Technical and Clarifying Modifications to April 26, 2007 Revised Draft Air Resources Board’s Proposed St ate Strategy for California’s 2007 State Implementation Plan
and May 7, 2007 Revised Draft Appendices A through H

The following are technical modifications to the Revised Draft of the Proposed State Strategy for California’s 2007 Im plementation Plan. The changes are briefly described below, and a strikeout/ underlined version of the corresponding page(s) is also attached.

Technical Modifications to April 26, 2007 Revised Draft:

1. Page 4. Changes an error in the descr iption of estimated tons per day NOx reductions from mobile sources in the South Coast between 2006 and 2014.

2. Page 23. Adds reference to federal Bureau of Land Management.

3. Page 27. Makes a clarifying cha nge describing SOx reductions from petroleum refining.

4. Page 29. Removes specific referenc e to federal and international sources.

5. Page 31. Corrects pesticide inventor y numbers in the table, “San Joaquin Valley – Top sources of ROG”. (Note: There is no change to the official planning inventory numbers specified in Appendix A. Incorrect numbers were inadvertently included in the table.)

6. Page 35. Adds clarifying langua ge about ARB’s and U.S. EPA’s authority to
control mobile sources.

7. Page 47. Adds clarifying langua ge about ARB’s and U.S. EPA’s authority to
control mobile sources.

8. Pages 59-62. Adds two rows to expec ted emission reduction tables showing the impact of the adopted St ate measures and making related clarifying changes to the tables. (Note: No impact on ARB SIP commitment numbers.)

9. Page 63. Changes an inco rrect page number reference.

10. Page 67. Adds clarifying langua ge about ARB’s and U.S. EPA’s authority to
control mobile sources.

11. Page 68. Adds clarifying lan guage regarding ARB’s and U.S. EPA’s authority to control in ternational sources.Technical Modifications 12. Page 70. Adds clarifying language to the notes describing the elements of the attainment demonstration table.

Technical Modifications to May 7, 2007 Revised Draft: Appendices A through H

1. Appendix A, Page 100. Corrects a summation erro r for PM2.5 grand total numbers for the San Joaquin Valley.

2. Appendix A, Page 103. Corrects a summation error for SOx grand total numbers for the San Joaquin Valley.

3. Appendix C, Pages 1-4. Interstate Transport. Adds clarifying language to long-distance transport, clarifies dist rict headings and make other wording clarifications.

4. Appendix D, Page 2. Deletes refe rence to federally-approved transport couples in regards to RFP demonstrations.Technical Modifications Technical Modifications to Page 4 of the April 26, 2007 Revised Draft

The proposed mobile source strategy and SIP commitments are described in Chapter 3. Individua l measures are described in more detail in Chapt er 5. The figure below shows the decrease in em issions for passenger vehicles, heavyduty trucks, and construction equi pment between now and 2014 with the proposed State Strategy. Due to increas ingly more stringent mobile source controls, emissions from these categorie s are all on a downward trend, despite growth in population, travel, and the economy. The new measures in the proposed State Strategy would accelerate these emissions reductions. ARB staff is proposing an aggressive new emission reduction commitment of 122 tons per day of NOx reductions in the South Coas t by 2014 in order to meet the region’s PM2.5 attainment needs. This would bring the total mobile source NOx
reductions achieved betw een 2006 and 2014 to about 450 430 tons per day.



### Impact of State Strategy by 2014
South Coast - NOx

0 50 100 150 200 250

2006 2014
Trucks 2006 2014 Passenger
Vehicles 2006 2014
Construction

Equipment

In contrast to passenger vehicles, tru cks, and construction equipment that show substantial emission decreas es with natural fleet turnover, locomotives and ships show an increase in emissions without the proposed State Strategy. Locomotive emissions have been decreasing in the South Coast due to the accelerated introduction of the cleanes t current technology (Tier 2). However, as shown below, growth overtakes this benefit by 2014. The proposed State Strategy
includes a measure to accelerate intr oduction of the next generation of clean technology once U.S. EPA adopts its pr oposed new Tier 4 standards. The 2014 benefits assume Tier 4 engines becoming available in 2012. The 70 percent reduction projected for 2020 is based on t he proposed measure to accelerate the introduction of Tier 4 locomotives to California.Technical Modifications Technical Modifications to Page 23 of the April 26, 2007 Revised Draft

Environmental Justice

The SIPs consist of strategies designed to bring a region’s air quality into compliance with federal standards. SIPs must be designed to ensure air quality standards throughout the ent ire region, so achiev ing air quality standards provides public health benefits to every community. This makes SIP implementation important to meeting ARB’s communi ty health and environmental justice goals. As part of our environmental justice progr am, ARB has initiated air quality studies in several communities and continues to focus resources on mobile source enforcement in environm ental justice communities. ARB’s Air Quality and Land Use Handbook, approved by ARB in May 2005, provides guidance to help improve local land use decisions that can negatively impact public health at the community level.

ARB’s SIP strategies have a significant nexus to community health due to the emphasis on cleaning up the legacy fleets of diesel engines. Much of the large equipment and vehicles that help constr uct our buildings and highways and move our goods are not well controlled and have very long lives. Adopting rules to clean up these fleets will have an imm ediate and significant effect on the communities where these sources are concentrated.

Regional Haze

The same particulate air pollutants that affect public health also extinguish and scatter light, thereby obscuring visibility. The federal Clean Air Act set the farreaching goal of achieving natural visibility conditions by 2064 in the nation’s most treasured parks and wilderness areas. Of the 156 designated areas, 29 are in California, managed by the National Park Service, the federal Bureau of Land Management, and the U.S. Forest Service. T herefore California is working in concert with fourteen other western states to reduce controllable emissions of particulates so that regional haze is reduc ed in the western region of the country. In 1999, the U.S. Environmental Protecti on Agency published rules to guide the preparation of Regional Haze State Impl ementation Plans to reduce regional haze.

ARB is currently preparing the first regi onal haze plan for the entire State, for transmittal to EPA by the December 17, 2007 deadline. General trends in California since the 1990s show that emi ssion controls are improving visibility in our parks and wilderness areas . The regional haze plan will show how these controls constitute reasonable progress alo ng the path to natural visibility. In 2012, ARB will conduct a mid-course review of measured visibility changes and analyze how emission reductions implem ented to achieve the 8-hour ozone and the PM2.5 standards will move the State further along the pat h to natural visibility in the future.Technical Modifications Technical Modifications to Page 27 of the April 26, 2007 Revised Draft

SOx . Sulfur oxide emissions are dominat ed by the mobile source category of ships and commercial boats. Evaporative losses from petroleum Petroleum refining (a stationary source) are is another significant source of SOx. The other sources that make up 5 percent or more of the SOx inventory are locomotives and mining and cement manufacturing.

