2008 PM2.5 Plan 

## Chapter 9

Conclusion2008 PM2.5 Plan This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 9: Conclusion

2008 PM2.5 Plan 9-1 

## Chapter 9: Conclusion

9.1 ATTAINMENT OUTLOOK

As required by EPA (72 FR 20601) and as explained in C hapter 2, all nonattainment

areas are to attain the 1997 PM2.5 standard as expeditiously as practicable, but by an

initial attainment deadli ne of April 5, 2010 (based on 2007, 2008, and 2009 data, making 2009 the compliance year). Areas demonstrating that attainment is impracticable by compliance year 2009 can re ceive an extension of up to five years, making the final attainment deadline Apri l 5, 2015 (based on 2012, 2013, and 2014 data, with 2014 as the compliance year).

A full extension to compliance year 2014 is not automatic, and some areas may obtain shorter extensions. To be granted an extensi on, areas must show that attainment by 2009 is impracticable and that the area will attain the st andard by an alternative date that is as expeditious as practicable. Ar eas must evaluate the attainment potential for each compliance year between 2009 and 2014. Regional modeling was performed for the design value for 2014 by ARB. Receptor modeling was performed for design values for all years from 2009 to 2014 and the year for each site to comply with the annual standard is reflected in Table 3-2. Receptor modeling analysis projects that Bakersfield will not attain prior to 2014. The Regional model evaluates sites in Bakersfield, not evaluated by the receptor mode ling, that have higher proj ected values for the year 2014. The Receptor and Regiona l modeling predictions are in very close agreement as

shown in Table 3-5 and ther efore it is reasonable to conclude that both modeling approaches project attainment by but not before 2014. Additional support for this conclusion arises from review of proposed reductions. The commi tment from ARB for

extensive NOx reductions in 2014 is necessa ry to achieve attainment. Only if a significant portion of these reductions were implemented ahead of the proposed commitment would it be likely to ac hieve compliance by an earlier year.

Modeling conducted for this plan) indicate s as discussed in Chapter 3 that NOx

contributions to ammonium ni trate are the dominant source for annual PM2.5 levels in the Valley. Figure 9-1 shows that ammonium ni trate is, by far, the largest contribution to the Valley’s annual PM2.5 concentration re sulting in almost half of the annual concentration. Since NOx is the limiting compound for ammonium nitrate in the Valley 1

, NOx controls reduce ammonium nitrate the most effectively. Other contributions are collectively equal to the impact of ammoni um nitrate and must also be addressed through emission reductions. Principle sour ces of directly em itted PM2.5 include geologic material, motor vehicl e emissions and tire and brake wear, organic carbon and vegetative burning. Atmospheric formation of secondary PM2.5 is dominated by NOx

formation of ammonium nitrat e followed by SOx formation of ammonium sulfate with

1 See Section 3.2.6 of this plan; Lurmann, Frederick W. et al. (December 2006). “Processes Influencing Secondary Aerosol Formation in the San Joaquin Valley during Winter.” Journal of the Air and Wast e Management Association 56: 1679-1693; or Kleeman, Michael J.; Ying, Qi; and Kaduwela , Ajith (2005). “Control Strategies for the Reduction of

Airborne Particulate Nitrate in Ca lifornia’s San Joaquin Valley.” Atmospheric Environment 39: 5325-5341.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 9: Conclusion

2008 PM2.5 Plan 9-2 small contributions of secondary organic aeros ol from motor vehicles and other organic

carbon sources. The contributions shown in Figure 9-1 are 2014 projections after implementation of all reductions. Even after the reductions in 2014, all of the source categories contribute a significant percentage of the annual concentr ation. It should also be noted that during some months the c oncentration of ammonium nitrate is very low and PM2.5 is dominated by directly em itted sources (geologi c, motor vehicle, organic carbon and vegetative burning) and secondary ammonium sulfate.

