San Joaquin San Joaquin Valle San Joaquin Valley

Air Basin Plan Air Basin Plan

Demonstrating Attainment Demonstrating Attainment Attainment 

Of Federal

 1-hour Ozone Standards hour Ozone Standards

 

Extreme

Ozone Attainment Attainment

Demonstration DemonstrationPlan

October 8, 2004 October 8 tober 8, 2004
 

 

San Joaquin Valley Unified Air Pollution Control District 

1990 E. Gettysburg Avenue 

Fresno, California 93726 

(559) 230-5800 

www.valleyair.org
 

San Joaquin Valley 

Air Pollution Control District

Governing Board, 2004 

 

Barbara Patrick, Chair 

Supervisor, Kern County 

Thomas W. Mayfield, Vice Chair 

Supervisor, Stanislaus County 

Mike Maggard 

Councilmember, City of Bakersfield 

Michael G. Nelson 

Supervisor, Merced County

Susan B. Anderson 

Supervisor, Fresno County 

Jack A. Sieglock 

Supervisor, San Joaquin County 

Tony Barba 

Supervisor, Kings County 

Ronn Dominici

Supervisor, Madera County 

Sam Armentrout 

Councilmember, City of Madera J. Steven Worthley 

Supervisor, Tulare County 

Dan Prince 

Councilmember, City of Ripon 

Executive Director/Air Pollution Control Officer 

David L. Crow 

Deputy Air Pollution Control Officer 

Seyed Sadredin
 

CONTRIBUTORS 

The following individuals contributed to the preparation of the main document. 

Many members of the San Joaquin Valley Unified Air Pollution Control District 

staff as well as staff from the California Air Resources Board and the San 

Joaquin Valley Councils of Government were involved in various aspects of 

developing the Extreme Ozone Attainment Demonstration Plan. Names of 

contributing staff are listed alphabetically. 

San Joaquin Valley Unified Air Pollution Control District 

David L. Crow 

Executive Director/Air Pollution Control Officer 

Seyed Sadredin 

Deputy Air Pollution Control Officer 

David L. Jones 

Director, Planning Division 

David Mitchell 

Planning Manager 

Scott Nester 

Planning Manager

Contributing Staff 

Jennifer Barba, Air Quality Specialist Elena Nuño, Air Quality Specialist 

Cynthia Echavarria, Air Quality Specialist Steve Shaw, Project Planner 

George Heinen, Supervising Air Quality Engineer Evan Shipp, Supervising AQ Meteorologist 

Don Hunsaker, Supervising Air Quality Planner Jim Sweet, Project Planner 

David Nunes, Project Planner

California Air Resources Board 

Ravi Ramalingam 

Adjith Kaduwela 

Kurt Karperos 

Councils of Government 

Cari Anderson, CA Consulting, Inc 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN Revised October 20, 2005

 

 

SJVUAPCD Table of Contents 

 i 

TABLE OF CONTENTS 

LIST OF TABLES........................................................................................................... v 

LIST OF FIGURES ......................................................................................................... vi 

EXECUTIVE SUMMARY................................................................................................ vii 

1 INTRODUCTION.................................................................................................. 1-1 

1.1 PURPOSE OF THIS PLAN ....................................................................... 1-1 

1.2 REGULATORY ASPECTS........................................................................ 1-2 

1.2.1 Attainment Classification.............................................................. 1-2 

1.2.2 Agency Responsibilities ............................................................... 1-3 

1.2.3 Sanctions, FIP and penalties ....................................................... 1-4 

1.2.4 Conformity.................................................................................... 1-4 

1.3 SJVAB PLANNING HISTORY................................................................... 1-5 

1.4 SERIOUS AREA REQUIREMENTS.......................................................... 1-8 

1.5 PLAN DEVELOPMENT............................................................................. 1-10 

1.5.1 Process........................................................................................ 1-10 

1.5.2 Schedule...................................................................................... 1-11 

1.5.3 Content ........................................................................................ 1-11 

2 SAN JOAQUIN VALLEY AIR QUALITY ............................................................. 2-1 

2.1 INTRODUCTION....................................................................................... 2-1 

2.2 AIR QUALITY DETERMINANTS IN THE SJVAB...................................... 2-2 

2.2.1 General ........................................................................................ 2-2 

2.2.2 Geography and Topography ........................................................ 2-2 

2.2.3 Climate......................................................................................... 2-3 

2.2.4 Ozone Transport .......................................................................... 2-6 

2.2.5 Population.................................................................................... 2-7 

2.2.6 Development Patterns.................................................................. 2-8 

2.3 OZONE...................................................................................................... 2-9 

2.3.1 Background.................................................................................. 2-9 

2.3.2 Adverse Effects............................................................................ 2-9 

2.3.3 Precursors and Formations.......................................................... 2-11 

2.3.4 Design Value Determinations from Ozone Levels........................ 2-12 

2.3.5 Area Classification for the One (1)-Hour Ozone Standard ........... 2-13 

2.3.6 One (1)-Hour Ozone Exceedance Trends.................................... 2-13 

2.3.7 Status of Federal 8-Hour Standard .............................................. 2-15 

2.4 OZONE MONITORING ............................................................................. 2-16 

2.4.1 Monitoring Network ...................................................................... 2-16 

2.4.2 Other Ozone Monitoring............................................................... 2-18 

2.4.3 Conclusion ................................................................................... 2-26 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN Revised October 20, 2005

 

 

SJVUAPCD Table of Contents 

 ii 

2.5 OTHER POLLUTANTS OF CONCERN IN THE SAN JOAQUIN 

VALLEY..................................................................................................... 2-26 

2.5.1 Particulate Matter......................................................................... 2-26 

2.5.2 Carbon Monoxide......................................................................... 2-28 

2.5.3 Toxic Air Pollutants ...................................................................... 2-28 

2.6 REFERENCES.......................................................................................... 2-29 

3 EMISSIONS INVENTORY ................................................................................... 3-1 

3.1 INTRODUCTION....................................................................................... 3-1 

3.2 INVENTORY TYPES................................................................................. 3-1 

3.2.1 Modeling Inventory....................................................................... 3-1 

3.2.2 Planning Inventory ....................................................................... 3-3 

3.2.3 Data Sources and Accuracy......................................................... 3-3 

3.2.4 Emission Source Types ............................................................... 3-4 

3.3 BASELINE YEAR EMISSIONS ................................................................. 3-6 

3.4 FUTURE INVENTORIES........................................................................... 3-12 

3.4.1 Growth Factors ............................................................................ 3-12 

3.4.2 Control Factors ............................................................................ 3-13 

3.4.3 Inclusion of Emission Reduction Credits...................................... 3-13 

3.5 CONFORMITY BUDGETS ........................................................................ 3-23 

3.6 EMISSIONS INVENTORY UNCERTAINTIES........................................... 3-24 

3.7 CONCLUSION .......................................................................................... 3-25 

4 CONTROL STRATEGY....................................................................................... 4-1 

4.1 INTRODUCTION....................................................................................... 4-1 

4.2 DISTRICT RULE DEVELOPMENT SCHEDULE....................................... 4-1 

4.2.1 District Control Measures............................................................. 4-4 

4.2.2 Control Measures Table............................................................... 4-5 

4.2.3 2004-2007 Control Measures....................................................... 4-8 

4.2.4 Potential Control Measures Requiring Further Study................... 4-28 

4.2.5 Reasonably Available Control Technologies................................ 4-35 

4.2.6 Clean Fuels or Advanced Control Technologies .......................... 4-37 

4.3 FUTURE STUDY MEASURES.................................................................. 4-37 

 4.3.1 Mobile Source Measures............................................................. 4-38 

 4.3.2 Other Sources ............................................................................. 4-39 

 4.3.3 Sustainable Incentives................................................................. 4-40 

4.4 DISTRICT INCENTIVE PROGRAMS........................................................ 4-41 

4.4.1 Heavy-Duty Engine Incentive Program ........................................ 4-42 

4.4.2 Electric Lawn Mower Incentives................................................... 4-42 

4.4.3 Future Programs .......................................................................... 4-43 
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SJVUAPCD Table of Contents 

 iii 

4.5 PUBLIC EDUCATION ............................................................................... 4-43 

4.5.1 Outreach Program........................................................................ 4-44 

4.5.2 District Publications...................................................................... 4-45 

4.5.3 Youth Education........................................................................... 4-45 

4.5.4 Events/Activities........................................................................... 4-46 

4.6 OVERVIEW OF REGIONAL TPA RACM .................................................. 4-46 

4.6.1 Introduction .................................................................................. 4-46 

4.6.2 Overview of existing measures .................................................... 4-47 

4.6.3 Suggested measures ................................................................... 4-50 

4.6.4 Adopted measures....................................................................... 4-51 

4.6.5 Public Participation....................................................................... 4-51 

4.7 STATE EMISSION REDUCTIONS FOR THE SJVAB............................... 4-53 

4.7.1 Introduction .................................................................................. 4-53 

4.7.2 Current Implementation Status .................................................... 4-54 

4.7.3 ARB Commitments for Extreme OADP for SJVAB....................... 4-55 

4.8 CONTINGENCY MEASURES................................................................... 4-57 

4.9 LONG-TERM MEASURES........................................................................ 4-58 

5 FUTURE OZONE AIR QUALITY......................................................................... 5-1 

5.1 INTRODUCTION & SUMMARY ................................................................ 5-1 

5.2 PARTICIPANTS ........................................................................................ 5-1 

5.3 MODEL CHOICE....................................................................................... 5-1 

5.4 MODEL BASE CASE ................................................................................ 5-2 

5.5 FUTURE YEAR PROJECTIONS............................................................... 5-5 

5.6 ATTAINMENT DEMONSTRATION ........................................................... 5-9 

5.7 MODELING CAVEATS AND FUTURE WORK ......................................... 5-13 

6 OUTREACH......................................................................................................... 6-1 

6.1 INTRODUCTION....................................................................................... 6-1 

6.2 PRE-DRAFT PLAN WORKSHOPS........................................................... 6-1 

6.3 CITIZEN’S ADVISORY COMMITTEE ....................................................... 6-2 

6.4 DISTRICT GOVERNING BOARD ............................................................. 6-2 

6.5 WEB SITE POSTINGS.............................................................................. 6-3 

6.6 STUDY AGENCY ...................................................................................... 6-3 

6.7 DRAFT EXTREME OADP ......................................................................... 6-3 

6.8 PROPOSED EXTREME OADP................................................................. 6-4 

7 RATE OF PROGRESS (ROP) DEMONSTRATION ............................................ 7-1 

7.1 INTRODUCTION....................................................................................... 7-1 

7.2 1990 RATE OF PROGRESS BASELINE INVENTORIES......................... 7-1 

7.3 FUTURE YEAR (2008 AND 2010) INVENTORIES ................................... 7-3 

7.4 1990-2008 MILESTONE (51 PERCENT) DEMONSTRATION.................. 7-3 

7.4.1 Required 51 Percent Reduction for 2008..................................... 7-4 

7.4.2 2008 Rate of Progress Demonstration......................................... 7-4 
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SJVUAPCD Table of Contents 

 iv 

7.5 1990-2010 MILESTONE (57 PERCENT) DEMONSTRATION.................. 7-6 

7.5.1 Required 57 Percent Reduction for 2010..................................... 7-6 

7.5.2 2010 Rate of Progress ................................................................. 7-9 

7.6 PRIOR ROP & MILESTONE COMPLIANCE DEMONSTRATION ............ 7-13 

 7.6.1 Prior ROP .................................................................................... 7-13 

 7.6.2 Milestone Compliance Demonstration ......................................... 7-15 

7.7 REFERENCES.......................................................................................... 7-16 

8 CALIFORNIA CLEAN AIR ACT TRIENNIAL PROGRESS REPORT AND 

PLAN REVISION ................................................................................................. 8-1 

8.1 INTRODUCTION....................................................................................... 8-1 

8.1.1 Attainment Demonstration............................................................ 8-2 

8.1.2 Air Basin Description.................................................................... 8-2 

8.2 OZONE AIR QUALITY INDICATORS ....................................................... 8-3 

8.2.1 Air Quality Indicators.................................................................... 8-3 

8.2.2 Expected Peak Day Concentration (EPDC)................................. 8-3 

8.2.3 Exposure Indicators ..................................................................... 8-4 

8.3 PROGRESS TOWARD AIR QUALITY STANDARD ATTAINMENT.......... 8-6 

8.4 TRANSPORT MITIGATION ...................................................................... 8-13 

8.5 CONTROL MEASURE IMPLEMENTATION ............................................. 8-16 

8.5.1 Stationary Source Control Measures ........................................... 8-16 

8.5.2 Mobile Source Control Measures................................................. 8-19 

8.5.3 Land Use Programs ..................................................................... 8-22 

8.6 PLAN REVISION....................................................................................... 8-23 

8.6.1 Introduction .................................................................................. 8-23 

8.6.2 Control Strategy ........................................................................... 8-23 

8.6.3 Updated Strategy and Expected Reductions ............................... 8-25 

8.6.4 Further Study Measures............................................................... 8-26 

8.7 REFERENCES.......................................................................................... 8-27 

9 ACRONYMS AND GLOSSARY .......................................................................... 9-1 

 9.1 ACRONYMS ............................................................................................. 9-1 

 9.2 GLOSSARY .............................................................................................. 9-4 

APPENDICES 

A. County Emission Inventories for On-Road Motor Vehicles .................................. A-1 

B. Current List of Emission Reduction Credits.......................................................... B-1 

C. Regional Transportation Planning Agency Commitments .................................... C-1 

D. Modeling and Attainment Demonstrations ........................................................... D-1 

E. Cap on Stationary Source Growth by Pollutant.................................................... E-1 

F. Suggested Control Measures............................................................................... F-1 

G. Clean Air Act Requirements................................................................................. G-1 

H. Comments and Responses: Public Review of Draft Extreme OADP ................... H-1 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN Revised October 20, 2005

 

 

SJVUAPCD List of Tables 

 v 

LIST OF TABLES 

Table # Title Page #

Table 1-1 Nonattainment Classifcation and Design Value Assignment.....................1-2 

Table 1-2 Requirements for Severe versus Extreme Nonattainment Areas ..............1-9 

