2008 PM2.5 Plan 

Chapter 9 

 

Conclusion 
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Chapter 9: Conclusion 

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9-1 

Chapter 9: Conclusion

9.1 ATTAINMENT OUTLOOK 

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

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

initial attainment deadline 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 receive an extension of up to five years, 

making the final attainment deadline April 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 extension, areas must show that attainment by 

2009 is impracticable and that the area will attain the standard by an alternative date 

that is as expeditious as practicable. Areas 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 modeling, that have higher projected values for the year 

2014. The Receptor and Regional modeling predictions are in very close agreement as 

shown in Table 3-5 and therefore 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 commitment from ARB for 

extensive NOx reductions in 2014 is necessary to achieve attainment. Only if a 

significant portion of these reductions were implemented ahead of the proposed 

commitment would it be likely to achieve compliance by an earlier year. 

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

contributions to ammonium nitrate are the dominant source for annual PM2.5 levels in 

the Valley. Figure 9-1 shows that ammonium nitrate is, by far, the largest contribution to 

the Valley’s annual PM2.5 concentration resulting in almost half of the annual 

concentration. Since NOx is the limiting compound for ammonium nitrate in the Valley1

, 

NOx controls reduce ammonium nitrate the most effectively. Other contributions are 

collectively equal to the impact of ammonium nitrate and must also be addressed 

through emission reductions. Principle sources of directly emitted PM2.5 include 

geologic material, motor vehicle emissions and tire and brake wear, organic carbon and 

vegetative burning. Atmospheric formation of secondary PM2.5 is dominated by NOx 

formation of ammonium nitrate 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 Waste 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 California’s San Joaquin Valley.” Atmospheric Environment 39: 5325-5341. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Chapter 9: Conclusion 

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small contributions of secondary organic aerosol 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 concentration. It should 

also be noted that during some months the concentration of ammonium nitrate is very 

low and PM2.5 is dominated by directly emitted sources (geologic, 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 standard attainment outlook for the San 

Joaquin Valley as a basin-wide average for compliance years 2009 through 2014. 

The emissions inventory (including rules adopted as of December 2006) does not meet 

the emissions targets. Table 9-1 compares the emissions inventory 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 reductions that will be achieved by the District’s and 

ARB’s regulatory control measures. However, the District has several reasons to 

expect that attainment will be achieved earlier than 2014. 
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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 SO2 emissions inventory, 

before Plan control strategy (Table B-3) 26.4 23.0 23.3 23.6 23.8 25.5

12 SO2 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 yielded 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 attainment 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 closer to the tougher, 2006 federal PM2.5 

standard). 

The estimated NOx, direct PM2.5, and SO2 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 development 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Chapter 9: Conclusion 

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process for each measure, District staff will consider the most effective technologies 

available; rules may achieve more reductions than expected. Control measure 

feasibility studies may also reveal additional opportunities for reductions. ARB 

measures will achieve significant reductions that will greatly contribute to the Valley’s 

2014 attainment. However, ARB is not committed to pre-2014 emissions reductions at 

this time. It is probable that, in actuality, 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 attainment. The District still 

expects that the reductions achieved by these highly successful programs will help 

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

2006 PM2.5 standards. 

Figure 9-2 Annual PM2.5 Principal Components and Reductions 
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Figure 9-2 provides a graphic display of the 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 directly 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 inconsequential 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 the Reasonable Further Progress (RFP) 

demonstration. Then, if the emission reductions actually achieved are not enough to 

meet the RFP milestones or the attainment target, contingency measure reductions 

quickly make up the difference. The discussion of contingency measures in a state 

implementation plan (SIP) should include a trigger mechanism, an implementation 

schedule, and an indication that the reductions from the measures were not used to 

demonstrate RFP or attainment (72 FR 20642-20643). 