Direct PM2.5 . Directly emitted PM2.5 comes main ly in the form of smoke, soot, and dust particles. Major sources include managed burning and agricultural burning; dust generated by vehicles traveling on paved and unpaved roads, residential fireplaces, cooking and fuel co mbustion; and particle emissions from diesel-fueled engines on trucks, ships, and construction equipment. While soot from diesel engines is not a major porti on of the entire dire ct PM2.5 emissions inventory, it is a major health concern, as it is a toxic air contaminant that can cause premature death.

Forecasting Future Emissions

Estimates of projected future emissi ons depend on two independent variables: growth and control. Different methods ar e used to estimate t he future growth of emission sources based on their type. And future emission controls are incorporated into the projected emi ssions for each source category based on when the controls are implemented, how much the controls reduce emissions, and how many units (vehicles, consum er products, etc.) are affected.

The charts on the next page show the change in total projected statewide emissions for NOx, ROG, and SOx from 2006 to 2023 and the relative emissions change in each of these emission source categories. They reflect projected growth in each category combined with the benefits of the existing control program (those emission controls adopted prior to 2007). For example, SOx emissions as a category continue to grow due to ship emission increases. This makes ship SOx emissions a high priority for control in the new SIP strategy. NOx and ROG emissions are decreasing as a result of existi ng control programs despite substantial growth in population, travel, and the economy.

ARB uses two computer models to simu late and forecast emissions for on- and off-road sources. For cars , sport utility vehicles, minivans, and trucks, ARB used EMFAC2007. For off-road vehicles and equipment, ARB used OFFROAD2007. Both models were released for public us e in November 2006 after a multi-year development process. As required by federal guidance, EM FAC2007 uses the latest fleet information for vehicles age and population. The data is developed from the California Departm ent of Motor Vehicle registration data through 2005. For SIP purposes, as required by State la w, vehicle activity is based on local transportation agency projections, or Calif ornia Department of Transportation data, if local data are not available.Technical Modifications Technical Modifications to Page 29 of the April 26, 2007 Revised Draft

Here are some things we have learned by analyzing the emissions inventory for these two areas:

• South Coast NOx emissions are signi ficantly impacted by goods movement, with the ships, trains, trucks, and off-road equipm ent that move goods contributing about 30 percent of all South Coast NOx emissions. Aircraft NOx emissions are also increasing.

• The impact of goods movement in the San Joaquin Valley is felt mostly by the emissions contribution of heavy-duty trucks, which are projected to remain the largest NOx emitter through 2023.

• Emissions of NOx from manufacturing and industrial sources in the San Joaquin Valley become increas ingly significant as em issions from mobile sources decline in the future.

• The large population in the South Coast is the main reason why consumer product emissions are projected to become the number one ROG emissions source by 2014.

• San Joaquin Valley ROG emissions are significantly impacted by agricultural sources such as livestock waste.

• The existing emission control program will cut heavy-duty truck NOx emissions about 70 percent in the San Joaquin Valley and South Coast by 2023, but they need to be cut even more by new strategies to attain ozone and PM2.5 standards.

• Mobile sources under subject to federal and international standards jurisdiction (like ships, l ocomotives, and aircraft) contribute an increasingly greater proportion of total emissions, especially NOx, in future years as emission increases due to growth over whelm the existing control program, while emissions of mobile sources under State jurisdiction decrease due to stringent controls.Technical Modifications Technical Modifications to Page 31 of the April 26, 2007 Revised Draft

South Coast Air Basin – Top Sources of ROG Summer emissions, tons per day
Source Category 2006 2014 2023

PASSENGER VEHICLES 207 112 76

CONSUMER PRODUCTS 101 103 110

RECREATIONAL BOATS 64 53 51 OFF-ROAD EQUIPMENT (LAWN AND GARDEN) 52 40 38 ARCHITECTURAL COATINGS (PAINTS AND THINNERS) 31 29 31 OFF-ROAD EQUIPMENT (COMMERCIAL, INDUSTRIAL) 28 15 12 PETROLEUM MARKETING (GASOLINE EVAPORATIVE LOSSES) 27 28 31 COATINGS (PAINTS AND THINNERS - NON ARCHITECTURAL) 27 25 28

GASOLINE-FUELED COMMERCIAL TRUCKS 24 13 8

GAS CANS 21 10 7 OFF-ROAD EQUIPMENT (CONSTRUCTION AND MINING) 20 12 8

TOTAL OF TOP CATEGORIES 600 441 399

TOTAL 732 567 534

TOP CATEGORIES PERCENT OF TOTAL 82% 78% 75%

San Joaquin Valley – Top Sources of ROG Summer emissions, tons per day
Source Category 2006 2014 2023

PASSENGER VEHICLES 62 37 24

WASTE DISPOSAL/COMPOSTING 57 72 80 LIVESTOCK WASTE (DAIRY CATTLE) 40 33 41 OIL AND GAS PRODUCTION (EVAPORATIVE LOSSES/FLARING) 28 26 23

CONSUMER PRODUCTS 24 26 30

PESTICIDES 22
18 20
18 20
18

HEAVY DUTY DIESEL TRUCKS 20 13 8

RECREATIONAL BOATS 20 17 17 FOOD AND AGRICULTURE (CROP PROCESSING AND WINERIES) 13 12 13 ARCHITECTURAL COATINGS (PAINTS AND THINNERS) 11 12 13 OFF-ROAD EQUIPMENT (COMMERCIAL, INDUSTRIAL) 10 6 4 FARM EQUIPMENT (COMBINES AND TRACTORS) 10 5 3

TOTAL OF TOP CATEGORIES 317 313 279
277 277 275

TOTAL 452 410 414

TOP CATEGORIES PERCENT OF TOTAL 70% 68% 67%

Note: Emissions do not include impact of State Strategy proposed new measures.Technical Modifications Technical Modifications to Page 35 of the April 26, 2007 Revised Draft



### 3. ARB’s 2007 SIP STATE STRATEGY

The State Strategy maps out how to ac hieve the emission reductions necessary to meet federal air qua lity standards. The two main emission reduction components of the State St rategy are the adopted SIP measures and proposed new measures. The adopted SIP meas ures include those adopted through 2006. Proposed new measures include those to be adopted after 2006.

Responsibility for implementing emission reduction measures is shared between the agencies with primary respon sibility for controlling air po llution in California: the Air Resources Board, 35 local air pollution control and air quality management districts, and the U.S. Enviro nmental Protection Agency. However, given the current status of statewide emissions, AR B has the lion’s share of responsibility, followed by U.S. EPA.

Agency Roles in SIP Measure Development

Local Measures

Local air districts are pr imarily responsible for controlling emissions from stationary and areawide sour ces (with the exception of consumer products) through rules and permitting programs. Ex amples include industrial sources like factories, refineries, and power plants; co mmercial sources like gas stations, dry cleaners, and paint spray booth operations; residential sources like fireplaces, water heaters, and house paints; and mi scellaneous non-mobile sources like emergency generators. Distric ts also inspect and test fuel vapor recovery systems to check that such system s are operating as certified.