Figure 9-1 Percent Contribution to Annual PM2.5 Concentrations

• Tire and brake wear includes on-road sources only

• Percentages shown are for the 2014 annual receptor modeling values in Bakersfield

Table 9-1 shows the 1997 annual PM2.5 sta ndard attainment outlook for the San Joaquin Valley as a basin- wide average for compliance years 2009 through 2014. The emissions inventory (including rules ado pted as of December 2006) does not meet the emissions targets. Table 9-1 compares the emissions in ventory that will result from this plan’s aggressive control strategy to the attainment targets. Each possible attainment year is evaluated. According to this analysis, the San Joaquin Valley will reach attainment by 2014 with the reduction s that will be achieved by the District’s and ARB’s regulatory control measures. Howeve r, the District has several reasons to expect that attainment will be achieved earlier than 2014.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 9: Conclusion

2008 PM2.5 Plan 9-3 Table 9-1 San Joaquin Valley PM2.5 Attainment Outlook

Ref# 2009 2010 2011 2012 2013 2014

1 Baseline annual NOx inventory, before Plan control strategy (Table B-2) 500.9 469.5 443.3 424.4 393.1 376.2

2 NOx Emissions Target (Chapter 3) 1 291.2

3 District control measure commitments (Table 6-3a) -2.43 -3.24 -4.26 -8.56 -8.82 -8.97

4 ARB control measure commitments (Chapter 7) 0.0 0.0 0.0 0.0 0.0 -76.0

5 Emissions inventory with 2008 PM2.5

Plan controls (Lines 1, 3, and 4) 498.5 466.3 439.0 415.8 384.3 291.2

6 Baseline annual PM2.5 emissions inventory, before Plan control strategy (Table B-1) 79.8 79.0 77.9 77.0 75.9 75.0

7 Direct PM2.5 Target (Chapter 3) 1 63.3

8 District control measure commitments (Table 6-3b) -1.60 -2.96 -4.46 -6.69 -6.70 -6.70

9 ARB control measure commitments (Chapter 7) 0.0 0.0 0.0 0.0 0.0 -5.0

10 Adjusted emissions inventory with 2008

PM2.5 Plan controls (Lines 6, 8, and 9) 78.2 76.0 73.4 70.3 69.2 63.3

11 Baseline annual SO 2 emissions inventory, before Plan control strategy (Tabl e B-3) 26.4 23.0 23.3 23.6 23.8 25.5

12 SO 2 Target (Chapter 3) 1 24.6

13 District control measure commitments (Table 6-3c) -0.06 -0.11 -0.16 -0.92 -0.92 -0.92

14 ARB control measure commitments (Chapter 7) 0.0 0.0 0.0 0.0 0.0 0.0

15 Adjusted emissions inventory with 2008

PM2.5 Plan controls (Lines 11, 13, and 14) 26.3 22.9 23.1 22.7 22.9 24.6

Attainment? No No No No No Yes Projected attainment year 2014

1 Chapter 3 shows that the 2014 inventory with plan controls will bring the Valley into attainment

9.1.1 Attainment before 2014

As explained in Chapter 3, the receptor modeling conducted for this plan provides a conservative analysis. Often, the reductions target yielde d from rollback is a high estimate of what will actually be required for attainment. This was evidenced in the District’s PM10 plans: rollback projected attain ment by 2010, but the Valley attained the PM10 standards based on 2004-2006 data. By using a similar, conservative analysis in this PM2.5 Plan, the Valley could attain the 1997 standard early (and subsequent reductions will help bring the Valley cl oser to the tougher, 2006 federal PM2.5 standard).

The estimated NOx, direct PM2.5, and SO 2 and other reductions expected from the

District’s exhaustive control measure analysis are based on the best technical information available at the time this plan was compiled. During the rule developmentSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 9: Conclusion

2008 PM2.5 Plan 9-4 process for each measure, District staff will consider the most effective technologies available; rules may achieve more reduc tions than expected. Control measure feasibility studies may also reveal additi onal opportunities for reductions. ARB measures will achieve significant reductions that will greatly contri bute to the Valley’s 2014 attainment. However, ARB is not commi tted to pre-2014 emissi ons reductions at this time. It is probable that, in actualit y, ARB measures will achieve some pre-2014 reductions, and these could also contribute to attainment before 2014.

The District’s incentive programs (described in section 6.5) achieve further reductions that, for SIP creditability reasons, are not quantified for attainm ent. The District still expects that the reductions achieved by these highly successful programs will help

ensure attainment of the 1997 PM2.5 standar d early and faster progress towards the

2006 PM2.5 standards.

Figure 9-2 Annual PM2.5 Principal Components and ReductionsSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 9: Conclusion

2008 PM2.5 Plan 9-5 Figure 9-2 provides a graphic display of t he improvement that will be provided by the combination of District reduction efforts, with the exception that District incentive reductions that are not yet funded cannot be included per EPA calculation procedures. This figure displays PM2.5 concentrations di rectly from the receptor model. EPA procedures for the calculation of a future year design value reduce the 2014 projection to 14 micrograms. The combined sources of directly emitted PM2.5 and ammonium nitrate are clearly the two largest segments and have the most significant associated

reductions. Ammonium sulfate is not in consequential and is also addressed by

reduction efforts.