Table 2-1 SJVAB Populations and Land Area...........................................................2-8 

Table 2-2 Ozone Monitoring Stations in the San Joaquin Valley Air Basin................2-19 

Table 3-1 SJVAB 2000, 2008 and 2010 Planning Emissions Inventories..................3-7 

Table 3-2 Estimated NOx Growth, Control and Estimated Offset Use for 

Stationary Sources ....................................................................................3-15 

Table 3-3 Estimated VOC Growth, Control and Estimated Offset Use for 

Stationary Sources ....................................................................................3-18 

Table 3-4 Transportation Conformity Budgets...........................................................3-24 

Table 4-1 District Control Measure Schedule (2004-2007)........................................4-2 

Table 4-2 Potential Control Measures Requiring Further Study ................................4-6 

Table 4-3 Defined State Measures from the 2003 Statewide Strategy......................4-56 

Table 5-1 SJVAB Federal 1-Hour Ozone Attainment Concept ..................................5-11 

Table 7-1 1990 ROP Baseline Year Inventory...........................................................7-2 

Table 7-2 1990 Adjusted Base Year VOC Inventory Calculations (Tons/Day) ..........7-3 

Table 7-3 Reductions from Adopted Rules and Regulations Not Included in 

the 2008 and 2010 Projected Inventories..................................................7-4 

Table 7-4 2008 Rate of Progress Demonstration Summary ......................................7-7 

Table 7-5 2010 Rate of Progress Demonstration Summary ......................................7-11 

Table 7-6 Comparison of Unadjusted Emissions Inventories used in Amended 

2002/2005 ROP Plan and Extreme OADP ................................................7-14 

Table 8-1 San Joaquin Valley Air Basin Ozone Exceedances...................................8-7 

Table 8-2 BARCT Rules ............................................................................................8-15 

Table 8-3 2001-2003 Rulemaking Schedule..............................................................8-16 

Table 8-4 Actual Emissions Reductions for District Rules Affecting Ozone 

Precursor Emissions (2000-2002) .............................................................8-19 

Table 8-5 Rulemaking Schedule for 2003-2005 ........................................................8-25 

Table 8-6 Planning Emissions Inventories (summer, tons/day).................................8-26 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN Revised October 20, 2005

 

 

SJVUAPCD List of Figures 

 vi 

LIST OF FIGURES 

 Figure Title Page #

Figure 2-1 Counties Comprising the San Joaquin Valley Air Basin ............................ 2-1 

Figure 2-2 San Joaquin Valley Wind Patterns During Ozone Season ........................ 2-4 

Figure 2-3 Basin 1-Hour Design Value for 1986-2003................................................ 2-13 

Figure 2-4 Number of Days Over the 1-Hour Federal Ozone Standard...................... 2-14 

Figure 2-5 San Joaquin Valley Ozone Exceedances.................................................. 2-15 

Figure 2-6 San Joaquin Valley Air Basin Air Quality Monitoring Network ................... 2-17 

Figure 4-1 Overview of Local Government Control Measure Process for the 

Extreme Ozone Attainment Demonstration Plan ....................................... 4-49 

Figure 5-1 Wind Field for July 30, 2000 at 5:00 AM and 3:00 PM PST....................... 5-4 

Figure 5-2 Maximum Ozone Concentration, 2000 CCOS Episode............................. 5-6 

Figure 5-3 Change in Maximum Ozone Concentration due to Wildfires ..................... 5-7 

Figure 5-4 Maximum Ozone Concentration, 2010, without Additional Controls.......... 5-8 

Figure 5-5 Carrying Capacity Diagram for Bakersfield on July 30, 2010 .................... 5-10 

Figure 7-1 Graphical Summary of 2008 ROP Demonstration for San Joaquin 

Valley Ozone ............................................................................................. 7-8 

Figure 7-2 Graphical Summary of 2010 ROP Demonstration for San Joaquin 

Valley Ozone ............................................................................................. 7-12 

Figure 8-1 Expected Peak Day Concentration at Arvin-Bear Site............................... 8-8 

Figure 8-2 Expected Peak Day Concentration at the Bakersfield Golden State 

Site ............................................................................................................ 8-9 

Figure 8-3 Expected Peak Day Concentration at the Bakersfield 5558 

California Ave Site..................................................................................... 8-9 

Figure 8-4 Expected Peak Day Concentration at the Clovis N. Villa Ave. Site ........... 8-10 

Figure 8-5 Expected Peak Day Concentration at the Fresno 1st Street Site ............... 8-10 

Figure 8-6 Expected Peak Day Concentration at the Hanford-Irwin Site .................... 8-11 

Figure 8-7 Expected Peak Day Concentration at the Maricopa-Stanislaus 

Street Site.................................................................................................. 8-11 

Figure 8-8 Expected Peak Day Concentration at the Merced-South Coffee 

Ave. Site.................................................................................................... 8-12 

Figure 8-9 Area Weighted Exposure per Square Kilometer........................................ 8-12 

Figure 8-10 Population Weighted Exposure per Person............................................... 8-13 
 

SJVUAPCD Executive Summary 

vii 

EXECUTIVE SUMMARY 

This Extreme Ozone Attainment Demonstration Plan (OADP) sets forth the 

emission reductions and timeline for attaining the federal 1-hour ozone ambient 

air quality standards in the San Joaquin Valley Air Basin (SJVAB) by November 

15, 2010. The San Joaquin Valley Unified Air Pollution Control District (District), 

in conjunction with the California Air Resources Board (ARB), the U.S. 

Environmental Protection Agency (EPA), and the eight regional Transportation 

Planning Agencies (TPAs) in the Valley, developed this plan to provide healthy 

air for all of the Valley’s people and to meet federal and state requirements for 

ozone planning documents. 

For the purposes of this Extreme OADP, ozone is a colorless, odorless reactive 

gas found near the earth’s surface. Ozone is formed during summer months 

when pollutants emitted from society’s activities and natural sources react in the 

presence of light winds, sunlight and warm temperatures. Principal pollutants 

involved in these reactions are nitrogen oxides (NOx) and volatile organic 

compounds (VOCs); NOx and VOCs are termed ozone precursors. 

Ozone is the prime ingredient of smog, and adversely affects human health and 

environmental resources. When inhaled, even at very low levels, ozone can 

cause acute respiratory problems, aggravate asthma, significantly decrease lung 

capacity in healthy adults, inflame lung tissue, and impair the defenses of the 

body’s immune system. Ozone also interferes with the ability of plants to make 

and store food; compromises growth, reproduction and overall plant health; and 

makes plants more susceptible to diseases, pest and other environmental 

stressors. In addition, ozone can also damage materials such as rubber, paper, 

and plastics, thereby generating additional costs to society. 

Because ozone is an air pollutant that can adversely affect human health, 

damage vegetation, and degrade materials, EPA has established ambient air 

quality standards under the authority of the Federal Clean Air Act that identify 

safe levels for ozone in the atmosphere to prevent and minimize these impacts. 

Ozone levels measured in the atmosphere at levels lower than the standards are 

viewed as safe, whereas levels above the standards represent a reasonable 

danger to public health and welfare (non-health related damages), and thus 

require action to reduce emissions of ozone precursors. EPA has issued two 

different standards for ozone: a 1-hour average of 0.12 parts per million and an 

8-hour average of 0.08 ppm; each of these is subdivided into primary standards 

that protect public health and secondary standards that protect public welfare (for 

each of the 1-hour and 8-hour ozone standards, the numeric value of the 

standard is the same for primary and secondary standards). This Plan 

addresses only the 1-hour standards. 

In 1997, EPA determined that the 1-hour standards were not needed to protect 

public health given the promulgation of the 8-hour standards. On April 15, 2004 

EPA issued a final rule revoking the 1-hour standards, effective June 15, 2005. 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

 

SJVUAPCD Executive Summary 

viii 

Areas in the United States where ozone levels measured in the ambient air 

exceed the 1-hour standards of 0.12 ppm are said to be in nonattainment of the 

standards. An area complies with the federal 1-hour ozone standards when 

measured 1-hour average ozone levels at any given monitoring station do not 

exceed 0.12 ppm more than one day per year over any consecutive three-year 

period (40 CFR 50.9). Thus an area that has a monitoring station with measured 

1-hour average ozone levels greater than 0.12 ppm on four or more days over a 

three-year period has not attained the standards, even if all of the days occurred 

in only one of the three years. 

The severity or magnitude of a given area’s ozone nonattainment problem is 

given by the 1-hour ozone design value, which is based on the fourth highest 

measured 1-hour ozone level in excess of 0.12 ppm in a three-year period at a 

given monitoring station. In accordance with the federal Clean Air Act, EPA uses 

the design value at the time of standard promulgation to assign nonattainment 

areas to one of several classes that reflect the severity of the nonattainment 

problem; classifications range from marginal nonattainment to extreme 

nonattainment. The Federal Clean Air Act contains provisions for changing the 

classifications using factors such as clean air progress rates and requests from 

States to move areas to a higher classification. On April 16, 2004 EPA issued a 

final rule classifying the SJVAB as extreme nonattainment, effective May 17, 

2004 (69 FR 20550). Under this rulemaking, the SJVAB’s attainment date is 

November 15, 2010. 

This Extreme OADP is a roadmap that identifies emission reductions needed to 

attain the federal 1-hour ozone standards by November 15, 2010. According to 

the final rule reclassifying the SJVAB as extreme nonattainment for the federal 1-

hour ozone standards, the Extreme OADP is due to the EPA on November 15, 

2004. The principal components of an ozone attainment demonstration plan 

consist of data describing measured ozone levels in the atmosphere for the area 

in question, baseline and future emissions inventories, descriptions of emissions 

controls that will reduce future emissions, and a description of results from a 

photochemical model relating emissions to ambient ozone levels and 

demonstrating attainment of the appropriate standards at a future date. This 

Extreme OADP meets federal requirements for extreme 1-hour ozone plans. 

Ozone levels measured in the SJVAB’s atmosphere in 2003 exceeded the 

federal 1-hour ozone standards on 37 days, which was a slight increase above 

2002 levels. In addition, for the period 2001—2003, eight monitoring sites 

experienced more than three exceedances of the federal 1-hour ozone 

standards, with one site (Arvin) experiencing more than 50 exceedances and 

another site (Parlier) experiencing more than 40 exceedances. The overall 1-

hour ozone design value for the SJVAB in 2003 was 0.15 ppm. These data 

reflect the pervasiveness of the SJVAB’s 1-hour ozone nonattainment problem. 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

 

SJVUAPCD Executive Summary 

ix 

The Extreme OADP presents an emissions inventory developed under the 

Central California Ozone Study that describes the baseline (2000) and future 

(2008 and 2010) emissions rates for VOC and NOx, the pollutants that combine 

in the atmosphere to form ozone. The Plan includes transportation conformity 

emissions budgets for the years 2008 and 2010, which affect the planning 

activities of the Valley TPAs. Information provided by the TPAs, the mobile 

source emissions model EMFAC2002 (Version 2.2), and emission reductions 

calculated by ARB and the District form the basis of the conformity budgets. 

The Extreme OADP presents emissions reductions sufficient to demonstrate 

attainment of the federal 1-hour standards by November 15, 2010 and to meet 

federal rate of progress emission reduction milestones for the years 2008 and 

2010. The District and ARB will implement the control measures achieving these 

reductions. Many of the District measures used in the Extreme OADP were 

presented in the 2003 PM10 Plan that EPA approved effective June 25, 2004. In 

addition, the District developed other emission control measures to meet federal 

and state requirements outside of this Extreme OADP, and identified them in the 

January 2004 Extreme OADP Status Report. Many of the ARB emission control 

measures also stem from the 2003 PM10 Plan. Additional ARB measures for 

this Extreme OADP were first described in the January 2004 Extreme OADP 

Status Report, and before that in the State and Federal Strategy for the California 

State Implementation Plan (SIP), adopted by ARB on October 23, 2003. 

The District and ARB evaluated the potential for these reductions to reduce 1-

hour ozone levels in the SJVAB by using a gridded photochemical model in 

accordance with EPA-approved procedures. This model uses a series of 

computer programs to relate VOC and NOx emissions to ozone levels. All of the 

reductions described in the previous paragraph, combined with minor reductions 

from incentive programs and other state mobile source emission control 

programs, were almost sufficient to demonstrate attainment of the federal 1-hour 

ozone standards in the SJVAB by November 15, 2010. To provide the needed 

additional reductions, the District, in accordance with federal Clean Air Act 

provisions for extreme nonattainment areas, identified additional emission 

reductions to be provided by long-term measures that will be identified no later 

than spring of 2007. The total reductions identified as being needed to 

demonstrate attainment in the SJVAB represent about 14.5% of 2010 VOC 

emissions and about 14.5% of 2010 NOx emissions, beyond those reductions 

planned or committed to as of 2002. These percent reductions translate to about 

53 tons/day of VOC emissions and about 58 tons/day of NOx emissions that 

must be reduced using future emission reduction control measures (including 5 

tons per day each of VOC and NOx emissions reductions to be achieved by the 

long-term measures). Emission reductions implemented by ARB and EPA are 

critical to the SJVAB’s demonstration of attainment of the federal 1-hour ozone 

standard by November 15, 2010. The resulting 2010 emissions inventory that 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

 

SJVUAPCD Executive Summary 

x 

demonstrates attainment of the federal 1-hour ozone standards in the SJVAB is 

about 314 tons per day of VOC and about 344 tons per day of NOx. 

An additional important function of this Extreme OADP is to is to determine if 

planned emissions reductions meet federal requirements for rate of progress in 

reducing emissions of ozone precursors for the specified years of 2008 and 

2010. The emission reductions identified in this Extreme OADP as needed to 

demonstrate attainment of the federal 1-hour ozone standards, exclusive of the 

long-term measures, were more than sufficient to meet federal rate of progress 

emission reduction milestones for 2008 (a 51% reduction compared to 1990 

emissions) and 2010 (a 57% reduction compared to 1990 emissions). A 

combination of VOC and NOx emission controls were needed to meet the 

milestones. In addition, the District used the emissions inventory in the Extreme 

OADP to show that the most recent prior rate of progress evaluations for the 

SJVAB (2002 and 2005) are still valid. 