State Measures

ARB is responsible for controlling emissions from mobile sources (except where federal law preempts ARB’s authority) and consumer pr oducts, developing fuel specifications, establishing gasoline v apor recovery standards and certifying vapor recovery systems, providing tec hnical support to the districts, and overseeing local district compliance wit h State and federal law. The Department of Pesticide Regulation is responsible fo r control of agricultural, commercial and structural pesticides, while the Bureau of Automotive Repair runs the State’s Smog Check programs to ident ify and repair polluting cars.

Federal Measures

U.S. EPA has the authority to control emissions from certain mobile sources, including sources all or partly und er exclusive federal jurisdiction (like interstate trucks, some farm and construction equipment, aircraft, marine vessels, and locomotives based in this country) which it shares in many cases with local districts and ARB . U.S. EPA also has oversight authority for state air programsTechnical Modifications as they relate to the federal Clean Ai r Act. International organizations develop standards for aircraft and marin e vessels that operate outside the U.S.Technical Modifications Technical Modifications to Page 47 of the April 26, 2007 Revised Draft

SOx, 49 tons per day of NO x, and about 4 tons per day of direct PM2.5 in the South Coast by 2014.

Ships

Emissions from ocean-going vessels, unlik e most major pollution sources, are not projected to decrease in future years, since ships have little or no emission controls and run on high-emitting bunker f uel, and shipments of cargo containers are projected to grow significantly over the next two decades. Ships currently emit half the statewide SOx emissions, and it is estimated that ships will jump from the sixth to the sec ond highest statewide NOx pro ducer by 2023. It is essential to reduce ship emissions as t hey are entering our ports and when they are docked through application of demonstr ated control technologies, use of cleaner fuels, and operational efficiencies. Since ARB does not have authority to set ship engine emission standards, we For maximum effectiveness, ARB needs
to must work with national and internat ional authorities, as well as the ports, as well as coordinate with national and international authorities, to implement many of the control measures necessary to clean up these sources

.
ARB took a big step in reducing emissions from ships in December 2005 by adopting a rule phasing in the use of cleaner low-sulfur fuel in ship auxiliary engines that will reduce SOx emissions fr om auxiliary engines by 96 percent and PM2.5 emissions by 83 per cent beginning in 2010.

Proposed New Ship Measures

In addition to the 2005 auxiliary engine fuel rule, the State Strategy proposes to reduce emissions from ship auxiliary engines through cold ironing and other clean technology. Cold ironing allows ship s to turn off their auxiliary engines and instead plug into an electrical system for power when they are docked at a port. This measure would phase in the number of ships capable of using cold ironing and other at-dock technologies such as the “hood”, which fits onto a ship’s exhaust stack and cleans the emissi ons, and is estimated to reduce NOx emissions about 19 tons per day in 2014 and 28 tons per day in 2020.

The State Strategy proposes to reduce emissions from ship main engines through a variety of measures. A main engine fuel rule, patterned after the auxiliary engine fuel rule, would help reduce emissions by introducing a cleaner, low-sulfur fuel beginning no later than 2010. Increasing the use of cleaner new engines or retrofitted engines beginning in 2010 could be implemented via regulation, incentives, voluntary agr eements, or a combination of these approaches. Higher ship speeds cause mu ch higher emissions. So a measure is proposed that would strengthen a current voluntary program by requiring ships to reduce their speeds to 12 knots within 40 nautical miles of the Ports of Los Angeles and Long Beach. The combination of ship main engine measures would reduce both NOx and SOx em issions by 20 tons per day and direct PM2.5 emissions by over 2 tons per day in 2014. These reducti ons would increase substantially through 2023.Technical Modifications Technical Modifications to Page 59 of the April 26, 2007 Revised Draft

Expected Emission Reductions fr om Proposed New SIP Measures 2007 SIP State Strategy (tons per day)

South Coast and San Joaquin Valley -- 2023

South Coast San Joaquin Valley Proposed New State SIP Measures NOx ROG NOx ROG

Passenger Vehicles 7.1 10.5 2.1 3.3 Smog Check Improvements (BAR) 6.9 7.5 2.1 1.9 Expanded Vehicle Retirement 0.2 0.5 0.04 0.1 Modifications to Reformulated Gasoline Program -- 2.5 -- 1.3 Heavy-Duty Trucks 18.3 1.7 21.2 2.3 Cleaner In-Use Heavy-Duty Trucks 18.3 1.7 21.2 2.3

Goods Movement Sources 99.2 1.9 16.4 1.3 Ship Auxiliary Engine Cold Ironing & Clean Technology 30.8 -- -- -- Cleaner Main Ship Engines and Fuel 39.9 -- -- --
Port Truck Modernization 7.0 -- -- --
Accelerated Intro. of Cleaner Line-Haul Locomotives 15.6 1.9 16.4 1.3 Clean Up Existing Harbor Craft 5.9 NYQ -- NYQ Off-Road Equipment 13.9 1.9 5.4 0.6 Cleaner In-Use Off-Road Equipment (over 25hp) 13.9 1.9 5.4 0.6 Cleaner In-Use Agricultural Equipment NYQ NYQ NYQ NYQ

Other Off-Road Sources 2.4 24.0 0.6 11.4

New Emission Standards for Recreational Boats 2.4 17.6 0.6 5.3 Expanded Off-Road Rec. Vehicle Emission Standards -- 6.4 -- 6.1 Additional Evaporative Emission Standards -- NYQ -- NYQ Vapor Recovery for Above Ground Storage Tanks -- NYQ -- NYQ

Areawide Sources -- 13.7 -- 6.3 Consumer Products Program -- 13.7 -- 3.8 Pesticides: DPR Regulation -- NYQ -- 2.5 Reductions from Proposed New State Measures 141 54 46 25
Reductions from Adopted State Measures 448 211 340 66 Total Emission Reductions from State Strategy 589 265 386 91

NYQ = Not Yet Quantified. BAR = Bureau of Automoti ve Repair. DPR = Dept. of Pesticide Regulation.