Contingency measures must be fully adopted rules or control 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 contingency measures before they are triggered (72 FR

20643). All available measures needed to demonstrate attainment of the standards 

must be considered first; all remaining measures should be considered as candidates 

for contingency measures. EPA also notes, “It is important not to allow contingency 

measures to counteract the development of an adequate control strategy 

demonstration” (72 FR 20643) and that “The key is that the statute requires that 

contingency measures provide for additional emission 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 federal Clean Air Act do not specify the number of 

contingency measures that plans must include 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 approximately 1 year’s worth of emissions 

reductions necessary to achieve RFP for the area.” (72 FR 20643). 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Chapter 9: Conclusion 

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A nonattainment area subject to federal contingency measure provisions has two 

general options for providing emission reductions above and beyond those needed to 

meet federal requirements for reasonable 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 reductions 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 requirements provide 

emission reductions above and beyond those required for reasonable further 

progress, and to use these reductions as contingency reductions since they are 

above and beyond those needed for meeting federal milestones. The second 

option is stronger in that the “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 into 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 demonstration 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 Coast Air Quality Management 

District (SCAQMD 2007), numerous issues affect the implementation of contingency 

measures. These include availability 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 adverse environmental impacts. 

Nonattainment areas with significant attainment challenges have developed aggressive 

and far-reaching emission reduction measures to meet federal Clean Air Act 

requirements. The result of this “no stone 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 for areas such as the SJVAB and the South 

Coast Air Basin, which have pervasive ozone and particulate matter attainment 

challenges. Any feasible approach for reducing emissions that has been identified has 

been implemented. However, because areas such 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 Option 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 develop the control program for attainment and 

then to use excess reductions as candidates for contingency measures (72 FR 20643). 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Chapter 9: Conclusion 

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Control measures developed and enhanced by the District since the passage of the 

1990 federal Clean Air Act Amendments have become increasingly stringent, leaving 

little room for “extra” reductions that could be set aside to fulfill general contingency 

measure requirements. Three recent analyses prepared and adopted by the District to 

meet federal and state air quality planning requirements demonstrate that the District’s 

control measures often lead the State in terms of stringency of emissions control. First, 

the analysis of rules affecting emissions of particulate matter and its precursors 

(including VOC and NOx measures) that was required by Section 39614 of the 

California Health and Safety Code (also referred to as the Senate Bill 656 analysis) 

shows that for the 103 control measures identified by ARB as required by this section of 

the Health and Safety Code, 37 of the District’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 District Governing Board in August 2006 

shows that District rules meet or exceed RACT 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 capable 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 concluded that the District’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 reductions until 2014; 

consequently, the state measures offer no potential to help with PM2.5 RFP milestones 

for 2009 and 2012. The timing of the state reductions is especially 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 reductions that occur prior to 

2014 would go a long way to providing contingency 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 meet an RFP milestone. 
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Chapter 9: Conclusion 

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9.2.2.2 Surplus Reductions from Adopted Measures 

9.2.2.2.1 Ozone Nonattainment Fee 

In May 2002, the District adopted Rule 3170 (Federally Mandated Ozone Nonattainment 

Fee) that requires each affected major stationary 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 nonattainment 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 fee provisions for the 1-hr ozone standard, even though the 

standard itself was revoked. The District 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 November 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 other air pollution control programs identified by the District. 

Funding would reach District programs in time to help with the 2012 RFP milestone2

 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 counting on failing to attain the former 1-hr ozone 

NAAQS. On the contrary, current monitoring data show that the SJVAB is on track to 

attain the former 1-hr ozone NAAQS by its statutory attainment date 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 meet the federal requirements for PM2.5 

contingency measures, and thus would be implemented. 

The amount of emission reductions available as PM2.5 contingency from 

implementation of Rule 3170 is a function of the dollars/ton of the fee (which is tied to 

the rate of inflation), the number 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 measure for the years 2013 or 2016. 

9.2.2.2.2 Incentives 

Section 6.5 of this 2008 PM2.5 Plan identifies substantial incentive-based funding that 

will be spent by the District to achieve emissions 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 milestone generally have one calendar year to implement a remedy to correct the 

shortfall. So the District would have until December 31, 2013 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 Pollution Control District April 30, 2008

Chapter 9: Conclusion 

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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 procedural, record keeping, and reporting 

requirements to ensure that the all incentive-based reductions achieved by the District 

meet EPA requirements and guidance for SIP creditability. 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 contingencies. 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 decisions 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 contingency measures would generate about $90 

million per year, which provides an estimated 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 source emission control program, which has 

been very successful in reducing emissions in the Valley and throughout California. 

The methods used in Chapter 8 to calculate emission reductions needed to meet RFP 

goals withheld reductions that in turn become 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 contingencies; 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 Agency, 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 Pollution Control District, SB656 Particulate Matter 

(PM) Control Measure Implementation 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 Plan, which noted that 1 tpd of permanent NOx emission 

reductions cost about $25 million. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

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