In addition, this plan fulfills requirements of the California Clean Air Act regarding 

the development of a triennial progress report and California Air Quality 

Attainment Plan revision that examines air pollutant exposure data, control 

measure implementation, and other air quality information with emphasis on 

meeting California ambient air quality standards. The California Clean Air 

documents in this Extreme OADP focus on the historical time period of 2000-

2002, and project, where recommended by ARB guidance, into the next threeyear planning period (2003-2005). The California Clean Air Act components of 

this plan meet state requirements for triennial progress reports and plan 

revisions. 

For state requirements, the Extreme OADP presents trends in ozone air quality 

indicators developed by ARB for reporting progress towards attaining the 

California 1-hour ozone standard and discusses the implementation of all 

feasible emission control measures. The information presented in this part of the 

plan shows that the SJVAB trends for most of the ARB-mandated ozone air 

quality indicators showed either a downward trend (improvement) or little 

movement up or down for the period of interest (2000—2002), although the 

overall long-term trend for most of the indicators in the SJVAB is one of 

improving air quality. The District continues to be actively involved in determining 

and implementing all feasible control measures, and works closely with 

downwind adjacent districts to evaluate control measures implemented and 

planned. 
Chapter 1 - Introduction
❖
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

 

SJVUAPCD Chapter 1 - Introduction 

1-1 

1 INTRODUCTION 

1.1 PURPOSE OF THIS PLAN 

The San Joaquin Valley Air Basin (SJVAB) does not currently meet the federal 

primary (health-based) and secondary (welfare-based) one-hour national 

ambient air quality standards (standards or NAAQS) of 0.12 parts per million 

(ppm) by volume for the air pollutant ozone. At levels above the federal 

standards, ozone adversely affects public health, diminishes the production and 

quality of many agricultural crops, reduces visibility, degrades man-made 

materials, and damages native and ornamental vegetation. 

The San Joaquin Valley Unified Air Pollution Control District (District), which is 

responsible for air quality management in the SJVAB, has been implementing 

emissions control measures to reduce 1-hour ozone levels, and has shown 

demonstrable progress over the past fifteen years. However, additional emission 

reductions are needed to bring the SJVAB into attainment with the federal 1-hour 

ozone standards. Because the District has authority over only a portion of the 

variety of air pollution sources in the SJVAB, it does not have the ability to put in 

place all of the emissions controls needed to bring the SJVAB into attainment. 

Additional emission reductions to be implemented by the California Air 

Resources Board (ARB) and the U.S. Environmental Protection Agency (EPA) 

are needed to achieve attainment. The federal Clean Air Act requires that the 

SJVAB attain the standard by November 15, 2010.1

This plan was prepared to fulfill the requirements of the federal Clean Air Act for 

demonstrating attainment of the federal 1-hour ozone standard by November 15, 

2010. As such, it describes the factors contributing to the SJVAB’s persistent 

ozone air quality problem, quantifies air pollutant emissions that cause ozone to 

form in the SJVAB, identifies control measures (past, present and future) needed 

to reduce these emissions, and projects future air quality based on 

implementation of these controls. In addition, this plan meets other requirements 

of the federal Clean Air Act that address the rate of progress (ROP) in reducing 

emissions of ozone precursor emissions by specified milestone years, which are 

2008 and 2010 for extreme nonattainment areas. Lastly, this plan fulfills 

California Health and Safety Code requirements for the California Clean Air Act 

Plan Triennial Progress Report and Plan Revision, both of which address 

progress towards meeting the state 1-hour ozone ambient air quality standard. 

 

1

 On April 30, 2004 EPA issued a final rule revoking the federal 1-hour ozone standard, effective 

June 15, 2005 (69 FR 23858). Effective June 15, 2005 the SJVAB would no longer be 

nonattainment for the federal 1-hour standard and the November 15, 2010 date for attainment 

would be eliminated. Focus would then shift to the attainment of the 8-hour standard, and District 

and state emission control measures committed to in this Extreme OADP would be implemented 

for their contribution toward reducing 8-hour ozone levels. 
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1.2 REGULATORY ASPECTS 

1.2.1 Attainment classification

Measured levels of pollutants in the atmosphere determine whether or not a 

given area is classified as attaining the standards (measured levels are lower 

than the standards) or nonattainment (measured levels are greater than the 

standards). For attainment of the federal 1-hour ozone standard, the principal 

statistic of interest is the number of times measured pollutant levels exceed the 

ozone NAAQS (also termed the number of exceedances). An area is in 

compliance with the primary and secondary federal 1-hour ozone NAAQS when 

measured 1-hour ozone levels at any given station do not exceed on average 

0.12 parts per million by volume more than one day per year over any three year 

period (40 CFR 50.9). Thus an area with four or more exceedances at a given 

monitor over a three-year period has not attained the standard. Numerous sites 

in the SJVAB typically experience four or more exceedances, over any given 

three-year period (see section 2 for details). For the SJVAB to be classified as 

attainment for the federal 1-hour ozone standard, it would have to have no sites 

with four or more exceedances over a three-year period. 

Once an area is designated as nonattainment for the federal 1-hour ozone 

standard, an air quality statistic termed the “design value” helps determine the 

magnitude of the nonattainment problem, as indicated below in Table 1-1 

(Section 181(a) of the Federal Clean Air Act):2

Table 1-1 

Nonattainment Classification and Design Value Assignment 

Nonattainment classification Design Value (ppm) 

Marginal 0.121 up to 0.138 

Moderate 0.138 up to 0.160 

Serious 0.160 up to 0.180 

Severe 0.180 up to 0.280 

Extreme 0.280 and above 

As can be seen, the extreme areas on the bottom have the worst ozone air 

pollution problem and the highest design value. The “design value” can be 

thought of as the pollutant concentration in the atmosphere at which we have 

healthy air for that pollutant. It is the concentration for which we design our air 

pollution control programs. A design value is calculated for each monitor 

 

2

 Typically, nonattainment area classification based on design value is done in conjunction with 

implementing a new standard, such as EPA did in 2004 with the 8-hour ozone standard. 
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measuring the pollutant in a given air basin. For the overall basin, the design 

value is defined as the highest for that basin. For the federal 1-hour ozone 

standard, the design value is based on the fourth highest exceedance in a 3-year 

period at a given monitoring station. 

Two principal events that have triggered nonattainment area classification based 

on design value are the passage of the 1990 Federal Clean Air Act Amendments 

(at which time the above table was created) and in conjunction with implementing 

a new standard, such as EPA did in 2004 with the new 8-hour ozone standard. 

An air basin’s nonattainment classification is not always based only on design 

value. If an area fails to attain the standard by the date given for the 

classification, EPA can bump up an area to the next highest nonattainment 

category, if it fails to attain the standard by the date specified in the Federal 

Clean Air Act, even though the design value may not have changed or may have 

changed only marginally. An air basin’s nonattainment classification can also 

change by state request in accordance with Section 181(b)(3) of the Federal 

Clean Air Act. Factors driving such requests include the severity and complexity 

of a nonattainment problem, the need for emissions controls beyond the authority 

of the entity responsible for clean air planning, and the types of sources playing 

key roles in creating high pollutant levels. 

1.2.2 Agency responsibilities

The reduction of ozone precursor emissions in the SJVAB requires the 

cooperation of local, regional, state, and federal governments. At the federal 

level, the EPA is responsible for setting the NAAQS and establishing federal 

motor vehicle emission standards. The EPA is also responsible for reducing 

emissions from locomotives, aircraft, heavy duty vehicles used in interstate 

commerce, and other sources such as off-road engines that are either preempted 

from state control or best regulated at the national level. The EPA also has the 

authority under the FCAA to require preparation of state plans for air quality and 

may approve or disapprove state air quality plans. 

The ARB is the lead state agency for air quality. It is responsible for preparing 

and submitting a state air quality plan to the EPA. In preparing a state plan, the 

ARB reviews and approves regional air quality plans and incorporates them into 

a SIP. Under state authority, ARB also establishes emission standards for onroad motor vehicles and some off-road sources; it also establishes fuel 

specifications and develops “consumer product” standards for meeting air quality 

goals in California. Other state agencies such as the Department of Pesticides 

and the Bureau of Automotive Repair also have responsibility for certain 

emission sources. The air pollution control districts and air quality management 

districts are responsible for developing the portion of the SIP that deals with 

stationary and area source controls in their respective geographic areas; they 

also cooperate with Regional Transportation Planning Agencies (RTPAs) to 

develop local government control measures. 
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1.2.3 Sanctions, FIP and penalties

The FCAA [Title I, Part D, Section 179(b)] directs the EPA to impose sanctions 

on any area that fails to comply with the requirements of the law. The two 

mandatory sanctions consist of the following: (1) increased emissions offsets for 

major stationary sources, and (2) a prohibition on the use of federal highway 

funds. The offset sanction applies to major stationary sources. In a severe nonattainment area, a major source is defined as any source that emits, or has the 

potential to emit, 25 tons per year or more of VOC or NOx. Under the FCAA 

[Title I, Part D, Section 173(a)], the owner/operator of a major source must obtain 

construction and operation permits from the District for constructing a new major 

source or for making a major modification to an existing source. To obtain these 

permits, the source must reduce emissions within the District by more than the 

emissions created by the new or modified source on a 1.5 to 1 ratio for extreme 

areas. If the mandatory offset sanction is imposed, the offset ratio will become 2 

to 1, which means that for every one ton of emissions produced, two tons must 

be reduced from an applicable source in the SJVAB. 

The highway construction sanction, when implemented, prohibits the federal 

Secretary of Transportation from approving or awarding transportation projects or 

grants, except for projects designed to improve a demonstrated safety problem 

or intended to minimize air pollution. Air quality exceptions to this sanction 

include the following types of programs: (1) programs for public transit, (2) bus 

and high-occupancy lanes, (3) employer trip reduction programs, (4) ramp 

metering and signalization, (5) parking facilities for multiple occupancy vehicles, 

(6) road use charges, (7) programs for breakdown and accident scene 

management, and (8) other programs improving air quality. 

In the event that a state is unable to enact emission controls sufficient to attain a 

federal standard, EPA can promulgate a Federal Implementation Plan (FIP) until 

such time that state and local planning actions are back on track to achieve 

attainment. FIPs are not common and are developed on a case-by-case basis 

as needed. FIPs are not required to meet the same planning deadlines as the 

SIPs they are temporarily replacing. 

1.2.4 Conformity

Conformity requirements date back to the 1977 amendments to the FCAA, but 

the 1990 FCAA Amendments substantially broadened their coverage and made 

them more specific. Under the conformity requirements, the Valley RTPAs 

cannot approve any activity unless it conforms to the SIP’s purpose of eliminating 

the severity and number of violations of the federal standards and achieving 

expeditious attainment of these standards. 

Transportation plans refer to Regional Transportation Plans (RTPs) prepared and 

adopted by Transportation Planning Agencies. A RTP is normally a 20-year 

master plan for each county that provides policies, actions, and financial 
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1-5 

projections to guide investment decisions. Transportation programs refer to 

Transportation Improvement Programs (TIPs). A TIP is a financially constrained 

set of highway and transit projects to be funded over a multi-year period. It 

includes all projects requiring federal funding, permits, or other approvals, as well 

as regionally significant, non-federally funded projects. A transportation project is 

any highway or transit project that is included in the RTP and TIP, requires 

federal funding or action, or is regionally significant, and is submitted to the 

RTPAs for project review and fund application approval. 

1.3 SJVAB PLANNING HISTORY 

After passage of the 1990 Federal Clean Air Act Amendments, EPA classified 

the SJVAB as “serious” nonattainment for the federal 1-hour ozone standards, 

based on the SJVAB’s design value for the 1987—1989 time period of data 

collection used for the original classification (56 FR 56694). As such, the SJVAB 

was required to attain the standard by November 15, 1999. In accordance with 

the Federal Clean Air Act, the District prepared and submitted in 1994 a plan 

demonstrating attainment by the required date. 

The SJVAB failed to attain the federal 1-hour ozone standard by November 15, 

1999 as required in the Federal Clean Air Act.3

 Consequently, in November 

2001 EPA reclassified the SJVAB from “serious” to “severe” nonattainment (66 

FR 56476); at the same time, EPA also changed the boundary of the SJVAB by 

removing a portion of eastern Kern County, required implementation of six 

emission control measures from the 1994 Plan, and required submittal by May 

31, 2002 of a severe area ozone nonattainment plan meeting the specific 

provisions of Section 182 (d) of the federal Clean Air Act. In 2002, the District 

and ARB provided all required items to EPA except for a plan demonstrating 

attainment of the federal 1-hour ozone standard by November 15, 2005 (rules 

were submitted in late 2001/early 2002, and a 2002 and 2005 Rate of Progress 

Plan was adopted by the District on May 16, 2002 and transmitted by ARB to 

EPA on September 6, 2002)4

. 

On October 2, 2002, EPA issued a final rule specifying “severe” area 

requirements that had not yet been met for the SJVAB (67 FR 61784). These 

items, which included a plan demonstrating attainment of the federal 1-hour 

ozone standard by November 15, 2005, were required to be submitted to EPA no 

 

3

 The SJVAB’s failure to reach attainment by 1999 is due to a number of factors, including: (1) 

the emission inventory was not fully developed and understood in 1994, and as a result the 

attainment strategy did not adequately account for all emissions in the inventory; and (2) 

emissions from sources outside the District that are transported into the air basin and contribute 

to exceedances of the ozone standard were not adequately addressed. 