Locomotives measure relies on U.S. EPA rulemaking and industry agreement to accelerate fleet turnover. Note: Emission reductions reflect the combined impact of regulations and supportive incentive programs. Emission reduction estimates for each proposed measure are shown for informational purposes only. Actual emission reductions from any particular measure may be greater than or le ss than the amounts shown.Technical Modifications Technical Modifications to Page 60 of the April 26, 2007 Revised Draft

Expected Emission Reductions fr om Proposed New SIP Measures 2007 SIP State Strategy (tons per day)

South Coast and San Joaquin Valley -- 2020

South Coast San Joaquin Valley Proposed New State SIP Measures NOx ROG NOx ROG

Passenger Vehicles 9.6 12.9 2.7 4.1 Smog Check Improvements (BAR) 8.3 8.7 2.4 2.2 Expanded Vehicle Retirement 1.3 1.2 0.3 0.3 Modifications to Reformulated Gasoline Program -- 3.0 -- 1.6 Heavy-Duty Trucks 26.9 2.6 30.2 3.3 Cleaner In-Use Heavy-Duty Trucks 26.9 2.6 30.2 3.3

Goods Movement Sources 87.1 1.8 15.6 1.2 Ship Auxiliary Engine Cold Ironing & Clean Technology 28.3 -- -- -- Cleaner Main Ship Engines and Fuel 32.3 -- -- --

Port Truck Modernization 8.0 -- -- --
Accelerated Intro. of Cleaner Line-Haul Locomotives 13.4 1.8 15.6 1.2 Clean Up Existing Harbor Craft 5.1 NYQ -- NYQ Off-Road Equipment 18.7 2.9 7.0 1.0 Cleaner In-Use Off-Road Equipment (over 25hp) 18.7 2.9 7.0 1.0 Cleaner In-Use Agricultural Equipment NYQ NYQ NYQ NYQ

Other Off-Road Sources 1.6 17.9 0.4 8.7

New Emission Standards for Recreational Boats 1.6 12.8 0.4 3.8 Expanded Off-Road Rec. Vehicle Emission Standards -- 5.1 -- 4.9 Additional Evaporative Emission Standards -- NYQ -- NYQ Vapor Recovery for Above Ground Storage Tanks -- NYQ -- NYQ

Areawide Sources -- 13.5 -- 6.1 Consumer Products Program -- 13.5 -- 3.6 Pesticides: DPR Regulation -- NYQ -- 2.5 Reductions from Proposed New State Measures 144 52 56 24 Reductions from Adopted State Measures 423 203 312 65 Total Emission Reductions from State Strategy 567 255 368 89

NYQ = Not Yet Quantified. BAR = Bureau of Automoti ve Repair. DPR = Dept. of Pesticide Regulation.

Locomotives measure relies on U.S. EPA rulemaking and industry agreement to accelerate fleet turnover. Note: Emission reductions reflect the combined impact of regulations and supportive incentive programs. Emission reduction estimates for each proposed measure are shown for informational purposes only. Actual emission reductions from any particular measure may be greater than or le ss than the amounts shown.Technical Modifications Technical Modifications to Page 61 of the April 26, 2007 Revised Draft

Expected Emission Reduc tions from Proposed New SIP Measures 2007 SIP State Strategy (tons per day)

South Coast -- 2014

Direct Proposed New State SIP Measures NOx ROG PM2.5 SOx

Passenger Vehicles 14.4 17.7 0.3 -- Smog Check Improvements (BAR) 12.0 10.5 0.2 -- Expanded Vehicle Retirement 2.4 2.8 0.05 -- Modifications to Reformulated Gasoline Program -- 4.4 -- -- Heavy-Duty Trucks 47.3 5.1 3.0 -- Cleaner In-Use Heavy-Duty Trucks 47.3 5.1 3.0 --

Goods Movement Sources 49.4 0.7 3.6 20.1 Ship Auxiliary Engine Cold Ironing & Clean Technology 18.5 -- 0.3 0.4 Cleaner Main Ship Engines and Fuel 20.0 -- 2.4 19.7

Port Truck Modernization 2.0 -- 0.5 --
Accelerated Intro. of Cleaner Line-Haul Locomotives 4.3 0.7 0.2 -- Clean Up Existing Harbor Craft 4.6 -- 0.2 --
Off-Road Equipment 10.5 2.7 2.6 -- Cleaner In-Use Off-Road Equipment (over 25hp) 10.5 2.7 2.6 -- Cleaner In-Use Agricultural Equipment NYQ NYQ NYQ --

Other Off-Road Sources 0.4 6.6 -- -- New Emission Standards for Recreational Boats 0.4 4.2 -- -- Expanded Off-Road Rec. Vehicle Emission Standards -- 2.4 -- -- Additional Evaporative Emission Standards -- NYQ -- NYQ Vapor Recovery for Above Ground Storage Tanks -- NYQ -- NYQ

Areawide Sources -- 12.9 -- -- Consumer Products Program -- 12.9 -- -- Pesticides: DPR Regulation -- NYQ -- -- Reductions from Proposed New State Measures 122 46 9 20 Reductions from Adopted State Measures 306 164 8 14 Total Emission Reductions from State Strategy 428 210 17 34

NYQ = Not Yet Quantified. BAR = Bureau of Automoti ve Repair. DPR = Dept. of Pesticide Regulation.

Locomotives measure relies on U.S. EPA rulemaking and industry agreement to accelerate fleet turnover. Note: Emission reductions reflect the combined impact of regulations and supportive incentive programs. Emission reduction estimates for each proposed measure are shown for informational purposes only. Actual emission reductions from any particular m easure may be greater than or less than the amounts shown.Technical Modifications Technical Modifications to Page 62 of the April 26, 2007 Revised Draft

Expected Emission Reductions fr om Proposed New SIP Measures 2007 SIP State Strategy (tons per day)

San Joaquin Valley -- 2014

Direct Proposed New State SIP Measures NOx ROG PM2.5 SOx

Passenger Vehicles 3.8 6.5 0.1 -- Smog Check Improvements (BAR) 3.3 2.9 0.05 -- Expanded Vehicle Retirement 0.5 0.7 0.01 -- Modifications to Reformulated Gasoline Program -- 2.9 -- --
Heavy-Duty Trucks 61.4 6.4 3.6 -- Cleaner In-Use Heavy-Duty Trucks 61.4 6.4 3.6 --

Goods Movement Sources 7.2 0.5 0.2 -- Ship Auxiliary Engine Cold Ironing & Clean Technology -- -- -- -- Cleaner Main Ship Engines and Fuel -- -- -- --

Port Truck Modernization -- -- -- --
Accelerated Intro. of Cleaner Line-Haul Locomotives 7.2 0.5 0.2 -- Clean Up Existing Harbor Craft -- NYQ -- --
Off-Road Equipment 3.7 0.9 0.8 -- Cleaner In-Use Off-Road Equipment (over 25hp) 3.7 0.9 0.8 -- Cleaner In-Use Agricultural Equipment NYQ NYQ NYQ --

Other Off-Road Sources 0.1 3.5 -- -- New Emission Standards for Recreational Boats 0.1 1.3 -- -- Expanded Off-Road Rec. Vehicle Emission Standards -- 2.2 -- -- Additional Evaporative Emission Standards -- NYQ -- NYQ Vapor Recovery for Above Ground Storage Tanks -- NYQ -- NYQ

Areawide Sources -- 5.7 -- -- Consumer Products Program -- 3.2 -- -- Pesticides: DPR Regulation -- 2.5 -- -- Reductions from Proposed New State Measures 76 23 5 0 Reductions from Adopted State Measures 211 49 7 0 Total Emission Reductions from State Strategy 287 72 12 0

NYQ = Not Yet Quantified. BAR = Bureau of Automoti ve Repair. DPR = Dept. of Pesticide Regulation.

