within their jurisdiction. This map shows the distribution of enforcement actions within the Stockton AB617 boundary by rule. Click on a point to see the details of each enforcement action.
Notice of Violation (NOV) is issued to document a violation. Under specific circumstances Notice to Comply (NTC) can be issued for first-time, minor violations. NTC does not have a monetary penalty; however, without quick resolution within the established compliance period, an NOV will be issued to the facility. From 2017 to 2020, the District issued 175 NOVs and 37 NTCs within the AB617 boundary.
Excess emissions comprise a large proportion of the total enforcement actions in the AB617 boundary. This chronic non-compliance within the boundary, points to a lack of protection of community health and a gap in compliance within the district. When reallocating resources to enforcement, emission standard compliance at facilities should be evaluated first to best protect community health.
Complaint Process
Residents can file air quality complaints to the district regarding issues such as odors, smoke, dust, illegal burning, and other air pollution violations. During non-business hours a voice message system will forward complaints to the on-call inspector. Inspectors will investigate the site of the complaint to determine if a violation should be issued and if the complaint should be confirmed.
Browse the map and click on a point to see the complaint descriptions and associated resolution.
Notice the cluster of odor complaints around the Port of Stockton.
Although Odor Nuisances comprise one of the greatest categories of complaints, none of the Odor Nuisance complaints resulted in a violation.
The California Health and Safety Code section (41700) states that “no person shall discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons....”
This means that multiple complaints from separate households must be filed regarding odor nuisances for them to result in a violation. This would require significant community organization for basic protection of public health.
This specific policy should be reevaluated by the air district. Inspections using monitors and detection methods to determine the potential contaminants present could provide a better method for validating, rather than volume of complaints that puts the onus on the community members.
This map shows the distribution of complaints throughout Stockton and the resolution. The majority of complaints were unable to be confirmed by the air district, potentially pointing to a lag in response time that prevents inspectors from validating complaints. Increasing the number of inspectors in heavily burdened communities could help increase confirmation rates and result in more NOVs issued, thus holding industrial emitters accountable.
Solution Table
In creating our implementation plan, we considered the following evaluation criteria for our various proposals. These are rough guidelines rather than an exact formula for prioritizing actions, and it is important to note the primacy of community input when making any implementation decision. Though our method of averaging the three criteria for each proposal may not be the best optimization technique, it does provide a good starting point for choosing which solutions will best serve the AB617 community.
Criteria for ranking solutions
Economic
- Cost of implementing the solution
- Greatest benefit per dollar spent
Technological
- Quantity of emissions reduction
- Temporary or permanent solution?
- Timeline of implementation
- Successful implementation elsewhere
Community
- Environmental justice assessment for each solution
- Maximize positive health impacts
- Facilitate community-led dialogue between stakeholders
Note: In parentheses are the reasons the strategy did not get a perfect 5/5 in each category. **On a 1-5 scale, with 5 being best and 1 worst. %Community rankings are a temporary value based on criteria, working with community members will help with a more accurate value ^Averaged among categories
Timeline
The goal of the regulatory implementation plan is to create a habitable environment for Stockton residents, where residents can enjoy outdoor spaces without the worry of the long term health impacts. In 2022, our plan indicates that the air district’s enforcement and complaint process will be audited by environmental justice organizations, revealing disproportionate treatment of industry in EJ communities, including Stockton, and aiding the district in refocusing their enforcement efforts. In 2023, CARB would pass a state-wide carbon tax. This measure forces industrial emitters to pay for their emissions and limits their emission in certain zip codes. This prevents big industries from buying up emission credits (as they could in the cap-and-trade program) and emitting in historically overburdened communities.
theCARB is in the process of expanding Regulatory Advisory 17 to include bulk goods, which are the majority of the cargo handled in Stockton. This regulation would make it more profitable for shipping companies to retrofit their ships for electrification, thus prompting them to turn to other ports. If the Port of Stockton wants to retain its market for bulk cargo, it needs to begin implementing electrification now to keep up with emissions limits. Until the port can retrofit all berths, a bonnet option is an ideal short-term solution to maintain the level of growth Stockton has had in the past decade.