4

 ARB transmitted the 2002 and 2005 Rate of Progress Plan to EPA on September 6, 2002 

primarily to incorporate specific enforceable District control measures into the SIP. The motor 

vehicle emissions inventories in this plan were not used to set conformity budgets because they 

were based on dated modeling techniques and vehicle activity data not suited for budgets. 
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later than March 18, 2004. This EPA action [which was effective on September 

18, 2002] triggered an 18-month clock for imposing emissions offset sanctions, a 

24-month clock for imposing highway funding sanctions, and a 24-month clock 

for preparing a Federal Implementation Plan (FIP) for the SJVAB.5

 Failure to 

submit the required items by March 18, 2004 would trigger the offset sanctions; 

failure to submit the required items by September 18, 2004 would trigger the 

highway fund sanctions and EPA promulgation of the FIP. Stopping the clocks 

required submittal of the necessary revisions by the dates specified; these 

revisions are (1) a demonstration of attainment of the 1-hr ozone standard by no 

later than November 15, 2005 [an ozone attainment demonstration plan (OADP)]; 

(2) a demonstration of creditable emission reductions of ozone precursors at a 

rate of at least 3%/yr until November 2005; (3) a rule addressing Reasonably 

Available Control Technology for lime kilns; (4) an inventory; and (5) contingency 

measures. In 2003, the District and ARB provided all of the required items to 

EPA except for the plan demonstrating attainment of the federal 1-hour ozone 

standard by November 15, 2005.6

The District and ARB began work on a severe ozone attainment demonstration 

plan in late 2001, which included photochemical modeling to determine the 

magnitude of emissions reductions needed to attain the standard in the SJVAB 

by November 15, 2005. This modeling indicated that the emissions reductions 

needed for attainment were beyond what the District, ARB, or EPA could 

accomplish individually; consequently, attainment depended upon the District’s 

continued control of sources within its authority, in addition to ARB’s 

implementation of their own emission control measures on sources outside the 

authority of the District to regulate (primarily mobile sources). Most of ARB’s 

rules were scheduled to go into effect in the post-2007 time frame7

, which did not 

help the District demonstrate attainment for the SJVAB by 2005. In addition, 

EPA was developing regulations to reduce emissions from sources under their 

control (e.g., locomotives, aircraft, diesel engines, etc.), but the federal 

implementation schedule for these rules was in the post-2005 time frame also. 

 

5

 Under the Federal Clean Air Act, EPA may develop and implement its own federal emission 

control measures if it finds that state and local measures do not meet requirements. This Federal 

Implementation Plan (FIP) is thus a temporary activity that supersedes the State Implementation 

Plan; it remains in effect until such time as EPA turns the attainment demonstration program back 

to state and local agencies. 

6

 On April 10, 2003, California submitted to EPA the District’s Amended 2002/2005 Rate of 

Progress (ROP) Plan for San Joaquin Valley Ozone, which provides all of the severe area SIP 

revisions required by EPA in the October 2002 Federal Register notice, except for the OADP. 

This Amended ROP Plan is based on ARB’s updated motor vehicle emissions model and 

updated activity data, and thus could be used to set conformity budgets. On July 10, 2003 EPA 

found the conformity budgets to be adequate. On September 4, 2003, EPA found the Amended 

ROP Plan to be complete, and it is under review at EPA. 

7

 ARB’s rulemaking activities are heavily influenced by the attainment planning schedule for the 

South Coast Air Basin, which as an extreme ozone nonattainment area must attain the federal 1-

hour ozone standard by November 15, 2010. 
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The District and the California Air Resources Board (ARB) have acknowledged 

that emission reductions stemming from new state and federal controls (which 

are outside of the District’s authority to implement) are needed to demonstrate 

attainment of the 1-hr ozone standards in the SJVAB, and that these controls will 

not go into effect until after 2005. The District needed a mechanism to allow time 

for state and federal measures to come into effect in order to attain the standard. 

Since the District could not accelerate implementation of state and federal 

measures, other options were explored. Section 181(b)(3) of the Federal Clean 

Air Act allows states to request EPA to reclassify an area to a higher 

classification. Higher classes reflect a more substantial nonattainment problem 

that in turn requires more time to solve. The District’s only option for pursuing a 

higher classification, with a later attainment date, was to request classification as 

extreme nonattainment.8

 

The District held numerous workshops and other public discussions (e.g., staff 

reports at Governing Board meetings) during the period 2001—2003 on the 

subject of requesting EPA to reclassify the SJVAB as extreme nonattainment for 

the federal 1-hour ozone standards. Consequently, on December 18, 2003, after 

extensive public debate and stakeholder discussion, the District’s Governing 

Board voted unanimously to request EPA through ARB to classify the SJVAB as 

extreme nonattainment for the federal 1-hour ozone standards. 

ARB forwarded this request to EPA on January 9, 2004. On February 23, 2004 

EPA proposed approval of the request (69 FR 8126) and on April 18, 2004, EPA 

signed the final rule approving the request. The classification as extreme 

nonattainment became final on May 17, 2004 (69 FR 20550). This classification 

changes the SJVAB’s attainment date for the federal 1-hour ozone standard to 

November 15, 2010, thereby providing time for critical state and federal 

emissions controls to come into effect in the post-2005 time frame. The 

classification to extreme also removes all prior “severe” area requirements and 

associated sanctions and FIP clock because once a nonattainment area is 

reclassified, the Federal Clean Air Act requirements of the new classification 

supersede those of the previous classification, and the previous attainment 

requirements (and any associated deficiencies) are moot (69 FR 8127). No 

sanctions or FIP clock for planning deficiencies for the Federal 1-hour ozone 

standard apply to the SJVAB as of May 17, 2004.9

 

8

 In May 2001, The District requested EPA to designate the SJVAB as “Severe-17”, which would 

have extended the attainment date to November 15, 2007. In November 2001, EPA denied the 

request because the “Severe-17” category can be assigned based only on design value, and the 

SJVAB’s 1-hour design value at the time of the request was not high enough for classification as 

“severe-17.” (66 FR 56476) 9

 EPA has an obligation to issue a FIP if they do not approve the Amended 2002 and 2005 Rate 

of Progress Plan for San Joaquin Valley Ozone that was submitted to them in April 2003. The 

District owes this Plan to EPA whether the District’s classification is extreme or severe. 
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1.4 EXTREME AREA REQUIREMENTS 

Extreme nonattainment areas must meet all requirements specified in Section 

182(d) of the FCAA for a “severe” area plus the requirements for extreme areas 

specified in Section 182(e). Table 1-2 compares key federal Clean Air Act 

provisions for severe and extreme nonattainment areas. 

When it transitioned from severe to extreme nonattainment, the District’s 

attainment date changed to November 15, 2010, and it also picked up two 

additional ROP milestone years of 2008 and 2010 for which it must demonstrate 

that SJVAB emissions reductions are meeting the targets established by the 

federal Clean Air Act for these years. In addition to these general planning 

requirements, the District must begin to implement the other extreme area 

requirements shown in Table 1-2. 

The federal Clean Air Act requires extreme nonattainment areas to define a 

major source as one whose emissions of ozone precursors meet or exceed 10 

tons per year. The lower major source definition also affects implementation of 

two other programs: New Source Review (NSR) and Title V permitting. For the 

SJVAB, the lower major source threshold under extreme would require an 

estimated 150 more sources to obtain Title V permits10 (exclusive of agricultural 

sources). For NSR, the lower major source threshold is expected to have a 

minimal effect on SJVAB sources because the District’s NSR program 

requirements already meet “extreme” levels (10 tons per year) due to California 

Clean Air Act requirements. The offset ratio would change to the higher level of 

1.5:1, with the option of a 1.2:1 ratio if the District is able to demonstrate use of 

best available control technology on all major sources. The District is committed 

to submitting revised NSR and Title V rules reflecting “extreme” classification to 

EPA by May 16, 2005, as required by the Final Rule reclassifying the SJVAB to 

extreme nonattainment (69 FR 20552).11 The District already complies with the 

“clean fuels” part of the extreme area requirements (Section 4.2). The traffic 

control measures are optional, as is the new technologies provision that is used 

in Chapter 5 of this plan. Lastly, the District adopted a rule on May 16, 2002 

implementing a nonattainment fee of $5000 per ton of emissions, and submitted 

the rule through ARB to EPA for approval. EPA has not yet taken final action on 

the rule, which was written to apply to either a severe or extreme nonattainment 

area. 12 This Extreme OADP meets all federal requirements for extreme area 

plans, as is shown in Appendix G. 

 

10 The District issues permits to about 7000 facilities, exclusive of agricultural operations. 11 The District could revisit the NSR rule again after EPA revokes the federal 1-hour ozone 

standard on June 15, 2005, due to the effects of revocation on new source review as specified in 

Phase I of the final rule implementing the federal 8-hour ozone standard (40 CFR 51.905(e)(4)) 

[NSR thresholds are growth measures that change with an area’s classification]. 

12 This rule, if trigged by nonattainment, would generate an estimated $4 million to $ 36 million 

per year in the SJVAB, but federal law does not mandate how the funds should be spent. 
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TABLE 1-2 

 Provisions for Severe vs. Extreme Nonattainment Areas 

[FCAA Sections 182(d) and (e) and section 185] 

Category Severe Area Provisions Extreme Area Provisions 

Major Stationary 

Source 

Includes any stationary source or 

group of sources located within a 

contiguous area and under common 

control that emits, or has the 

potential to emit, at least 25 tons per 

year of VOCs or NOx. 

Includes any stationary source or group of sources 

located within a continuous area and under common 

control that emits, or has the potential to emit, at least 

10 tons per year of VOCs or NOx. 

Modifications to 

Sources 

Not applicable Any change at a major stationary source that results in 

any increase in emissions from any discrete operation, 

unit, or other pollutant-emitting activity at the source 

shall be considered a modification from the standpoint 

of permit requirements unless the increase is offset by 

reductions in the same pollutant from other discrete 

operations within the same source at an offset ratio of 

at least 1.3 to 1. 

Clean 

Fuels/Advanced 

Control 

Technologies 

for Boilers 

Not applicable Extreme areas shall submit plan revisions that require 

each new, modified, and existing electric utility and 

industrial/commercial boiler emitting >25 tons per year 

of NOx to burn as its primary fuel, natural gas, 

methanol, or ethanol or use advanced technology for 

reducing NOx emissions. 

Traffic Control 

Measures 

Not applicable Extreme plans may contain provisions establishing 

traffic control measures applicable during heavy traffic 

hours to reduce the use of heavy-duty or high-polluting 

vehicles. 

New 

Technologies 

Not applicable EPA may approve extreme area SIP provisions that 

anticipate development of new control techniques or 

improvement of existing control technologies, and 

attainment based on these provisions, if the state can 

demonstrate that such provisions are not needed to 

achieve the emission reductions in the 1990—2000 

time frame and if the state has submitted enforceable 

commitments to develop and adopt contingency 

measures to be implemented if the new technologies 

do not produce the intended emission reductions. 

Offset 

Requirement 

Emission offset requirement is at 

least 1.3 to 1 for new or modified 

sources as the ratio of total emission 

reductions of VOCs to total increase 

emissions of such air pollutants, 

except if all existing major sources in 

the nonattainment area use best 

available control technology for the 

control of VOCs and NOx, the ratio 

remains at least 1.2 to 1. 

The ratio of total emission reductions of VOCs to total 

increased emissions of such air pollutant shall be at 

least 1.5 to 1, except that if the State plan requires all 

existing major sources in the nonattainment area to 

use best available control technology for the control of 

volatile organic compounds, the ratio shall be at least 

1.2 to 1. 

Failure to attain 

fee 

If area fails to attain the standard by 

November 15, 2005, major stationary 

source of VOCs in the area shall pay 

a fee to the state of $5000/ton of 

VOC emissions per calendar year in 

excess of 80% of a baseline defined 

as the actual or allowable emissions. 

Same requirements except for attainment date of 

November 15, 2010. 
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1.5 PLAN DEVELOPMENT 

1.5.1 Process 

In June 2002, recognizing the likelihood of eventually requesting classification to 

extreme nonattainment, the District Governing Board directed staff to begin 

preparation of a plan that demonstrates attainment of the federal one-hour ozone 

standard by November 15, 2010. Work on the Extreme OADP has been ongoing 

since June 2002; most of the initial effort was directed at preparing the Amended 

2002 and 2005 Rate of Progress Plan for San Joaquin Valley Ozone. 

Consequently work focused on updating emissions inventories and control 

measures, and examining emissions trends over time. 

Independent of the Ozone Rate of Progress Plan, work was also ongoing in this 

time frame on analysis of meteorological and atmospheric chemistry data 

collected during the summer 2000 Central California Ozone Study (CCOS). This 

data analysis supported selection of ozone episodes from the summer of 2000, 

and the simulation of ozone levels for the episodes as the basis for attainment 

demonstrations in the Extreme OADP. The District and ARB developed this 

Extreme OADP with the best CCOS information available through March 2004. 

As CCOS work continues and new information becomes available, it will be 

incorporated into future revisions of the Extreme OADP or in future plans for 

attaining the federal 8-hour ozone standard. At a minimum, the District is 

committed to revising the Extreme OADP in 2007 (assuming EPA is still requiring 

states to conduct planning activities for the federal 1-hour ozone standard, which 

they plan to revoke in June 2005); this revision would include updated ozone air 

quality information, updated or new control measures as appropriate, updated 

emissions inventories, and revised modeling as appropriate. If EPA does not 

require the Extreme OADP to be revised in 2007, any updated analyses and 

control measure evaluations would be presented in the 8-hour ozone attainment 

demonstration plan that is due to EPA by June 15, 2007. 

Section 6 provides more information on the public process used to develop this 

Extreme OADP. The District conducted public workshops on the Extreme OADP

in July 2003, January 2004, and in August 2004. Monthly coordination meetings 

among District staff, ARB, and the transportation planning agencies helped guide 

the plan development over the 2003—2004 time period. Many regularly 

scheduled technical meetings among staff from ARB and other districts 

addressed emissions inventory and photochemical modeling issues (see Section 

5 and Appendix D for more information). 
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1.5.2 Schedule 

In its final rule reclassifying the SJVAB to extreme nonattainment, EPA specified 

a due date of November 15, 2004 for the SJVAB Extreme OADP (69 FR 20550). 

This rule became effective on May 17, 200413. The Draft Extreme OADP was 

released to the public for review on July 30, 2004; the public comment period 

closed on August 27, 2004. The District Governing Board is scheduled to 

consider the Extreme OADP for adoption on October 8, 2004. Following 

adoption, the Extreme OADP would be sent to ARB for approval on October 28, 

2004, and then on to EPA by November 15, 2004. 

1.5.3 Content 

This Extreme OADP is organized into the following chapters. Chapter 2 

presents an overview of SJVAB ozone air quality, including air quality monitoring 

data, air quality determinants, ozone effects, and trends in ozone air quality. 