Locomotives measure relies on U.S. EPA rulemaking and industry agreement to accelerate fleet turnover. Note: Emission reductions reflect the combined impact of regulations and supportive incentive programs. Emission reduction estimates for each proposed measure are shown for informational purposes only. Actual emission reductions from any particular m easure may be greater than or less than the amounts shown.Technical Modifications Technical Modifications to Page 63 of the April 26, 2007 Revised Draft

Commitments to Reduce Emissions

The tables below describe the emission reduction commitment proposal for Board approval. ARB staff proposes to commit to achieve the emission reductions set forth in these tables, by the dates indicated in the table on Page 65 64 entitled, “Schedule for Boar d Consideration of Proposed ARB Rulemaking.” The reductions may be achi eved through a combination of actions, including regulations, incentives , and other enforceable mechanisms.

Summary of Emission Reducti on Commitments – South Coast

Year NOx ROG Direct PM2.5 SOx

2014 122 46 9 20

2020 1 144 52 -- --

2023 141 54 -- --

2023 CAA 182(e)(5) measures 241 2 40 2

-- --

1 The 2020 commitment in the South Coast is necessary to provide for attainment in the downwind

nonattainment areas.

2 The reductions of NOx and ROG from 182(e)(5) meas ures will be reassessed as new SIPs are developed

and revised.

Summary of Emission Reduction Co mmitments – San Joaquin Valley

Year NOx ROG Direct PM2.5 SOx

2014 76 23 5 0

2020 56 24 -- --

2023 46 25 -- --

2023 CAA 182(e)(5) measures 81 1

-- 1

-- --

1 The reductions of NOx and ROG from 182(e)(5) measur es will be reassessed as new SIPs are developed

and revised.

Summary of Emission Reduction Commitments – Coachella Valley

Year NOx ROG

2018 7 2Technical Modifications Technical Modifications to Page 67 of the April 26, 2007 Revised Draft

Role of Funding and Incentive Programs

Over the past 40 years, California has st eadily improved air quality in the face of tremendous economic and population growth. T he vast majority of that progress has come from effective regulations. Accordingly, ARB st aff expects State and federal regulations to play the primary role in implementing the State Strategy. In the regulatory paradigm, polluting sour ces pay for the necessary emission controls as part of doing business. Regulated industries may pass these costs on to consumers in the form of higher prices, although competition and other factors may prevent some companies from recouping all of their control costs. Low-interest loans with extended payment periods are available to aid smaller businesses that need upfront capital to comply.

In recent years, regulatory program s have been supplemented with financial incentives to accelerate voluntary acti ons, such as replacing older equipment. Incentive programs like the Carl Moyer Pr ogram are both popular and effective. They also help to demonstrate emerging technologies that then can be used to set a tougher emissions benchmark for regul atory requirements. Most of the existing incentive programs are designed to pay for the incr emental cost between what is required by regulation and advanced technology that exceeds that level. The incentive programs are publicly funded through fees paid by California vehicle owners as part of their annual regi strations, smog inspections or new tire purchases. California is currently inve sting up to $140 million per year to clean up older, higher emission sources.

The support for clean air incentive funding from Governor Schwarzenegger, the Legislature, and California’s voting public is reflected in the passage on November 7, 2006, of the Highway Safety , Traffic Reduction, Air Quality, and Port Security Bond Act of 2006. The B ond Act includes $1 billion to accelerate the cleanup of air pollution caused by goods movement activities in California. With appropriation by the Legislature, and s ubject to such conditions and criteria contained in a statute that it will enact, ARB will appropriate this money to fund emission reductions from activities rela ted to the movement of freight along California’s trade corridors.

Federal Actions Needed

Measures in the State Str ategy to reduce emissions from interstate and international sources rely on the federal government to develop more stringent emission standards and to ensure these st andards go into effect as soon as possible. Emission reductions from loco motives, off-road equipment, marine auxiliary engines, and harbor craft are a si gnificant part of t he State Strategy. Proposed State measures would accelerate the introduction of cleaner engines and equipment, but the emission reductions re ly on the availability of cleaner new engines. U.S. EPA has prim ary, and in some cases exclusive, authority to establish new engine emission st andards for these sources.Technical Modifications CAA section 209(e)(2) allows California to seek authorization to adopt and enforce emission standards for some non-r oad mobile sources. However, it is not likely that ARB could consult with affected parties, develop and adopt regulations, and secure U.S. EPA approval to enact the regulations in time to ensure that resulting cleaner engines will be widely available by 2014. Therefore, M measures in the State Strategy to reduce emissions from interstate and international sources rely on the federal government to develop more stringent emission standards and to ensure these standards go into effect as soon as possible.

ARB is proposing several measures to reduce ship emissions through a combination of regulations, incentives , and actions by ports and the privateTechnical Modifications Technical Modifications to Page 68 of the April 26, 2007 Revised Draft

sector. However, national and internati onal action to clean up shipping fleets is also needed to fully realize our clean air goals. And aircraft emissions, which will become one of the South Coast’s t op five NOx sources by 2020, are unaddressed in the State Strategy due to the lack of effective international standards.

California must rely on U.S. EPA plays an important role in to representing its California’s interests before foreign or international regulatory bodies that negotiate minimum global standards governing have the ability to reduce emissions from international goods movement sources such as ocean-going vessels . In this role, U.S. EPA should adv ocate for the adoption of cleaner ship emission standards and less polluting practi ces by the International Maritime Organization.

Possible Federal Actions

Adopt more stringent st andards for sources under subject to federal control. U.S. EPA should move as fast as possible to lower standards for sources that it can regulate under its control , keeping in mind California’s air quality challenge and
attainment deadlines. Ther e are categories of emission sources that we do not have the authority to r egulate operational controls on these sources at the State
level. We also do not have the ability to regulate such sources in markets outside of California that then when they operate within California. However, for these sources and for other sources under exclusive or concurrent federal jurisdiction, federal regulation woul d enable greater and faster emission reductions than otherwise would be possible with only State action. Not only would federal action lower emissions for new sources, but it would allow State and local actions to lower emissions from existing sources by setting in-use rules that speed up the integration of t he cleaner engines and technology into California fleets. These sources incl ude: ships, locomotives, harbor craft, aircraft, and off-road equipment and vehicles.

Federal incentives for cleaner technology. Federal funding sources for clean air projects, as well as federal tax incent ives promoting the manufacture, sale, and purchase of cleaner vehicles, equipment, and technology, could enhance California’s aggressive incentive programs.Technical Modifications Technical Modifications to Page 70 of the April 26, 2007 Revised Draft

Setting the Ozone Emission Reduction Target (tons per day)

Nonattainment Area

South Coast (2023) San Joaquin Valley (2023)

NOx ROG NOx ROG

2006 Emissions Inventory 972 732 650 454

Carrying Capacity 114 420 160 342

Emission Reduction Target 858 312 490 112

(2006 Emissions Inventory) – (Carrying Capacity) = (Emission Reduction Target)

2006 Emissions Inventory = Amount of ozone-forming emissions. Carrying Capacity = Pollutant emissions limit that ensures air quality standards are met. Emission Reduction Target = Amount of emissions that must be reduced to meet the standard.