Following discussion with community members to see whether a baghouse is an acceptable control technology for DTE’s emissions, in late 2021, community leaders will meet with DTE leadership and discuss the implementation of a baghouse to conform with stricter PM2.5 regulations and the status of DTE’s expired permit. Contractors will then work to determine a quote for the baghouse cost and will finalize an installation plan by 2022. As a long term goal though, we intend to altogether eliminate DTE from the power grid by replacing both the power it generates with renewable sources and sustainably managing the biomass it is responsible for combusting.
Through implementation of air filtration systems in schools and homes, residents will see decreases in exposure to contaminants such as PM2.5. Air filtration investments represent a cost of $3.6 million to cover 2000 homes and 33 schools. Though not discussed in detail in this report, air filtration systems represent a measure aimed at reducing residents' exposure rates rather than directly reducing emissions. As such, filtration as a short-term action complements long-term pollution reduction measures.
Finally, implementation of a more extensive network of cheaper air monitoring stations could prove invaluable to the community in their fight for environmental justice and clean air.
Several strategies discovered by our team can extend beyond the scope of Stockton to improve accountability of industry, improve air quality, and empower community members. In particular, a balance of short and long-term solutions can result in rapid improvements to community air quality while simultaneously forging ahead with solutions that can transform industrial sectors. Among these are the port solutions, with a short-term bonnet and long-term electrification measures, and DTE solutions, with short-term baghouse filtration technology and long-term transformation into a low-emission renewable energy generator. Regulatory measures that place more responsibility on industry, such as updated complaint and inspection processes, will also aid communities like Stockton in reducing industrial pollution.
Acknowledgements
First and foremost, we are thankful for Matt Holmes and Nicholas Arosemena from Little Manilla Rising for their invaluable guidance and advice while working on this project. In addition, Professor Tina Chow and Bavisha Kalyan were extremely helpful in guiding our group through this process and providing ideas and support along the way. The rest of the CE105 class also gave excellent feedback on our reports and presentations that helped lay out future directions. Amelia Murphy and Daniel Taillant from IGSD provided valuable feedback and important considerations for our analysis. Finally, we acknowledge all parties involved in the AB617 process and the guest speakers we had in class who helped shape our project.
References
Ab, Stockton. “Community Air Monitoring Plan,” 2020.
Alto Ingredients, Inc., formerly Pacific Ethanol. “Overview Of Alto Ingredients, Inc.” 2021. Accessed April 29, 2021. https://www.pacificethanol.com/our-company .
Bennek, Robertson; Song, Ashley. "Stockton Air Pollution" 2021. https://docs.google.com/document/d/1fkUZEmEdjo4uTppKPiMNV3L_EyJ_sJo5YgTyVAObFc0/edit
“California Air Resources Board Pollution Mapping Tool.” Accessed March 13, 2021. https://ww3.arb.ca.gov/ei/tools/pollution_map/ .
Dupin, Chris. “California Plans to Expand Rules Requiring Ships to Use Shore Power.” FreightWaves, 8 Jan. 2020, www.freightwaves.com/news/california-plans-to-expand-rules-requiring-ships-to-use-shore-power.
Goicoechea, Adolfo, et al. “Tackling Air Pollution and Climate Change through Energy and Buildings - Final Report.” April 23, 2021. 31. Accessed May 3, 2021. https://docs.google.com/document/d/1wp2qFP-_uM1je1KrL2_Wr2wZZTwErGHRCh1_6Vee_C8/edit .
https://fox40.com/wp-content/uploads/sites/13/2016/02/promo278992020.jpg?w=640. Accessed May 8, 2021.
https://www.dtepowerandindustrial.com/wp-content/uploads/2016/07/BTW9609_copy.jpg. Accessed April 29, 2021.
“Lodi Energy Center, California, US - Power Technology | Energy News and Market Analysis.” Power Technology. Accessed April 29, 2021. https://www.power-technology.com/projects/lodi-energy-center-california-us/ .
Pacific Gas & Electric Co. “Natural Gas Storage.” Accessed April 29, 2021. https://www.pge.com/en_US/safety/gas-safety/natural-gas-storage.page .
U.S. Department of Commerce. “U.S. Census Bureau QuickFacts: Stockton City, California.” Accessed April 23, 2021. https://www.census.gov/quickfacts/fact/table/stocktoncitycalifornia/PST045219#qf-flag-X .