9.2 CONTINGENCY MEASURES

9.2.1 Introduction

Contingency measures achieve emission reductions beyond what is needed for the

modeled attainment demonstration or t he Reasonable Further Progress (RFP) demonstration. Then, if the emission reduc tions actually achieved are not enough to

meet the RFP milestones or the attainment target, c ontingency measure reductions quickly make up the difference. The discuss ion of contingency measures in a state implementation plan (SIP) should include a trigger mechanism, an implementation schedule, and an indication that the reduction s from the measures were not used to demonstrate RFP or attainment (72 FR 20642-20643).

Contingency measures must be fully adopted rules or contro l measures that are ready to be implemented quickly upon failure to meet RFP or failure of the area to meet the standard by its attainment date (72 FR 20643). EPA notes that nothing precludes a State from implementing c ontingency measures befor e they are triggered (72 FR 20643). All available measures needed to dem onstrate attainment of the standards must be considered first; all remaining meas ures should be considered as candidates for contingency measures. EPA also notes, “I t is important not to allow contingency measures to counteract the developm ent of an adequate control strategy demonstration” (72 FR 20643) and that “The key is that the statute requires that contingency measures provide for additional em ission reductions that are not relied on

for RFP or attainment and that are not included in the demonstration (72 FR 20642).

The 1990 Amendments to the fe deral Clean Air Act do not specify the number of contingency measures that plans must in clude nor do they specify the magnitude of emission reductions to be covered by contingency measures. However, in the PM2.5 Implementation Rule , EPA recommends that the “emissions reductions anticipated by the contingency measures should be equal to appr oximately 1 year’s worth of emissions reductions necessary to achieve RFP for the area.” (72 FR 20643).San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 9: Conclusion

2008 PM2.5 Plan 9-6 A nonattainment area subject to federal contingency measure provisions has two general options for providing emission r eductions above and beyond those needed to meet federal requirements for reasonabl e further progress and for attainment

demonstration:

 Option 1: Develop and adopt rules that would only be implemented should an

area fail to meet a federal milestone; emission reduction s from these rules would go into effect after an area fails to meet a federal milestone.

 Option 2: Determine if rules adopted to meet attainment r equirements provide emission reductions above and beyond t hose required for reasonable further progress, and to use these reductions as contingency reductions since they are above and beyond those needed for meeting f ederal milestones. The second option is stronger in that t he “extra” emission reductions are working year after year for expeditious attainment of the standard, and are not contingent upon failure of a milestone in order to go in to effect. Option 2 also reflects EPA’s position as given in the PM2.5 Implementation Rule (72 FR 20642): “The EPA has approved numerous SIPs under this interpretation—i.e., that use as contingency measures one or more Federal or local measures that are in place and provide reductions that are in excess of the reductions required by the

attainment demonstrati on or RFP plan. (62 FR 15844, April 3, 1977; 62 FR 66279, December 18, 1997; 66 FR 30811, June 8, 2001; 66 FR 586 and 66 FR 634, January 3, 2001.).”

As noted in the 2007 AQMP prepared by the South Coas t Air Quality Management District (SCAQMD 2007), numerous issues a ffect the implementation of contingency

measures. These include availa bility of District resources to implement and enforce the measure, cost effectiveness of the measure, effectiveness of the measure in reducing the emissions, availability of methods to quantify emission reductions, potential economic impacts, and potential adver se environmental impacts.

Nonattainment areas with sign ificant attainment challen ges have developed aggressive and far-reaching emission reduction measur es to meet federal Clean Air Act requirements. The result of this “no st one left unturned” policy is that when viable emission reductions are identified, they are implemented in order to bring the area into attainment as expeditiously as practicable. The reductions are usually not held in reserve to be used only if an area fails to meet a milestone. Consequently, the Option 1 contingency measures are not realistic fo r areas such as the SJVAB and the South Coast Air Basin, which have pervasive oz one and particulate matter attainment challenges. Any feasible approach for reduc ing emissions that has been identified has been implemented. However, because areas su ch as these are driven by the need to obtain very large emission reductions to attain the standards, they usually have reductions in excess of those needed to meet reasonable further progress requirements; this consequence makes Opti on 2 more viable for contingency measure

reductions in areas with substantial ozone and PM attainment challenges. Option 2 is

also in line with EPA’s direction to first dev elop the control program for attainment and then to use excess reductions as candidates for contingency measures (72 FR 20643).San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 9: Conclusion