Chapter 3 presents the planning emissions inventories used as the foundation for 

this plan. Current and future emission control measures are discussed in 

Chapter 4. Chapter 5 is the heart of this Extreme OADP, and uses emissions 

and air quality data to project future air quality and provide the basis for 

projecting future attainment of the federal 1-hour ozone standard. Chapter 6 

summarizes public outreach conducted during plan development, while Chapter 

7 fulfills Rate of Progress requirements in the federal Clean Air Act. Chapter 8 is 

included to meet separate State of California requirements for a triennial 

progress report and California Air Quality Attainment Plan revision, and Chapter 

9 defines acronyms and other terms used throughout the document. Lastly, a 

series of appendices performs two important functions: presenting detailed and 

technical information that supports the plan, and allowing the main body of the 

plan to be shorter and easier to understand for the lay audience. 

As shown in Appendix G, the federal elements in the Extreme OADP meet all 

federal requirements for extreme nonattainment area plans. Also as shown in 

Appendix G, the state elements in the Extreme OADP (principally Chapter 8) 

meet all state requirements for air quality attainment plans. 

 

13 In its Final Phase I Rule implementing the federal 8-hour ozone standard, EPA specified that 

unmet obligations for 1-hour attainment plans could be met using one of three options, any of 

which would be due on June 15, 2005 (69 FR 23998). One of the options is to prepare a 1-hour 

ozone attainment demonstration plan. The Final Phase I Rule for 8-hour ozone became effective 

on June 15, 2004. As of the date of this document, this apparent discrepancy in due dates for the 

SJVAB’s 1-hour ozone attainment demonstration plan has not been clarified. 
❖
Chapter 2 – San Joaquin Valley Air Quality
❖
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2 SAN JOAQUIN VALLEY AIR QUALITY 

2.1 INTRODUCTION 

The SJVAB consists of eight counties: Fresno, Kern (western and central), Kings, 

Madera, Merced, San Joaquin, Stanislaus, and Tulare (see Figure 2-1). 

Cumulatively, these counties represent approximately 16 percent of California’s 

geographic area, making the SJVAB the second largest air quality basin (based 

on area) as delineated by ARB. The current population within the SJVAB is 

approximately 3.4 million people. Based on California State Department of 

Finance projections, the population in the SJVAB is expected to grow to 3.6 

million by 2005, to 4 million by 2010 and to 4.9 million by 2020. 

 FIGURE 2-1 

Counties Comprising the San Joaquin Valley Air Basin

San Joaquin

 Stanislaus

 Merced Madera 

 Fresno

Tulare

 Kings

Kern
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2.2 AIR QUALITY DETERMINANTS IN SJVAB 

2.2.1 General 

Air pollution in the SJVAB can be attributed to human-related (anthropogenic) 

activities that produce emissions. Air pollution from significant anthropogenic 

activities in the SJVAB includes a variety of industrial-based sources as well as 

on- and off-road mobile sources. Activities that tend to increase mobile activity 

include increases in population, increases in general traffic activity (including 

automobiles, trucks, aircraft, and rail), urban sprawl (which will increase 

commuter driving distances), and general local land management practices as 

they pertain to modes of commuter transportation. These sources, coupled with 

geographical and meteorological conditions unique to the area, stimulate the 

formation of unhealthy air. The geography of mountainous areas to the east, 

west and south, in combination with long summers and relatively short winters, 

contributes to local climate episodes that prevent the dispersion of pollutants. 

Transport, as affected by wind flows and inversions, also plays a role in the 

creation of air pollution. These conditions are described in the following sections. 

2.2.2 Geography and Topography 

California is divided into regional air basins according to topographic air drainage 

features. The SJVAB consists of a continuous intermountain valley 

approximately 250 miles long and averaging 80 miles wide (Figure 2-1). On the 

western edge of the Valley is the Coast Mountain range, with peaks reaching 

5,020 feet, and on the east side is the Sierra Nevada range with some peaks 

exceeding 14,000 feet. The Tehachapi Mountains form the southern boundary of 

the Valley. This mountain range includes peaks over 6,000 feet, and contains 

mountain passes to the Los Angeles basin and the Mojave Desert. The SJVAB 

floor is only open to the north. 

Although marine air generally flows into the basin from the San Joaquin River 

Delta, the region’s topographic features restrict air movement through and out of 

the basin. The Coastal Range hinders wind access into the valley from the west, 

the Tehachapi Mountains prevent southerly passage of airflow, and the high 

Sierra Nevada range forms a significant barrier to the east. Additionally, most of 

the surrounding mountains are above the normal height of summer inversion 

layers (1,500-3,000 feet). These topographic features result in weak airflow. 

The wind pattern produces conditions that result in poor horizontal dispersion of 

pollutants. During high-pressure events over the SJVAB, pollutant dispersal is 

also limited vertically by inversions, as explained in 2.2.3. As a result, the SJVAB 

is highly susceptible to pollutant accumulation over time. 
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2.2.3 Climate 

Warm, dry summers and cool winters characterize the SJVAB floor. The 

average mean temperature over a thirty-year period is 65°F. High daily 

temperature readings in summer average around 95°F. The SJVAB also 

experiences mild winters, where the average daily low temperature is 45°F. In 

general, the SJVAB averages 106 days a year with 90°F or hotter, and 40 days a 

year with 100°F or hotter. The daily summer temperature variation can be as 

high as 30°F. The SJVAB has an “inland Mediterranean” climate that averages 

over 260 sunny days per year, primarily because semi-permanent high pressure 

systems establish themselves over the SJVAB and deflect low-pressure systems 

that might otherwise bring rain and winds. 

Precipitation in the SJVAB is confined primarily to the winter months with some 

usually occurring in late summer and fall. Average annual rainfall for the valley 

floor of the SJVAB is 9.25 inches, but varies from over 20 inches in the north part 

of the Valley to less than 5 inches in the south. 

For the purposes of transport, wind flows and inversion layers will be discussed. 

Wind speed and direction play an important role in the dispersion and transport 

of air pollutants. Wind moves ozone precursors and ozone downwind from 

source areas of emissions or areas where ozone is formed. Figure 2-2 depicts 

typical wind flow patterns for day and night during the ozone season in the 

SJVAB. As can be seen, the dominant wind flow pattern (day or night) in the 

SJVAB is from the northwest to the southeast, along the axis of the Valley. 

During the daytime, surface winds enter the SJVAB primarily from the north 

through the San Francisco Bay area; they also enter at other locations through 

passes in the coastal range. The air picks up ozone precursors emitted in the 

Bay Area and transports them down the valley where they eventually form ozone 

in the SJVAB. Precursor emissions from SJVAB source areas (Stockton, 

Modesto, Merced, etc.) are also transported down the valley where they are 

converted to ozone. This general transport moves air near the surface south 

from Stockton to Bakersfield. The effect of the transport is seen to the southeast 

of Fresno and Bakersfield. The city of Parlier (near the city of Fresno), and the 

communities of Edison and Arvin near Bakersfield, often experience the highest 

ozone levels in the SJVAB. Air leaves the southern end of the Valley during the 

day by flowing over the Tehachapi Mountains (southeast of Bakersfield) into the 

Mojave Desert, thereby transporting ozone and other pollutants out of the 

SJVAB. Also during the daytime, heated air rises into the mountains and 

transports ozone and other pollutants up the Sierra Nevada and coastal 

mountains. 
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FIGURE 2-2 

San Joaquin Valley Wind Patterns During Ozone Season

Source: SJVAQSPC 1996

At night, the same general wind flow pattern continues, with some important 

exceptions. First, the air is no longer able to exit the southern end of the SJVAB 

because it encounters cooler drainage winds from the surrounding mountains. 

Consequently, it is forced back north to set up a circular flow pattern (Figure 2-2) 

known as the Fresno eddy. The eddy circulates pollutants in a counterclockwise 

pattern, and returns polluted air to urban areas where more precursors are added 

the next day. Another important difference about the nighttime winds in the 

SJVAB is that they typically are caused by a jet stream of fast moving air at an 
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altitude of about 1000 ft and a speed of up to 30 mph. Lastly, some of the 

pollutants transported to higher altitudes from daytime heating return to the valley 

at night because of drainage winds from the mountains. 

Inversions affect air pollutant transport by limiting vertical dispersion of pollutants. 

An inversion occurs in the atmosphere when air temperature increases with 

height rather than decreases. Pollutants emitted to the atmosphere will rise and 

disperse as long as they are warmer than the surrounding air. When pollutants 

encounter air that is the same temperature or that is warmer, they are no longer 

able to rise and thus they remain at the elevation of the warmed air. Inversions 

limit vertical movement of air because displacement of air up or down in an 

inversion results in the air returning to its original level. This is called a stable 

atmosphere and results in little vertical air movement and therefore poor vertical 

pollutant dispersion. The inversion thus acts like a lid on the atmosphere. The 

SJVAB experiences two common types of inversions: radiation and subsidence 

inversions. 

Nocturnal cooling of an air layer near the earth’s surface is the principal cause of 

radiation inversions. The radiation inversion extends upward several hundred 

feet from the ground and occurs during the evening and early morning hours. 

During a radiation inversion, little vertical mixing occurs, which minimizes 

pollutant dispersal. At daybreak, the sun begins to heat the ground, which in turn 

heats the lower layers of air and eventually lifts and breaks the inversion, thereby 

facilitating pollutant dispersal. During summer months, daytime heat from the 

sun lifts the inversion to heights anywhere from 2,000 to over 5,000 feet (even 

higher over mountain ranges due to heating of the slopes), which helps disperse 

pollutants and lowers their concentrations. However, these same summer 

daytime conditions also increase ozone production, which can neutralize or offset 

the effects of enhanced vertical dispersion. Studies have shown that radiation 

inversions tend to persist longer into daylight hours in the southern part of the 

SJVAB due to a lack of marine air intrusion and associated atmospheric mixing. 

On the worst dispersion days the inversion may remain only a few hundred feet 

above the surface of the SJVAB. 

Subsidence inversions are caused by downward motion (subsidence) high in the 

atmosphere, typically in association with a high-pressure area positioned along 

the coast of California. As air descends under the influence of the high pressure 

system, it compresses and heats up, and as a result becomes warmer than the 

air beneath it. This limits vertical mixing, as the warm air aloft restricts air 

movement from below. 

During inversion events, air pollutant emissions build up in the atmosphere below 

the inversion; ozone precursors then react to form ozone, and levels increase 

from day to day. One-hour concentrations of ozone that exceed federal 

standards generally occur in the SJVAB during strong inversions. During many 

high ozone level events, the SJVAB is likely experiencing a combination of 

radiation and subsidence inversions. 
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2.2.4 Ozone Transport 

Ozone transport refers to the movement of ozone and ozone precursors from 

other basins to the SJVAB, from the SJVAB to other air basins, and within the 

SJVAB. Transport can occur at ground level and also at higher altitudes (e.g., 

movement of polluted air up mountain slopes during the day). Although 

improvements have been made in the SJVAB’s ozone air quality over the last 

decade, the basin continues to violate the federal 1-hour ozone standard on 

numerous days. Furthermore, in recent years, the location of the highest 

measured ozone levels has changed from northern Kern County to southeastern 

Fresno County. ARB’s 2001 assessment of ozone transport found that pollutants 

transported from other air basins affect the SJVAB’s ozone air quality, but the 

magnitude of the effect declines from north to south (ARB 2001). Local 

emissions are thought to be primarily responsible for the SJVAB’s worst ozone 

air quality. Attaining the federal 1-hour ozone standard by 2010 will require 

implementation of emission control measures in other basins, as governed by 

ARB’s Ozone Transport Mitigation Regulations, as well as reductions in the 

SJVAB’s precursor emissions. 

Transport of pollutants within the SJVAB plays a significant role in violations of 

the federal 1-hour ozone standard in the SJVAB. As discussed above, prevailing 

winds blow from the northern part of the SJVAB to the south, and can carry 

pollutants from San Joaquin, Stanislaus, and Merced counties to the Fresno 

area. Pollutants transported from the San Francisco Bay Area south to Fresno 

and Bakersfield must pass through the northern SJVAB, so transport from the 

San Francisco Bay Area to Fresno is combined with a northern SJVAB 

contribution. Further south, eddy currents can carry pollutants along the east 

side of the SJVAB from Tulare County and northern Kern County to the Fresno 

area. 

Ozone and precursors are transported from other basins to the SJVAB. On 

some days, according to the ARB study referenced above, pollutants transported 

from the San Francisco Bay Area affect ozone air quality in the northern SJVAB, 

mixing with local emissions to contribute to violations of the federal 1-hour ozone 

standard. On other days, violations of the standard are due entirely to local 

emissions. The effect of Bay Area transport diminishes with distance so that the 

ozone air quality in Fresno and Bakersfield is affected less. Overall, ARB rates 

the Bay Area’s impact on SJVAB ozone air quality as ranging from 

inconsequential to overwhelming (by itself can cause violations of the state 

standard) depending on meteorological conditions occurring at the time of 

transport evaluation and in the receptor area. ARB also identifies the broader 

Sacramento area as a source of ozone and precursor transport to the SJVAB, 

but the effect only ranges from significant (contributes to a violation of the 

standard when combined with local emissions) to inconsequential. 
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The SJVAB is also a source area for pollutants transported to other air basins. 

According to the ARB, the SJVAB can be a source area affecting ozone air 

quality in the broader Sacramento area, the Great Basin valleys, the mountain 

counties, the Mojave Desert, and the north central and south central coasts, 

depending on meteorological conditions. ARB rates the SJVAB’s contributions 

as ranging from inconsequential to overwhelming, depending on the receptor 

area. 

The above discussion is based upon a somewhat dated transport assessment 

that was limited in scope and limited by information on ozone behavior in the 

atmosphere. Work continues under CCOS to update our understanding of 

transport using improved emissions inventories, improved databases on 

meteorological behavior and atmospheric chemistry, and improved grid-based 

photochemical models. Consequently, findings and conclusions regarding 

transport may change from those presented above. Future development of 

CCOS episodes and modeling tools will provide updated and improved 

information to evaluate transport. Future plans addressing state or federal ozone 

standard attainment will incorporate significant advances in knowledge regarding 

transport. 

2.2.5 Population 

The SJVAB is a major geographic, population, and agricultural sub-region of 

California. Agriculture and agriculture-related businesses have thrived as a 

result of the Valley’s climate, excellent soil, extensive irrigation network, and its 

location between the San Francisco Bay Area and Southern California markets. 

