Phillip Kiddoo-Keynote

Air Pollution Control Officer

Great Basin Unified Air Pollution Control District


Mr. Kiddoo began his career with the District over a decade ago as a Research Systems Analyst and spent the last five years as its Senior Research and Systems Analyst. His work included sophisticated air monitoring and development of data analyses of dust pollution from the dried Owens Lake bed. Mr. Kiddoo previously worked for the California Department of Fish and Wildlife and the University of California White Mountain Research Station. He was born in Bishop, raised in Mammoth Lakes and Bishop and is married to wife Brenda. Their sons, Reymond and Dezert Sky are students at Bishop Union High School.

Title: Owens Lake: From Serious Non-Attainment for PM10 to 48.6 mi2 of Dust Control

Keynote 8:10am - Friday, May 13th

Abstract: On August 7, 1987, the Environmental Protection Agency (EPA) designated the Owens Valley Planning Area (OVPA) as one of the regions in California in violation of the National Ambient Air Quality Standard (NAAQS) for particulate matter less than 10 micros in diameter (PM10) and designated the OVPA as a “serious non-attainment area”. PM10 is a criteria pollutant regulated by the federal Clean Air Act, 42 U.S.C. Section 7401 et seq., as amended  (CAA).  Under the NAAQS adopted pursuant to the CAA, PM10 levels may not exceed an average concentration of 150 micrograms per cubic meter (μg/m3) during a 24-hour period more than one time per calendar year averaged over three years.

The serious non-attainment designation for PM10 in the OVPA is strictly attributed to air pollution from Owens Lake located in Inyo County, California, caused as a direct result of the drying of the lake due to water diversions by City of Los Angeles Department of Water and Power (City). By 1913 the completion of the Los Angeles Aqueduct had diverted, in entirety, the sole tributary of Owen Lake, the Owens River, over 200 miles south, providing water and power to the residents of Los Angeles. The exposed Owens Lake bed is comprised primarily of dry saline soils and crusts that are the source of wind-borne dust pollution during wind events where elevated concentrations of PM10 prior to any dust mitigation, exceeded the NAAQS up to approximately one-third of the days per year and up to100 times the standard on the largest exceedance days.

The Great Basin Unified Air Pollution Control District (District) is a unified district as provided by Division 26, Part 3, Chapter 3 of the California Health and Safety Code and consists of all of Inyo, Mono and Alpine counties. The District has regulatory authority over air quality issues in the OVPA where Owens Lake is situated.  California Health and Safety Code Section 42316, (CHSC 42316) enacted by the California Legislature in 1983, provides in part that the District has authority to require the City to undertake reasonable measures at Owens Lake in order to address the impacts of its activities that cause or contribute to violations of air quality standards.

To bring the OVAP into attainment for the federal air quality standard, the District, under authority of CHSC 42310, submitted to EPA its 1998 State Implementation Plan (SIP) that was approved the following year with an attainment deadline of December 31, 2001 that was extended five years. A series of subsequent SIPs were approved by the District Governing Board in 2003 and again in 2008 due to a failure to attain issued by EPA in 2007.  After years of litigation between the District and City over supplemental control requirement determinations, in 2014 the California Superior Court ruled in favor of the District. With a court endorsed 2014 Stipulated Judgment, 3.62 mi2 of additional dust control mitigation was required to be constructed by the City with a December 31, 2017 deadline to achieve attainment of the NAAQS.  On April 13, 2016, a final 2016 SIP was presented to the District Governing Board for proposed adoption requiring the City to construct, operate and maintain dust controls on an area totaling 48.6 mi2.  From 2000 through the 2017-18 budget year, the price tag to control PM10 emissions at Owens Lake is projected to surpass $2,100,000,000 (2.1B) dollars.  After construction is complete in 2017, projection of costs for ongoing operations and maintenance with purchasing of water from other sources to offset the 60,000 - 95,000 acre feet of water used on Owens Lake for dust mitigation, an additional $75,000,000 (75M) will be spent annually.