Meeting the Ozone Emission Reduction Target (tons per day)

Nonattainment Area

South Coast (2023) San Joaquin Valley (2023)

NOx ROG NOx ROG

Emission Reduction Target 858 312 490 112

Emission Reductions from Adopted SIP Measures 467 199 355 43

Emission Reductions from New Local Measures 9 19 8 47

Emission Reductions from New State Measures 141 54 46 25

Long-Term Measures 241 40 81 --

Total Reductions 858 312 490 115

Emission Reductions from Adopted SIP Measures = Emissions reduced from State and local measures adopted through 2006. Emission Reductions from New Measures = Emissions reduced from measures in the State Strategy or new local measures adopted after 2006. Long-Term Measures = Emissions reduced from measures adopted after 2020 that rely on new or evolving technology, as allowed in section 182(e)(5) of the Clean Air Act.Technical Modifications Technical Modifications to Appendix A, Page 100 of the May 7, 2007 Revised DraftOn-Road MobileLIGHT DUTY PASSENGER (LDA) 0.77 0.77 0.78 0.80 0.83 0.86 0.89 0.90 0.92 0.93 0.95 0.99 1.00 1.05 1.15LIGHT DUTY TRUCKS - 1 (LDT1) 0.27 0.27 0.27 0.27 0.28 0.28 0.29 0.29 0.30 0.30 0.31 0.31 0.32 0.33 0.36LIGHT DUTY TRUCKS - 2 (LDT2) 0.54 0.65 0.66 0.68 0.71 0.74 0.77 0.79 0.81 0.82 0.84 0.88 0.89 0.93 1.04MEDIUM DUTY TRUCKS (MDV) 0.24 0.35 0.35 0.37 0.39 0.41 0.43 0.44 0.46 0.47 0.48 0.50 0.51 0.54 0.60LIGHT HEAVY DUTY GAS TRUCKS - 1 (LHDV1) 0.04 0.04 0.04 0.04 0.04 0.05 0.05 0.05 0.05 0.05 0.05 0.06 0.06 0.06 0.07LIGHT HEAVY DUTY GAS TRUCKS - 2 (LHDV2) 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.02MEDIUM HEAVY DUTY GAS TRUCKS (MHDV) 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01HEAVY HEAVY DUTY GAS TRUCKS (HHDV) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.01 0.01 0.01 0.01 0.01 0.01LIGHT HEAVY DUTY DIESEL TRUCKS - 1 (LHDV1) 0.01 0.06 0.06 0.05 0.05 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.03 0.03LIGHT HEAVY DUTY DIESEL TRUCKS - 2 (LHDV2) 0.03 0.04 0.04 0.04 0.04 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.02 0.02MEDIUM HEAVY DUTY DIESEL TRUCKS (MHDV) 0.56 0.63 0.62 0.56 0.56 0.55 0.53 0.51 0.49 0.47 0.45 0.42 0.41 0.39 0.38HEAVY HEAVY DUTY DIESEL TRUCKS (HHDV) 8.92 9.01 10.81 8.69 8.13 7.56 7.01 6.48 5.96 5.47 5.00 4.17 3.81 3.23 2.68MOTORCYCLES (MCY) 0.02 0.04 0.04 0.04 0.04 0.04 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03HEAVY DUTY DIESEL URBAN BUSES (UB) 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04HEAVY DUTY GAS URBAN BUSES (UB) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00SCHOOL BUSES (SB) 0.08 0.09 0.09 0.09 0.09 0.10 0.10 0.10 0.10 0.10 0.10 0.11 0.11 0.11 0.11OTHER BUSES (OB) 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02MOTOR HOMES (MH) 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01On-Road Subtotal 11.56 12.05 13.86 11.70 11.23 10.74 10.27 9.77 9.28 8.81 8.38 7.62 7.30 6.82 6.58Other MobileAIRCRAFT 1.33 1.36 1.43 2.02 2.08 2.19 2.31 2.35 2.39 2.44 2.48 2.57 2.62 2.72 2.72TRAINS 0.60 0.60 0.59 0.54 0.54 0.54 0.53 0.53 0.53 0.53 0.53 0.53 0.53 0.54 0.54SHIPS AND COMMERCIAL BOATS 0.07 0.06 0.07 0.04 0.04 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.04 0.05RECREATIONAL BOATS 0.71 0.79 0.83 0.92 0.97 1.02 1.08 1.14 1.20 1.27 1.33 1.48 1.55 1.70 1.98OFF-ROAD RECREATIONAL VEHICLES 0.05 0.05 0.05 0.05 0.05 0.06 0.06 0.06 0.06 0.07 0.07 0.07 0.07 0.08 0.09OFF-ROAD EQUIPMENT 3.81 3.52 3.41 2.99 2.81 2.64 2.46 2.26 2.07 1.89 1.73 1.43 1.31 1.10 0.91FARM EQUIPMENT 4.03 3.63 3.48 3.03 2.89 2.79 2.64 2.42 2.19 1.99 1.82 1.50 1.34 1.06 0.73FUEL STORAGE AND HANDLING 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Other Mobile Subtotal 10.60 10.02 9.85 9.60 9.38 9.27 9.11 8.79 8.47 8.21 7.99 7.61 7.47 7.24 7.02Grand Total 94.16 88.01 86.22 84.95 85.23 82.46 82.37 82.36 82.34 82.38 82.48 82.80 82.99 83.44 84.22121.98 116.94 117.17 113.92 113.84 110.72 110.26 109.85 109.48 109.17 108.99 108.94 109.04 109.41 110.34Technical Modifications Technical Modifications to Appendix A, Page 103 of the May 7, 2007 Revised DraftOn-Road MobileLIGHT DUTY PASSENGER (LDA) 0.26 0.18 0.18 0.17 0.18 0.18 0.19 0.19 0.20 0.20 0.21 0.22 0.22 0.23 0.25LIGHT DUTY TRUCKS - 1 (LDT1) 0.12 0.09 0.09 0.06 0.06 0.06 0.07 0.07 0.07 0.07 0.07 0.08 0.08 0.08 0.09LIGHT DUTY TRUCKS - 2 (LDT2) 0.13 0.11 0.11 0.10 0.11 0.11 0.11 0.12 0.12 0.12 0.12 0.13 0.13 0.14 0.15MEDIUM DUTY TRUCKS (MDV) 0.09 0.09 0.09 0.08 0.09 0.09 0.09 0.09 0.09 0.09 0.10 0.10 0.10 0.10 0.11LIGHT HEAVY DUTY GAS TRUCKS - 1 (LHDV1) 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.03LIGHT HEAVY DUTY GAS TRUCKS - 2 (LHDV2) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.01 0.01 0.01 0.01MEDIUM HEAVY DUTY GAS TRUCKS (MHDV) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00HEAVY HEAVY DUTY GAS TRUCKS (HHDV) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00LIGHT HEAVY DUTY DIESEL TRUCKS - 1 (LHDV1) 0.00 0.05 0.04 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00LIGHT HEAVY DUTY DIESEL TRUCKS - 2 (LHDV2) 0.02 0.03 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00MEDIUM HEAVY DUTY DIESEL TRUCKS (MHDV) 0.18 0.23 0.23 0.02 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.04HEAVY HEAVY DUTY DIESEL TRUCKS (HHDV) 1.47 1.76 2.20 0.22 0.23 0.23 0.24 0.24 0.25 0.26 0.27 0.28 0.29 0.31 0.33MOTORCYCLES (MCY) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00HEAVY DUTY DIESEL URBAN BUSES (UB) 0.02 0.03 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00HEAVY DUTY GAS URBAN BUSES (UB) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00SCHOOL BUSES (SB) 0.02 0.02 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00OTHER BUSES (OB) 0.01 0.01 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00MOTOR HOMES (MH) 0.01 0.01 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00On-Road Subtotal 2.36 2.62 3.04 0.71 0.73 0.75 0.77 0.78 0.80 0.82 0.84 0.89 0.91 0.95 1.02Other MobileAIRCRAFT 0.42 0.45 0.45 0.50 0.51 0.52 0.54 0.54 0.55 0.56 0.57 0.58 0.59 0.60 0.61TRAINS 0.68 0.71 0.73 0.07 0.07 0.07 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02SHIPS AND COMMERCIAL BOATS 0.25 0.31 0.33 0.12 0.13 0.08 0.08 0.09 0.09 0.10 0.10 0.12 0.12 0.14 0.16RECREATIONAL BOATS 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01OFF-ROAD RECREATIONAL VEHICLES 0.08 0.06 0.07 0.07 0.08 0.08 0.08 0.09 0.09 0.09 0.10 0.10 0.11 0.11 0.13OFF-ROAD EQUIPMENT 0.46 0.48 0.49 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.06 0.06FARM EQUIPMENT 0.51 0.51 0.51 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05FUEL STORAGE AND HANDLING 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Other Mobile Subtotal 2.41 2.53 2.58 0.87 0.89 0.86 0.83 0.84 0.86 0.88 0.90 0.93 0.95 0.99 1.05Grand Total 3.63 3.74 3.79 2.07 2.10 2.06 2.03 2.04 2.06 2.07 2.09 2.12 2.14 2.18 2.2327.14 28.55 29.29 25.6 25.85 26.13 26.4126.73 27.07 27.4 27.75 28.34 28.65 29.24 30.12Technical Modifications Technical Modifications to Appendix C, Pages 1-4 of the May 7, 2007 Revised Draft