The SJVAB represents approximately 16 percent of the geographic area of 

California. It extends from the northern boundary of SJVAB south through the 

Valley to the SJVAB portion of Kern County (not including Eastern Kern County). 

From east to west, the SJVAB extends from the crest of the Sierra Nevada 

Mountains including the entire San Joaquin River watershed, down across the 

valley floor and up to the crest of the Coast Range Mountains. 

The SJVAB is California’s second largest air basin in land area. It has a 

population of approximately 3.4 million persons with expected growth projections 

of nearly 30 percent in a period of twenty years. As a result of this population 

growth, activities associated with an increased population base, particularly the 

major population centers within the SJVAB represent a significant contributor to 

the high levels of pollutants in the area. 

Increased population growth, in itself, is a source of ozone precursors. New 

residents emit ozone precursors from activities such as driving, recreation, home 

maintenance, hot water heating, industrial and agricultural activities, etc. 

Chapter 3 presents information on the ozone precursor emission rates for various 

categories of sources. Table 2-1 shows the most recent published estimates of 

population levels and projections within the SJVAB.
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Table 2-1 

SJVAB Population and Land Area 

 

County 19901 20001 20101 20201 Land Area2

Fresno 667,490 803,401 949,961 1,114,654 5,963 

Kern3

446884 545049 663223 779091.84 4,355 

Kings 101,469 129,823 156,334 184,751 1,391 

Madera 88,090 124,372 150,278 183,966 2,136 

Merced 178,403 210,876 277,715 360,831 1,929 

San Joaquin 480,628 567,798 747,149 989,462 1,399 

Stanislaus 370,522 449,777 559,051 653,841 1,494 

Tulare 311,921 369,355 447,315 543,749 4,824 

Total 2,645,407 3,200,451 3,951,026 4,810,346 23,490 1 As of May 2004. State of California, Department of Finance, Intercensal Estimates of the Population of California 

Counties, updated revised report 90-00. 

 2Area in square miles. Air Resources Board, The 2004 California Almanac of EMISSIONS & AIR QUALITY, California 

Environmental Protection Agency, Sacramento, 2004. The surface areas shown reflect land portions of air basins only 

and exclude water bodies. 

3

 Kern County has portions located outside of the San Joaquin Valley Air Basin. Populations are adjusted based upon a 

17% total population reduction to account for the portion of Kern County outside of the air basin. 

The Valley is the home of the nation’s most productive agriculture industry. 

According to the California Department of Food and Agriculture (CDFA 2002), 

eight of the top ten agricultural producing counties in the United States are 

located in California and six of California’s top ten counties are located in the 

SJVAB. The top two counties, Tulare and Fresno, produced over $6.7 billion in 

commodities in 2001. Over 27,000 farms are located in the region. Harvested 

acreage exceeds 5.1 million acres per year. Another 5.4 million acres is used as 

rangeland and irrigated pasture. Although farmland is being reduced by 

urbanization, agriculture will continue to play a key role in the region’s economy. 

2.2.6 Development Patterns 

Population growth can affect ozone air quality, but the effect can be exacerbated 

by development patterns and the technology used by the population to support 

its economic activities. For example, sprawl development increases commute 

distances; if the vehicles used for these commutes contain an increased 

percentage of high emission vehicles, emissions could increase. The 

jobs/housing imbalance can contribute to longer commutes and increased 

emissions; for example, increasing numbers of workers in the Bay Area are 

moving to the SJVAB for affordable housing, yet keep their jobs in the Bay Area 

and commute longer distances. For these reasons, control measures developed 

and studied by local governments are increasingly important, because local 

governments have land use authority to effect changes, whereas the District, 

ARB, and EPA do not. 
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2.3 OZONE 

2.3.1 Background 

Ozone is a highly reactive gas molecule comprised of three oxygen atoms (O3); it 

has a light blue color at very high concentrations. Ozone occurs naturally at 

altitudes high in the stratosphere (35,000 to 65,000 feet, depending on latitude 

and season) where it shields life on earth from harmful ultraviolet radiation. 

Depletion of stratospheric ozone by chemical reactions involving anthropogenic 

chemicals (principally chlorofluorocarbons) allows this radiation to reach the 

earth’s surface, thereby endangering the biosphere. For this reason, the FCAA 

(Title VI) addresses protection of the stratospheric ozone layer to maintain the 

crucial function of ultraviolet radiation filter. Ozone is also present in the first few 

hundred feet of elevation above ground level (in the troposphere) due to 

chemical reactions between hydrocarbons and nitrogen oxides from natural and 

anthropogenic sources in the presence of sunlight. Because of its reactivity, 

tropospheric ozone present in high enough concentrations as an air pollutant 

adversely affects human health and damages crops and materials (see Section 

2.3.2). Consequently, Title I, Part D of the FCAA addresses the control of 

emissions to reduce tropospheric ozone concentrations to safe levels. This plan 

focuses only on tropospheric ozone and does not address protection of the 

stratospheric ozone layer. All references to “ozone” in this plan refer to 

tropospheric ozone. 

2.3.2 Adverse Effects 

Ozone is a major component of “smog”, and it affects human health, 

vegetation/crops, and materials. In humans, ozone can irritate and inflame the 

respiratory tract, particularly during heavy physical activity, which results in heavy 

coughing, throat irritation, and breathing difficulty. Ozone damages vegetation 

and agricultural crops by interfering with the photosynthesis process. Studies 

have shown reductions of up to 20 percent in yields of grapes, cotton, oranges, 

alfalfa, and tomatoes. The ARB estimates that the SJVAB’s agricultural crop 

losses exceed $150 million due to exposure to ozone. According to the National 

Park Service, up to half the Ponderosa and Jeffrey Pine in the Sierra Nevada 

Mountains show ozone injury. Ozone also damages a number of materials 

widely used in commerce such as rubber, cotton, nylon, polyester, dyes, paints 

and coatings. Exposure to ozone is of principal interest due to its health effects, 

as described in the following paragraphs. 

Over the years, research studies of ozone in animal laboratories, human clinical 

studies and epidemiological studies have produced a multitude of evidence that 

correlates exposure to ozone and adverse health effects (ALA 2002). Ozone, 

acting as a strong oxidizer, has proved to significantly harm the respiratory 

system, thereby leading to the permanent damage of lung tissues. These 

damaged lung tissues result in decreased lung capacity. Chronic exposure to 
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high levels of ozone have also been established to negatively impact the immune 

system, making people more susceptible to respiratory illnesses, including 

bronchitis and pneumonia (Burnett 2001). Ozone also accelerates aging, and 

increases susceptibility to other infections (EPA 1999). Furthermore, ozone 

exposure exacerbates pre-existing asthma and bronchitis conditions, and in 

areas of high concentrations can lead to the development of asthma among 

active children (Gent 2003). 

Recent research continues to highlight the extent and severity that ozone 

exposure poses to human health. Exposure to ozone begins to adversely impact 

human health even before birth. Studies have shown that ozone exposure may 

be potentially related to cardiac birth defects during vulnerable pregnancy 

periods (Ritz 2002). Children are one of the groups most sensitive to ozone. 

They are more vulnerable than adults because of their size and physical 

immaturity and their tendency to be more active and to spend more time 

outdoors (where ozone levels are higher). Children also breathe in more air per 

pound of body weight than adults, thus exposing them even more to ozone 

toxicity (EPA 1997). Children who grow up in environments with high levels of 

ozone may also be expected to show diminished lung growth and capacity, 

making ozone a risk factor for premature respiratory morbidity later in life (ALA 

2002). In areas of elevated summertime ambient concentrations of ozone, a 

positive association with increases in emergency or urgent hospital admissions 

for respiratory problems in children less than 2 years of age was detected 

(McConnell). Asthmatic children using maintenance medication are especially 

vulnerable to ozone, even at levels below the EPA standards (Gent 2003). 

Asthma severity as measured by symptoms, medication use, restrictions in 

activity, or use of medical services, has been discovered to be affected by ozone 

exposure. With over 20 million Americans suffering from asthma, and only 60% 

of those Americans having it under control, ozone exposure has the possibility to 

affect many people (NHI 2003). Between 1980 and 1995, the percentage of 

children in the United States with asthma doubled, from 3.6 percent in 1980 to 

7.5 percent in 1995. The percentage dropped in 1996 to about 6 percent, but by 

2001 it had risen again, this time to 8.7 percent (6.3 million children) (CNN 2003). 

Hospital admissions for all respiratory causes including asthma show a 

consistent increase as ambient ozone, sulfate, or sulfur dioxide levels increase in 

a community (SCAQMD 2003). Fourteen Americans die every day from asthma, 

a rate three times greater than just 20 years ago (EPA 1997). Ozone greatly 

aggravates asthma by making asthma sufferers more sensitive to allergens, 

which are the most common triggers for asthma attacks. In addition, those 

suffering from asthma are more severely affected by the decreased lung capacity 

and irritation that ozone provokes upon the respiratory system (EPA 1999). 

Recent studies have also begun to demonstrate a causal link between ozone 

exposure and asthma. Results show that playing multiple team sports in a high 

ozone environment is associated with the development of physician-diagnosed 

asthma. The results were consistent with a large increased risk both for new-
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onset asthma and for the exacerbation of previously undiagnosed asthma 

(McConnell). These findings suggest that new incidences of asthma diagnoses 

can be associated with heavy exercise in communities with high concentrations 

of ozone. Children who participate in three or more outdoor sports and live in 

high ozone environments have a risk 3.3 times greater of developing asthma 

than those who did not play sports (McConnell). 

Another potentially significant finding is that animals in ozone studies have 

demonstrated possible chronic effects from ozone exposure, including 

permanent functional and structural changes of the lung (Burnett 2001). 

Repeated inflammation associated with ozone exposure over a lifetime may 

result in sufficient damage to lung tissues that individuals would then experience 

lower quality of life in terms of respiratory function and activity level (SCAQMD 

2004). In fact, living in an area of high levels of ozone and related co-pollutants 

for four or more years is associated with diminished lung function and more 

frequent reports of respiratory symptoms (Galizia 1999). 

Active children are considered to be most at risk from ozone exposure. Those 

children spend a significant part of their time outdoors, engaged in physical 

activity. Children are also more likely to have asthma or other respiratory 

illnesses. Asthma is the most chronic common disease for children (McConnell). 

Active adults are also at a significant risk. Healthy adults of all ages who 

exercise or work strenuously outdoors are considered a “sensitive group” 

because they have a higher level of exposure to ozone than less physically 

active people (EPA 1999) Individuals with respiratory diseases such as asthma 

are also considered at risk because ozone aggravates their condition. Asthma 

and other chronic respiratory diseases make an individual’s lungs more 

vulnerable to the effects of ozone. These individuals will suffer the effects of 

ozone at lower levels than sensitive people. Others are unusually susceptible to 

ozone. Scientists have yet to explain why certain people are more sensitive to 

ozone than others. Finally, elderly people will be at higher risk from ozone 

exposure if they already suffer from respiratory disease, are active outdoors, or 

are one of those unusually susceptible to ozone exposure. 

2.3.3 Precursors and Formation 

Ozone is the product of a series of chemical reactions involving sunlight, reactive 

organic gases [also called volatile organic compounds (VOCs)] and nitrogen 

oxides (NOx). VOCs and NOx are “ozone precursors” and are considered 

primary pollutants because they are emitted directly into the atmosphere. ARB 

originally expressed the December 5, 2001 hydrocarbon emissions data as 

reactive organic gases (ROG) rather than the currently used volatile organic 

compounds (VOC). Since ARB now considers the terms to be synonymous, 

“ROG” has been renamed as “VOC” in this plan. VOC emissions are a subset of 

ROG emissions. ROG is composed of hydrocarbon compounds that may 

contribute to the formation of smog by their involvement in atmospheric chemical 
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reactions. Ozone is considered a secondary pollutant because it is formed in the 

atmosphere from primary pollutants via photochemical reactions. 

Because solar energy is required to form ozone and the chemical reactions are 

not instantaneous, the greatest concentrations of ozone are usually downwind of 

urban centers and usually occur on summer afternoons when sunlight is most 

intense. In summer, as weather systems move through the area, a cycle of 

stable and less-stable air masses over the valley results in alternating periods of 

higher and lower ozone concentrations. During the winter months, a number of 

factors contribute to reduced ozone concentrations: clouds and fog block the 

required solar radiation at ground level, the sun angle is lower, the days are 

shorter, wintertime storms produce good dispersion conditions that inhibit the 

buildup of pollutants, and temperatures are not high enough to produce ozone in 

great quantities. 

2.3.4 Design Value Determinations from Ozone Levels 

Section 1.2.1 described the term “design value” for the federal 1-hour ozone 

standard. In general, the design value is the pollutant concentration in the 

atmosphere at which healthy air exists. Ambient air quality standards for which 

attainment is defined in terms of the number of instances in which a numeric 

value is exceeded in a given time frame are called “exceedance-based” 

standards. For standards such as these, which includes the federal 1-hour 

ozone standard, the design value must therefore be calculated.1

 The design 

value is currently calculated for the federal 1-hour ozone standard by taking the 

fourth highest2 daily maximum 1-hour ozone concentration at a given monitoring 

station during the three-year compliance period. The design value for a 

geographic area with more than one monitor, such as an air basin or county, is 

the same as the highest monitoring station’s design value. 

The design value for the SJVAB in 1994 (when the previous OADP was 

prepared) was 0.160 ppm (160 ppb). The SJVAB’s current design value, based 

on 2003 air quality monitoring data, has dropped to 0.151 ppm (151 ppb). Figure 

2-3 illustrates the SJVAB’s trend in 1-hour design value. 

 

1

 The calculation is needed to “translate” the exceedance-based information (e.g., number of 

times pollutant levels are higher than the numeric value of a standard) to a concentration 

(because design values are concentrations). In contrast to the federal 1-hour ozone standard, 

the federal 8-hour ozone standard is concentration-based, not exceedance-based, such that the 

design value is the same as the standard. 