2008 PM2.5 Plan 9-7 Control measures developed and enhanced by the District si nce the passage of the

1990 federal Clean Air Act Am endments have become increas ingly stringent, leaving

little room for “extra” reductions that coul d be set aside to fulfill general contingency measure requirements. Th ree recent analyses prepared and adopted by the District to meet federal and state air quality planning r equirements demonstrate that the District’s
control measures often lead the State in terms of stringency of emissi ons control. First, the analysis of rules affecting emissions of particulate matter and its precursors (including VOC and NOx meas ures) that was required by Section 39614 of the California Health and Safety Code (also refe rred to as the Senate Bill 656 analysis)

shows that for the 103 control measures identi fied by ARB as required by this section of the Health and Safety Code, 37 of the Distric t’s measures had the best level of emission control statewide, and another 39 District measures were equivalent to the best level of control. The bulk (>92%) of the remaining measures were for source categories not found in the District (SJVAPCD 2005). This analysis shows that the District rules are the most stringent in the State, thus offering little room for further emission reductions. Second, the RACT SIP Analysis prepared by District staff to meet federal Clean Air Act planning requirements and adopted by the Dis trict Governing Board in August 2006

shows that District rules meet or exceed RA CT for all applicable EPA source categories (SJVAPCD 2006). EPA’s historic definition of RACT has been the lowest emissions limitation that a particular source is capabl e of meeting by the application of control technology that is reasonably available, considering technological and economic feasibility (70 FR 66016). Third, ARB’s analysis of the District’s stationary source emission control program in late fall 2007 conc luded that the Distric t’s control measures are as stringent as any in the state, and lead the state in many source categories (ARB 2007).

9.2.2 Contingency Measures

9.2.2.1 New Commitments

If the Valley fails to meet RFP in 2009 or 2012, or fails to attain the standard by April 2015, the District proposes to request that ARB proceed with accelerating the adoption and/or implementation of any remaining ARB control measures that have not yet been adopted or fully implemented, to the extent feasible. As shown in Chapter 7 of this 2008

PM2.5 Plan , the state emission control measures proposed by ARB as part of the adopted state strategy do not begin to produce emission reduc tions until 2014; consequently, the state measures offer no pot ential to help with PM2.5 RFP milestones for 2009 and 2012. The timing of the state reductions is es pecially problematic, since
about 80% of the NOx emission inventory in the Valley is caused by mobile sources
under the control of the State of California. State emission r eductions that occur prior to 2014 would go a long way to providing contingen cy reductions for 2009 and 2012. This request would be done through formal District Governing Board resolution at a regularly-scheduled Governing Board hearing within two months after EPA notification

of a failure to m eet an RFP milestone.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 9: Conclusion

2008 PM2.5 Plan 9-8 9.2.2.2 Surplus Reductions from Adopted Measures

9.2.2.2.1 Ozone No nattainment Fee

In May 2002, the District adopted Rule 31 70 (Federally Mandated Ozone Nonattainment Fee) that requires each affected major stat ionary source in the District to pay a fee, based on emissions, if the District does not attain the national ambient air quality standard for 1-hour ozone by the deadline for its classification. Since the District is

classified as extreme nonattain ment for the 1-hr ozone NAAQS, the attainment date is November 15, 2010. In its Final Rule implementing the 8-hr ozone standard, EPA

indicated that collection of these fees would not be necessary after the June 15, 2005 revocation of the standard. However, in 2007, the D.C. Circuit Court directed EPA to

reinstate the nonattainment f ee provisions for the 1-hr ozone standard, even though the

standard itself was revoked. The Distric t has submitted adopted Rule 3170 through ARB to EPA, though EPA has not yet acted on the rule. Should the Valley fail to attain the 1-hr ozone standard by No vember 15, 2010, the District, under the current rule, would start assessing fees in May of 2012. The District would use the funds generated by these fees to implement ot her air pollution control progra ms identified by the District. Funding would reach District programs in time to help with the 2012 RFP milestone 2 or the 2014 PM2.5 attainment date.