Introduction

Sections 110 (a)(1) and (2) of the Clean Air Ac t require states to submit SIPs that implement, maintain, and enforce a new or revised national ambient air quality standard within 3 years following promul gation of the standard. Among the SIP elements identified in Sect ion 110(a)(2) is the r equirement to address the transport of pollutants between states. Th is section also requires states to ensure that their SIP does not interfer e with another state’s program to prevent significant deterioration of it s air quality or interfere with vi sibility in another state.

In April 2005, the U.S. EPA notified states of their fa ilure to make the required SIP submission addressing interstate trans port of pollutants related to ozone and PM2.5. This “failure to submit” finding for the required inters tate transport SIPs started a 24-month clock for U.S. EPA to issue a final Federal Implementation Plan (FIP) for any state that does not submit a plan and receive U.S. EPA approval within that time period.

On August 15, 2006, U.S. EPA issued guidance for submitting interstate transport or “Good Neighbor” SIPs. In accordance with that guidance, this document contains documents the findings that California meets the requirements of sections 110 (a)(1) and (2) of the Clean Air Act for both the federal 8-hour ozone standard and t he federal PM2.5 standard.

Closest Nonattainment Areas to California

Ozone : The closest 8-hour ozone nonattain ment areas are Las Vegas, Nevada, and Phoenix-Mesa, Arizona.

PM2.5 : The closest PM2.5 nonattainment area is Libby, Montana. Libby is more than 900 miles away from the San Joaquin Valley, the nearest PM2.5 nonattainment area in California.

Evaluation of significant contribution to nonattainment or interference with maintenance of attainment standards in another state

U.S. EPA did an analysis for its Clean Air Interstate Rule or CAIR to identify
states that were contribut ing significantly to nonattain ment of PM2.5 and ozone in adjacent states. In the preamble to that rule, U.S. EPA stated that:

“In analyzing significant cont ribution to nonattainment, we determined it was reasonable to exclude the Western U.S., including the States of Wash ington, Idaho, Oregon, California

, Nevada, Utah and Arizona from further analysis due to geography, meteorology, and topography. Ba sed on these factors, we concluded that the PM2.5 and 8-hour ozone nonattainment problems are not likely to be affected significantly by pollution transported across these States’ boundaries. Therefore, for theTechnical Modifications purpose of assessing State’s cont ributions to nonattainment in other States, we have only analy zed the nonattainment counties located in the rest of the U.S.” 1 (emphasis added)

The meteorological discussions below provide more detail.

Ozone : Ozone episodes over the Southwes tern United States are normally associated with strong high pressure systems centered over the Southwest Desert. These meteorological patterns are characterized by clear skies, warm temperatures, and light winds and result in very stagnant conditions over the region. Ozone is not transported over long distances under these conditions. On occasion, the strong high pressure is weak ly impacted by migrating low pressure systems over the Pacific Ocean. This has the dual effect of maintaining stagnant conditions over most of t he region while allowing weak pressure systems to push air that is high above the surface eastwar d and to transport ozone trapped in this layer over long distances.

PM2.5 : The technical support document for the PM2.5 designation of Lincoln County, Montana (containing Libby, Montana) found that the nonattainment area is “localized within and around the vici nity of the town of Libby due to topographical features and meteorology in the area impacted by emissions.” Therefore, Libby, Montana’s nonattainment status is not affected by emissions produced in other areas and transported to the Libby area.

U.S. EPA’s conclusion in CAIR pream ble plus the above meteorological summary support the finding that Californ ia does not significantly affect nonattainment areas in other states.

California’s existing stringent motor v ehicle control program, consumer product regulations, stationary source permitting, new source review programs, and new commitments outlined in the Californi a SIP further strengthened by the 8-hour ozone and PM2.5 SIPs will result in steadily decreasing emissions. This greatly reduces the likelihood Even with the occasional possibility of ozone being transported over long distances, California ’s air quality programs greatly reduce the likelihood that emissions from California will contribute significantly to nonattainment in any downwind state.