2

 Since an area can be in attainment with three exceedances of the federal 1-hour ozone 

standard in three years, the fourth highest value is of interest for the design value. 
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Figure 2-3 

Basin 1-Hour Design Value for 1986 - 2003

100

120

140

160

180

200

1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003

Year

Ozone ppb

Basin Design Value

2.3.5 Area Classification for the One (1)-Hour Ozone Standard 

Attainment for the one-hour ozone standard requires that the concentration of 

0.12 ppm by volume not be exceeded, on average, more than one day per year 

at any one monitoring station over any three-year period. If there are four or 

more exceedance days at a single monitor during a three-year period, the 

average number of exceedance days per year exceeds one and the air basin has 

not attained the standard. The EPA’s finding (November 2001) that the SJVAB 

did not attain the 1-hour ozone standard on schedule was based on the area’s 

design value (it is greater than 0.12 ppm) and the average number of 

exceedance days per year during the 1997 to 1999 period. 

2.3.6 One (1)-Hour Ozone Exceedance Trends 

Figure 2-4 shows the long-term trends in the SJVAB for the number of days over 

the federal 1-hour ozone standard, by region in the SJVAB (northern, central, 

southern), as well as by the basin as a whole. The Northern Region consists of 

San Joaquin, Stanislaus, and Merced counties. The Central Region consists of 

Madera, Fresno and Kings counties. The Southern Region consists of the 

western part of Kern County as well as Tulare County. As can be seen, the 
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number of days over the standard overall has decreased basinwide from a peak 

of over 70 in the late 1980’s to a level of 37 in 2003. However, short-term trends 

show an increase in the number of days over the standard basinwide: from below 

30 days in 1999 to 37 in 2003. A similar trend is observed for the Southern 

Region. Northern and Central Regions show a downward trend in this time 

frame. Trends in other ozone statistics primarily with respect to the State Ozone 

Standard are shown in Section 8. 

Figure 2-4 

Number of Days Over the Federal 1-hour Ozone Standard in the 

San Joaquin Valley Air Basin by Region

Number of One-Hour Ozone Exceedances from 1984-2003

0

10

20

30

40

50

60

70

80

1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003

Year

Number of Days

Northern Central Southern Basin

Figure 2-5 summarizes the SJVAB monitoring sites with more than three 

exceedances during 2001-2003. Compliance is achieved when this number is 

three or less for a three year period. As shown in Figure 2-5, eight monitoring 

sites experienced more than three exceedances, with one site (Arvin) 

experiencing more than 50 exceedances and another (Parlier) more than 40 

exceedances. These data reflect the pervasiveness of the SJVAB’s 1-hour 

ozone nonattainment problem. 
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Figure 2-5 

SJV Ozone Exceedances 

2.3.7 Status of Federal 8-Hour Ozone Standard 

The federal 8-hour ozone standards adopted by EPA in 1997 (0.08 ppm by 

volume for primary and secondary standards) were overturned in the US Circuit 

Court of Appeals for the District of Columbia in 1999 on the grounds that the 

agency had overstepped its authority and unlawfully usurped Congress’ 

legislative power. However, the EPA appealed the case to the US Supreme 

Court. In February 2000, the Supreme Court found that that EPA had not 

overstepped its authority and had not unlawfully usurped Congress’ legislative 

power; however, the Court did find that the implementation policy was unlawful. 

The Court confirmed that the Clean Air Act does not bar EPA from implementing 

the ozone standard. On November 13, 2002, the American Lung Association 

and eight other public interest groups filed a complaint alleging that EPA failed to 

designate areas for the 8-hour ozone standard. In response to this complaint, 

EPA published a proposed consent decree establishing April 15, 2004 as the 

date for promulgating attainment designations for the 8-hr ozone standard (67 FR

70070). EPA issued these designations on April 15, 2004. In addition, EPA also 

issued the Phase I of the implementation rule for the 8-hour standard on April 15, 

2004, which includes provisions on revocation of the 1-hour standard, antibacksliding, and area classifications. The effective date of the 8-hour ozone 

designation is June 15, 2004. EPA designated the SJVAB as nonattainment for 

the federal 8-hour ozone standard, and classified the SJVAB, based on its 2001-

0

10

20

30

40

50

60

Arvin

Clovis

Edison

Fresno-Drummond

Fresno-First

Fresno-Shaver Lake

Fresno-SSP

Parlier

SJVAB Sites with More Than Three Exceedances, 2001-2003
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2003 design value, as serious nonattainment. As such, the SJVAB’s attainment 

date for the federal 8-hour ozone standard is June 15, 2013. EPA will require 

submittal of the 8-hour OADP for the SJVAB in 2007. 

Phase I of the Final Rule also gives the District the option of preparing an early 8-

hour ozone increment of progress report or an early 8-hour OADP in lieu of 

submitting this Extreme OADP for the 1-hour ozone standards. Because EPA 

has found the 1-hour ozone standard is not necessary to protect public health, 

EPA has instructed states to focus resources on planning and implementation of 

the 8-hour ozone standard. (69 FR 23858) 

2.4 OZONE MONITORING 

2.4.1 Monitoring Network 

EPA requires ARB and the District to measure the ambient levels of air pollution 

to determine compliance with the NAAQS. To comply with this mandate, the 

District and the ARB operate an ambient monitoring network that consists of 28 

sites located throughout the SJVAB (see Figure 2-6). Not all stations monitor the 

same air quality or meteorological parameters, as indicated. Stations identified 

by a “G” designation in Figure 2-6 measure levels of ozone in the SJVAB’s 

atmosphere. 

Federal regulations require State and Local Air Monitoring System (SLAMS) 

networks to meet four basic monitoring objectives: 

• monitoring the highest concentration of a pollutant 

• monitoring representative concentrations in areas of high population 

density 

• monitoring the impact of major pollutant sources, and 

• monitoring pollutant background concentrations. 

Each monitor must be capable of representing a spatial scale consistent with its 

monitoring objective. Categories of spatial scale are: 

1) Microscale - An area of uniform pollutant concentrations with a radius 

ranging from several meters up to 100 meters. 

2) Middle Scale - Uniform pollutant concentrations in an area with a 

radius of approximately 100 meters to 0.5 kilometers. 

3) Neighborhood Scale - Uniform pollutant concentrations in an area with 

a radius of approximately 0.5 to 4.0 kilometers. 

4) Urban Scale - Citywide pollutant concentrations in an area with a 

radius ranging from 4 to 50 kilometers. 

5) Regional Scale - Uniform pollutant concentrations that would be 

characteristic of a very large (for example, rural) area that has a radius 

from tens to hundreds of kilometers. 
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Locations for the physical siting of air quality monitors are selected based on the 

objectives of the monitoring. All ozone monitoring in the Valley is directed toward 

measuring representative population exposures and maximum concentrations. 

As a result, most ozone monitors in the Valley are scaled for either neighborhood 

or urban scale measurements.

FIGURE 2-6 

San Joaquin Valley Air Basin Air Quality Monitoring Network 

The SJVAB has 23 ozone monitoring stations, with eleven operated by District 

personnel, three by the National Park Service, and nine by ARB. All ozone 

monitors are continuous analyzers and operated on the principle of ultraviolet 

absorption (40 CFR Part 50). Table 2-2 lists all ozone monitoring sites in the 

SJVAB. 

As indicated by Table 2-2, all ozone monitoring in the Valley is directed toward 

measuring representative population exposures and maximum concentrations. 

As a result of these monitoring objectives, most ozone monitors in the Valley are 

scaled for either neighborhood or urban scale measurements. 
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The four major metropolitan areas within the SJVAB, (Stockton, Modesto, 

Fresno, and Bakersfield), each have ozone monitors to better characterize the 

ozone distribution in the metropolitan area. The Fresno and Bakersfield areas 

each have ozone monitors to measure upwind transport (Madera-Pump Yard and 

Shafter-Walker Street), middle-city concentrations (Fresno-First, BakersfieldCalifornia, and Bakersfield-Golden State), downwind city-edge concentrations 

(Fresno-Drummond and Edison-Johnson Ranch), and downwind maximum 

concentrations (Parlier and Arvin). The upwind transport and middle-city ozone 

monitors measure representative concentrations while the downwind city-edge 

and downwind maximum monitors measure maximum concentrations. The 

Clovis-Villa and Oildale-Manor ozone monitors, located in the northeast quadrant 

of the Fresno and Bakersfield metropolitan areas, respectively, are sited for 

maximum concentrations. The remaining ozone monitors are located in smaller 

urban areas and several remote locations. These monitors are located for 

representative concentrations (with the exception of the Merced-Coffee Avenue 

station) since the areas where they are located are not capable of producing high 

concentrations of ozone. 

2.4.2 Other ozone monitoring 

In addition to the permanent monitoring network described above, the District has 

participated in a number of special studies directed at ozone monitoring in the 

SJVAB. 

2.4.2.1 Fresno oxidant study 

In the period from June through November, 1976, ARB conducted a saturation 

study to determine ozone concentrations within the Fresno metropolitan area and 

produced a report entitled "The Areal Representativeness of Air Monitoring 

Stations - Fresno Study Phase I (Oxidant)". Questions posed for the study 

included whether the Fresno-Olive site measurements represented average 

population exposure, the extent which ozone concentrations vary along an 

upwind to downwind traverse of the city, where the highest concentrations 

occurred, and how many stations were necessary to assure that the highest 

population exposures were measured. 

The monitoring for this study was performed with mobile vans as well as fixed 

monitoring stations. Parameters measured include O3, NOX, CO, CH4, THC (total 

hydrocarbons), and meteorological parameters including wind speed and 

direction, temperature, and relative humidity. The stations were placed in an 

approximate line from the northwest to southeast edge of Fresno to document 

pollutant concentrations along an upwind-downwind traverse of the city. 
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Table 2-2 

Ozone Monitoring Stations in the San Joaquin Valley Air Basin 

Site Name Sampling 

Interval/Frequency 

Scale Monitoring 

Objective 

Type 

Arvin 1 Hour/Continuous Urban Representative Conc. PAMS1/NAM

Bakersfield-California 1 Hour/Continuous Neighborhood Representative Conc. SLAMS4 

Bakersfield-Golden State 1 Hour/Continuous Neighborhood Representative Conc. PAMS/SLA

Clovis-Villa 1 Hour/Continuous Neighborhood High Concentration PAMS/NAM

Edison-Johnson Ranch 1 Hour/Continuous Urban High Concentration SLAMS 

Fresno-Drummond 1 Hour/Continuous Neighborhood High Concentration SLAMS 

Fresno-First Street 1 Hour/Continuous Neighborhood Representative Conc. SLAMS 

Fresno-Sky Park 1 Hour/Continuous Urban Representative Conc. SLAMS 

Hanford-Irwin 1 Hour/Continuous Neighborhood Representative Conc. SLAMS 

Madera-Pump Yard 1 Hour/Continuous Urban Representative Conc. PAMS/SLA

1 PAMS- Photochemical Assessment Monitoring Systems 2 NAMS-National Air Monitoring Systems 3 ARB – California Air Resources Board 4 SLAMS- State and Local Air Monitoring Systems 5 SJVUAPCD- San Joaquin Valley Unified Air Pollution Control District
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Table 2-2 

Ozone Monitoring Stations in the San Joaquin Valley Air Basin (cont.) 

Site Name Sampling 

Interval/Frequency 

Scale Monitoring 

Objective 

Type 

Maricopa-Stanislaus 1 Hour/Continuous Urban High Concentration SLAMS 

Merced-Coffee Avenue 1 Hour/Continuous Urban High Concentration SLAMS 

Modesto-14th Street 1 Hour/Continuous Neighborhood Representative Conc. SLAMS 

Oildale-Manor 1 Hour/Continuous Urban High Concentration NAMS 

Parlier 1 Hour/Continuous Urban High Concentration PAMS/NAM

Sequoia Nat’l. Park-Ash Mtn. 1 Hour/Continuous Regional Representative Conc. SPM6 

Sequoia Nat’l. Park-Lookout 

Point 

1 Hour/Continuous Regional Representative Conc. SPM 

Sequoia Nat’l. Park-Lower 

Kaweah 

1 Hour/Continuous Regional Representative Conc. SPM 

Shafter-Walker Street 1 Hour/Continuous Urban Representative Conc. PAMS/SLA

Stockton-Hazelton 1 Hour/Continuous Neighborhood Representative Conc. SLAMS 

Tracy-Patterson Pass 1 Hour/Continuous Urban Representative Conc. SLAMS 

Turlock-Minaret 1 Hour/Continuous Neighborhood Representative Conc. SLAMS 

Visalia-Church Street 1 Hour/Continuous Neighborhood Representative Conc. SLAMS 

6 SPM- Special Purpose Monitoring Stations 7 NPS- National Park Service
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Conclusions drawn from this study include: 

1 Meteorology plays a major role in ozone formation in the Valley. Long, hot, 

dry summer days with morning subsidence inversions and light winds are 

ideal conditions for ozone formation. 

2 Under normal meteorological conditions, the ozone concentrations 

recorded at Fresno-Olive are representative of average population 

exposure. Under adverse conditions, the concentrations at the downwind 

edge of the city are much higher than at Fresno-Olive. A new station 

located at the downwind edge of the city was recommended. This site is 

Fresno-Drummond. 

3 The incremental increase in ozone concentration per mile downwind 

across the city on an average day is much greater than the increase per 

mile downwind from the city. A measure of this "city effect" is the amount 

of increase in the max-hour concentration downwind along the resultant 

wind direction line. Max-hour oxidant concentrations increased, on the 

average, approximately forty percent across the city from air entering the 

city to the northwest. 

4 Under the most adverse meteorological conditions, the max-hour 

concentrations at the downwind edge of the city were approximately 15 

pphm greater than at the upwind edge. 

Though these statements may not be totally accurate today because of better 

emissions control, the results of this study are included to demonstrate the 

general characteristics of ozone formation in the Fresno metropolitan area. 

2.4.2.2 San Joaquin Valley Air Quality Study 

Air pollution control officials, local elected officials, and industry representatives 

agreed in late 1986 to undertake a cooperative air quality study. The policy 

makers’ ultimate goal was to identify and adapt well-founded, cost-effective ways 

to reduce air pollution in the San Joaquin Valley. The San Joaquin Valley Air 

Quality Study was initiated to provide technical tools to enable decision makers 

to develop and evaluate control strategies. The Study’s original charter 

describes the challenges: 

• To provide an improved understanding of the conditions that lead to 

high ozone levels in the Valley. 