It is important to note that inclusion of Rule 3170 as a contingency measure for PM2.5 does not imply that the District is counti ng on failing to attain the former 1-hr ozone NAAQS. On the contrary, current monitori ng data show that the SJVAB is on track to attain the former 1-hr ozone NAAQS by its st atutory attainment dat e of November 15, 2010. In the unlikely event that the SJVAB does not attain the former 1-hr ozone NAAQS, then emission reductions not used in demonstrating RFP or attainment for

PM2.5 would be available in time to m eet the federal requ irements for PM2.5 contingency measures, and t hus would be implemented.

The amount of emission reductions av ailable as PM2.5 contingency from implementation of Rule 3170 is a function of t he dollars/ton of the fee (which is tied to the rate of inflation), the num ber of affected sources, the cost of emission reductions in future years, and other factors. Thus it is premature at present to estimate the emission reductions from this contingency m easure for the years 2013 or 2016.

9.2.2.2.2 Incentives

Section 6.5 of this 2008 PM2.5 Plan identifies substantial in centive-based funding that will be spent by the District to achieve emi ssions reductions. Most of these emissions

reductions were not used in RFP evaluations or attainment demonstrations in this plan, for a variety of reasons. 3 First and foremost is that while reductions from some funding are SIP creditable (e.g., Moyer Program funds), not all of the incentive-based reductions

2 States failing to meet an RFP mileston e generally have one calendar year to implement a remedy to correct the shortfall. So the District would have until December 31, 201 3 to implement emission reductions equivalent to the shortfall that led to missing the 2012 RFP milestone.

3 ARB staff included appropriated Moyer funds in the emission inventory used in this plan. Future Moyer and nonMoyer funds are not reflected in RFP or attainment demonstrations.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 9: Conclusion

2008 PM2.5 Plan 9-9 are SIP creditable at this time. As noted in a separate resolution adopted by the District Governing Board in April 2007 as part of adoption of the 2007 Ozone Plan , the District has committed to implement various pr ocedural, record keeping, and reporting requirements to ensure that t he all incentive-based reductions achieved by the District meet EPA requirements and guidance for SIP cr editability. These incentive program changes are planned to be in place in time for the 2009 and 2012 RFP milestone years for PM2.5, such that emission reductions from the District’s substantial incentive funding over this time could be used as contingencie s. And regardless of the timing of the incentive program changes, reductions from current programs such as Moyer are SIPcreditable but were not used for RFP or attainment demonstrations in this 2008 PM2.5

Plan . Likewise, substantial reductions from anticipated funding sources such as Proposition 1B (Section 6.5.3) were also not used, even though they are interpreted to be SIP creditable, primarily because final deci sions regarding allocation of these funds by ARB’s Board will not occur until later in 2008. Based on information in Tables 6-6 through 6-8, the combination of incentive funds known at this time to be available to the District for possible use as PM2.5 cont ingency measures would generate about $90 million per year, which provides an estima ted 3.6 tpd of NOx emissions each year. 4
After five years, for example, the cumulative reduction would be 18 tpd.

9.2.2.2.3 Excess Reductions

The bulk of the emission reductions needed to attain the standards in this plan are achieved through ARB’s on-going mobile sour ce emission control program, which has been very successful in reducing emissions in the Valley and throughout California. The methods used in Chapter 8 to calculat e emission reductions needed to meet RFP goals withheld reductions that in turn becom e excess and thus meet the requirements of PM2.5 contingency measures. For 2009 and 2012, 1% of PM2.5 and 3 % of NOx baseline emissions are being reserved as cont ingencies; these result in reductions of about 1 tpd of PM2.5 direct and about 17 tpd of NOx. The 2015 mobile source program reductions from ARB are relied upon to meet 2014 contingency requirements.

References

ARB (2007). ARB Staff Report to the Air Resources Board: Accelerating San Joaquin Valley Air Quality Progress, California Environmental Protection Agen cy, Air Resources Board, November 6, 2007, page

14.

SCAQMD (2007). South Coast Air Quality Management District, 2007 Air Quality Management Plan, SCAQMD, Diamond Bar, California, June 2007, page 9-1.

SJVAPCD (2005). San Joaquin Valley Unified Air Pollu tion Control District, SB656 Particulate Matter (PM) Control Measure Implementat ion Schedule, SJVAPCD, Fresno, California, June 16, 2005.

SJVAPCD (2006). San Joaquin Valley Unified Air Pollution Control District, 8-hr Ozone RACT SIP Analysis, SJVAPCD, Fresno, California, August 2006.

4 This estimate is based on data from the 2007 Ozone Pl an, which noted that 1 tpd of permanent NOx emission reductions cost about $25 million.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 9: Conclusion

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