1 Rule to Reduce Interstate Transport of Fine Pa rticulate Matter and Ozone (Interstate Air Quality Rule Preamble), 69 FR at 4581, January 30, 2004.Technical Modifications Evaluation of interference with Preven tion of Significant Deterioration Measures of any other State

U.S. EPA guidance 2 for interstate transport SIPs advises states to make a SIP submission to confirm that major sources in the Stat e are currently subject to prevention of significant deteriorati on (PSD) and nonattainment new source review (NNSR) preconstruction permitti ng programs that apply to the 8-hour ozone standard.

For the PM2.5 standard, the guidance adv ises states to provide a SIP submission to confirm that major sources in the St ate are subject to PSD and NNSR permitting programs impl emented in accordance wit h U.S. EPA’s interim guidance calling for use of PM10 as a su rrogate for PM2.5 in the PSD and NNSR
programs.

In California, all areas are subject to some form of preconstruction program for ozone and PM2.5. These rules are as stringent, or more stringent, than the federal preconstruction progr ams (PSD and NNSR). For ozone, California is on track to submit SIPs per the Phase II 8-hour Ozone Implementation Rule. For PM 2.5, California’s preconstructi on programs are being implemented in accordance with EPA’s interim guidance calling for the use of PM10 as a surrogate for PM2.5 emissions.

The following air districts are in atta inment of the feder al 8-hour ozone and PM2.5 standards and have a SIP approved PSD rule.

• Mendocino County Air Pollution Control District

• Monterey Bay Unified Air Pollution Control Dis trict

• Northern Sonoma County Air Pollution Control District

• North Coast Unified Air Quality Management District

• Sacramento Metro Air Quality Ma nagement District (PM2.5)

On a case-by-case basis, U.S. EPA has delegated partial PSD permitting authority to the following air districts that are in attainment of the federal 8-hour ozone and PM2.5 standards.

• Antelope Valley Air Quality Management District

• Bay Area Air Quality Management District

• San Diego Air Pollution Control District

For all other areas that are in attainm ent of federal standar ds, U.S. EPA retains federal PSD permitting authority.

2 Guidance for State Implementation Plan (SIP) Submissions to Meet Current Outstanding Obligations Under Section 110(a)(2 )(D)(i) for the 8-Hour Ozone an d PM2.5 National Ambient Air Quality Standards , memo from William T. Harnett to Regi onal Air Division Directors dated August 15, 2006, Page 8.Technical Modifications The following air districts are nonattainm ent of the federal 8-hour ozone standard and have new source review rules or are on track to submit an NSR rules as part of their 8-hour ozone SIP development process. These rules are or will be equivalent to or more stringent than the federal requirements.

• Antelope Valley Air Quality Managem ent District (Antelope Valley and Western Mojave Desert Nonattainment Area)

• Amador County Air Pollution Cont rol District (Central Mountain Counties Nonattainment Area)

• Bay Area Air Quality Management District

• Butte County Air Quality Management District

• Calaveras County Air Pollution C ontrol District (Central Mountain Counties Nonattainment Area)

• El Dorado County Air Pollution C ontrol District (Sacramento Federal Nonattainment Area)

• Feather River Air Quality Managem ent District (Sacramento Federal Nonattainment Area)

• Imperial Air Pollution Control District

• Kern County Air Pollution Control District (Eastern Kern Nonattainment Area)

• Mariposa County Air Pollution Co ntrol District (Southern Mountain Counties Nonattainment Area)

• Mojave Desert Air Pollution Control District (Antelope Valley and Western Mojave Desert Nonattainment Area)

• Northern Sierra Air Quality Management District (Western Nevada County Nonattainment Area)

• Placer County Air Pollution C ontrol District (Sacramento Federal Nonattainment Area)

• Sacramento Metropolitan Air Quality Management District (Sacramento Federal Nonattainment Area)

• San Joaquin Valley Unified Air Pollution Control District

• South Coast Air Quality Management District

• Tuolumne County Air Pollution C ontrol District (Southern Mountain Counties Nonattainment Area)

• Ventura County Air Poll ution Control District

• Yolo Solano Air Quality Managem ent District (Sacramento Federal Nonattainment Area)

The following air districts are nonattain ment of the federal PM2.5 standard and already have NSR rules in place for PM 10. These rules ar e equivalent to or more stringent than the federal requirements.

• South Coast Air Quality Management District

• San Joaquin Valley Unified Air Pollution Control DistrictTechnical Modifications Technical Modifications to Appendix D, Page 2 of the May 7, 2007 Revised Draft

For RFP, nonattainment areas classified serious and above must demonstrate an 18 percent reduction in ROG and/or NOx emissions from the 2002 baseline ROG inventory by 2008. In the years that fo llow, they must dem onstrate, on average, an additional 3 percent per year reducti on in ROG and/or NOx emissions until their attainment year. Serious areas ar e: San Joaquin Valley, Coachella Valley and Sacramento. Note that for the r easons given above, Coachella Valley is subject to a 15 percent ROG-only reduction requirement from 2002 to 2008. The South Coast Air Basin is classified as severe.

For moderate and above 8-hour ozone nonatta inment areas, a limited amount of NOx reductions may also be used, to a point, as a substitution for ROG reductions for RFP. NOx emission reductions creditable toward the RFP requirement cannot be great er than the cumulative NOx reductions that are necessary to demonstrate attainment. Th is attainment consistency requirement is meant to prevent the substitution of NOx reductions for progress purposes that would not lead toward attaining the ozone standard.

U.S. EPA has taken the position in guidanc e, and not in regulation, that for nonattainment areas classified under Subpart 2, reductions needed for progress in the attainment year should equate to those needed for attainment. ARB staff disagrees. We believe a plain reading of the Act indicates that a 3 percent reduction per year is needed between the next-to-last milestone year and the attainment year. For example, in a severe-15 area, the next-to-last milestone year is 2017 and the attainment year is 2018. A 45 percent reduction is needed in 2017 for RFP. Therefore, the RFP r equirement for the next year (2018) is three percent more, or 48 percent – and not the reductions needed for attainment.

Upwind Emissions in RFP Demonstrations

Ozone levels are influenced by ROG and NOx emitted both within a nonattainment area and transported fr om upwind locations. U.S. EPA acknowledges this relationship by a llowing emission reductions from upwind locations outside the nonattainment area to be included for RFP, up to 100 kilometers for ROG and 200 kilometers for NOx.

The inclusion of transport contributions of ROG and NOx provides key emission reductions in RFP analyses for the fo llowing nonattainment areas: Antelope Valley and Western Mojave Desert, C entral Mountain Counties, Coachella Valley, Eastern Kern, Sout hern Mountain Counties and Western Nevada. Their emission inventories for RFP purposes include ROG and NOx emissions from counties that are (1) entirely withi n the designated 100km and 200km distances, and (2) part of the area’s established federally Board -approved transport couples.

Federal Motor Vehicle Control Program Adjustments