• To provide policy makers with the necessary tools and information 

to develop sound regional plans for equitable and effective 

emission controls to reduce ozone levels to meet state and federal 

ambient air quality standards.
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Field Measurements 

An extensive field measurement program was carried out during the summer of 

1990 with some additional fieldwork in 1991. The field program collected data on 

air pollutant concentration and weather conditions from July 1 through August 31. 

During the period continuous measurements were taken at 339 surface sites, 

which collected upper air data. 

The data from these monitors were transmitted to the Study headquarters on a 

real time basis. This allowed the Study to know immediately whether all sites 

were operational. It also provided the Study with the ability to forecast the onset 

of high ozone conditions. 

During these high ozone periods, of which there were 14 days comprising five 

episodes, additional special monitoring was conducted to enhance both the 

spatial and temporal density of measurements. This included over 1,000 hours 

of data recorded over the Valley by nine research aircraft; weather patterns aloft; 

and the collection of speciated hydrocarbon measurements. 

Several tracer studies were also conducted during the summer of 1990. In these 

studies, a tracer gas is released at a fixed location in known amounts. The 

movement of the tracer gas is then tracked to provide information on air 

movement and the rate of dilution by the air. 

Emission Inventory 

Emission data were also collected to characterize the magnitude and location of 

emissions occurring during each ozone episode day. This was particularly 

important as a number of ozone episodes occurred on weekends, a time when 

emission patterns are often significantly different than during weekdays. Studies 

were also conducted to develop estimates of emissions from natural and 

cultivated vegetation, assess motor vehicle traffic patterns, and update estimates 

from several categories of emission sources believed to be represented by 

outdated or inaccurate estimates. 

Data Analysis 

Team members assembled a comprehensive archive of the air quality and 

weather data collected during the field program for distribution to project 

scientists for analysis. The data analyses included: 1) an examination of the 

spatial and temporal distribution of ozone and ozone causing chemicals, 2) an 

assessment of the specific weather conditions associated with high ozone 

concentrations, and 3) an evaluation of air pollution concentrations aloft from the 

data collected via aircraft. These analyses provided an improved understanding 

of ozone patterns in the Valley as well as provided information crucial for 

understanding the performance of the air quality and weather models. 
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Findings 

Ozone concentrations were found to be highest in and around the major urban 

areas of Fresno and Bakersfield, and in the Stockton/Modesto area. Monitors 

detected peak ozone concentrations of 0.15 ppm at Fresno and Edison (south 

east of Bakersfield) during the August 3-6, 1990, ozone episode; these levels 

exceed the federal 1-hr ozone standards of 0.12 ppm. Much of the remainder of 

the San Joaquin Valley experienced ozone concentrations at or above the more 

restrictive California state standard, but did not exceed the federal standards. 

The general, weather conditions that led to high ozone levels in the Valley 

included large-scale high pressure systems that developed over the Western 

United States, low wind speeds and high temperatures. Theses conditions occur 

frequently in the Valley between May and September, and may persist for 

several days. The dominant wind flow pattern is from the northwest to the 

southeast along the axis of the Valley. Air leaves the southern end of Valley 

during the daytime by flowing over the Tehachapi Mountains (southeast of 

Bakersfield) into the Mojave Desert. Pollutants on the Valley floor are also 

transported up the Sierra Nevada and Coastal Mountains as heated air raises 

into the mountains during the daytime. Some pollutants may also be returned as 

cooler air sinks into the Valley during the nighttime. 

At night, a jet stream (of fast moving air) forms at an altitude of about 1,000 feet, 

with winds coming from the northwest at speeds of up to 30 mph. Because of 

nighttime stability conditions, air transported by this jet stream can’t exit the 

Valley and is partially forced back northward along the eastern edge of the 

Valley, resulting in a counterclockwise flow known as the “Fresno eddy.” The 

Fresno eddy circulates pollutants within the Valley, returning polluted air to urban 

areas where additional emissions are added to it. Air pollution trapped at higher 

elevations at night can contribute to high ozone levels on subsequent days. 

The August 3-6, 1990 ozone episode (which occurred over a weekend) is 

representative of the weather conditions associated with historical high ozone 

periods, including those observed during the 1980’s. August 3 and 4 were 

favorable for moderate ozone concentrations; August 5 and 6 were favorable for 

the occurrence of high ozone concentrations. 

2.4.2.3 Central California Ozone Study (CCOS) 

The Central California Ozone Study (CCOS) is an extensive project designed to 

improve our understanding of the transport, formation, and fate of loweratmosphere ozone throughout a large portion of central and northern California. 

The project will and has guided decision-makers in determining the amount, 

timing, and placement of emissions controls to attain ambient ozone standards. 

CCOS was planned during 1998 and 1999, and the field research began in the 

summer of 2000. CCOS was timed so that researchers could take advantage of 

staff and equipment that were already in place for the California Regional 
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Particulate Air Quality Study (CRPAQS). CCOS and CRPAQS collected 

voluminous data, and are now continuing with data analysis. 

The CCOS area of study (domain) includes most of northern California and all of 

central California. The northern boundary extends through Redding, thus 

representing the entire Central Valley of California. The eastern boundary 

extends past Barstow and includes a large part of the Mojave Desert and all of 

the southern Sierra Nevada. The southern boundary extends below Santa 

Barbara and into the South Coast Air Basin. The western boundary extends 

approximately 200 kilometers west of San Francisco (measurements were 

needed to characterize ozone levels in the air moving into California). 

The CCOS field measurement program was conducted during a four-month 

period from 6/1/2000 to 9/30/2000, a study period corresponding to the time of 

year the majority of the high ozone level episodes occurred in northern and 

central California during previous years. CCOS field staff from multiple agencies 

collected continuous surface air quality measurements and surface and upper-air 

meteorological measurements throughout the study period to provide sufficient 

data to model any day of the study period. They also collected data during 

episodes of high ozone levels to better understand the dynamics and chemistry 

of the formation of high ozone concentrations, and the contribution of transport to 

exceedances of federal and state ozone standards in downwind areas. CCOS 

field staff collected additional continuous surface air quality measurements at 

sites downwind of the San Francisco Bay Area, Sacramento, and Fresno to 

characterize ozone formation, carbon and nitrogen chemistry variations by time, 

day, and pollutant transport pattern. Additional work is ongoing to complete the 

project with analysis and modeling of the collected information, to improve the 

performance of modeling, and to guide actions to improve air quality for an 

extensive geographic region. 

A variety of organizations, including member agencies, universities, research 

institutes, and private consultants, conduct CCOS work, primarily under contracts 

administered by ARB and the San Joaquin Valleywide Air Pollution Study Agency 

(Study Agency). Funding comes from the federal budget (e.g., EPA, Department 

of Agriculture, Department of Defense), the state budget (e.g., ARB and the 

California Energy Commission), and from contributions provided by air districts 

and other organizations such as industry. CCOS has a Policy Committee to 

provide overall strategic direction and to help define the types of questions that 

need answering, and a Technical Committee to oversee the technical work and 

provide peer review. These committees are comprised of representatives from 

federal agencies, state agencies and industry. To date, funding of about $41 

million for CCOS and CRPAQS has produced voluminous atmospheric data and 

numerous peer-reviewed studies describing ozone formation in Central 

California. These studies have improved the understanding of ozone behavior, 

and have resulted in validated models that can predict the amount of ozone 

precursor reductions needed to attain the federal 1-hour ozone standards 

(including work supporting this Extreme OADP). The findings of these studies 
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will benefit the future health of millions of citizens and extensive areas of 

sensitive agricultural production and federally protected forests and parks. 

District and ARB staff examined several CCOS episodes for use in this Extreme 

OADP. As discussed in Chapter 5, modeling staff ultimately selected the CCOS 

episode from July 30 through August 2, 2000 for the plan. A typical Great Basin 

high-pressure system occurred during this episode, with a strong ridge that 

brought moderately high ozone levels to the SJVAB. The high-pressure system 

persisted for four days, before a trough off the Pacific Northwest coast moved the 

high-pressure system eastward, leaving approximately zonal flow over most of 

the SJVAB by August 3, 2000 (DRI 2003). The Bay Area and Sacramento Area 

also recorded moderately high ozone levels during this episode, with each 

experiencing 1-hour ozone levels slightly above the standard. 

Staff members from the District, ARB, other northern/central California districts, 

and consultants to the Study Agency, will continue to analyze CCOS episodes to 

improve model performance for use in future revisions to SIPs for the 1-hour 

ozone standard (as appropriate) and for use in future SIPs for the federal 8-hour 

ozone standard. 

2.4.2.4 PAMS Sampling 

The 1990 Federal Clean Air Act Amendments include a provision in Title I, 

Section 182 requiring States to begin a program of enhanced ozone monitoring. 

On March 4, 1992, EPA promulgated regulations as revisions to Title 40, Code of 

Federal Regulations, Part 58 for the establishment and operation of 

Photochemical Assessment Monitoring Stations (PAMS). EPA finalized these 

regulations on February 12, 1993. The regulations require enhanced monitoring 

of ozone, ozone precursors including oxides of nitrogen and volatile organic 

compounds, and meteorological parameters in areas designated as serious, 

severe, or extreme ozone nonattainment. 

The District's PAMS network consists of two smaller networks that are focused 

on monitoring PAMS parameters in the Bakersfield and Fresno Metropolitan 

Statistical Areas (MSAs). Each focused network consists of one Type 1 PAMS, 

one Type 2 PAMS, and one Type 3 PAMS. The Type 1 PAMS is sited to monitor 

morning upwind ozone and ozone precursor concentrations, the Type 2 PAMS is 

sited to monitor morning ozone and ozone precursor concentrations at the 

downwind edge of the central business district, and the Type 3 PAMS is sited to 

monitor peak afternoon ozone concentration downwind of the MSA. 

Currently, all six of the PAMS in the network are operational. The Fresno MSA 

Type 1 PAMS is located at Madera-Pump Yard, Type 2 is located at Clovis-Villa, 

and the Type 3 is located at Parlier. The Bakersfield MSA Type 1 is located at 

Shafter-Walker, Type 2 is located at Bakersfield-Golden State and the Type 3 

PAMS is located at Arvin. 

The District’s PAMS activities typically consist of collecting VOC and carbonyl 

(another type of chemical that reacts in the atmosphere to produce ozone) 
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samples on specified schedules. For example, the 2001 PAMS Program for 

VOC and carbonyl sampling was operated in accordance with the "California 

Alternative Sampling Schedule" (CAP III), for the July-September period. During 

these months sampling was scheduled for every 3rd day and called for the 

collection of at least four (4) three-hour integrated samples per day, plus 

additional samples surrounding suspected high ozone days (episodes). An 

episode is defined as a time frame in which a maximum hourly average ozone 

concentration exceeds the federal one-hour standard of 125 parts per billion. In 

terms of the number of episode days sampled, the Districts’ CAPIII proposal 

established a goal of capturing at least 3 episodes during the three-month 

season. 

The PAMS Site Types #1, #2, and #3 are pre-established SLAMS sites. 

Continuous monitoring for ozone, oxides of nitrogen, and surface meteorology is 

ongoing at these sites, and the data are routinely submitted to AIRS throughout 

the year. From July 1 to September 30 the District collects and ships samples 

related to VOC and carbonyl species for the PAMS season. VOC canisters and 

carbonyl cartridges are collected and sent to a contracted lab for analysis. 

2.4.3 Conclusion 

Ozone air quality in the SJVAB is extensively monitored. A permanent 

monitoring network continuously samples the air at various locations in the 

SJVAB to measure ozone levels in the atmosphere. During the ozone season, 

these data are supplemented by special ozone precursor samples collected 

during episodes of anticipated high ozone levels. In addition, federal, state and 

local governments have collaborated in the past on a number of special air 

quality studies, components of which have included measurements of ozone air 

quality and meteorological and other parameters that affect ozone formation. 

The most recent and most extensive of these special studies, the Central 

California Ozone Study, provided data that was used to develop this Extreme 

OADP (see Chapter 5). 

2.5 OTHER POLLUTANTS OF CONCERN IN THE SAN JOAQUIN 

VALLEY AIR BASIN 

2.5.1 Particulate Matter 

PM10 is composed of very small particulate matter measuring less than 10 

microns (one one-millionth of a meter) in diameter. These small particles are 

comprised of finely divided solids or liquids such as dust, soot, aerosols, fumes, 

and mists. The PM10 problem in the SJVAB is partially caused by the same 

compounds that produce ozone: VOCs and NOx. These compounds react in the 

atmosphere to form aerosols, which make up a significant fraction of PM10 in the 

SJVAB. Particulate matter is also directly emitted by society’s activities, 

including agricultural operations, industrial processes, fossil fuel combustion, 
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agricultural and prescribed fires, construction and demolition, and entrainment of 

road dust into the air. PM10 is also derived from natural sources, including 

windblown dust and wildfires. 

Community studies of air pollution effects on health have linked particulate 

matter, alone or in combination with other air pollutants, with a number of 

significant respiratory and cardiovascular-related effects. These effects include 

increased mortality and aggravation of existing respiratory and cardiovascular 

diseases as evidenced by increased hospitalization, school absences, and 

increased work loss days. Populations at general risk for suffering adverse 

health effects from exposures to particulate matter include children, asthmatics, 

the elderly, individuals with influenza, and individuals with chronic obstructive 

pulmonary cardiovascular disease. Particulate matter can also alter the body’s 

immune system and affect removal of foreign materials from the lung, and in 

children this can result in decreased lung capacity. 

The federal standards for PM10 are 50 micrograms per cubic meter for the 

annual average (primary and secondary standards) and 150 micrograms per 

cubic meter for the 24-hour average (primary and secondary standards). 

Exceedances of the 24-hour standard usually occur between October and 

February in the SJVAB. 

EPA originally classified the SJVAB as moderate non-attainment, but bumped it 

up to serious non-attainment in 1993 because the District was not able to 

demonstrate attainment by 1994 in its Moderate Area Plan. 

On August 19, 2003 California submitted a serious nonattainment area plan for 

PM10 to EPA (the 2003 PM10 Plan). After an initial review, EPA determined that 

amending the plan in a few key areas would facilitate its ultimate approval; 

consequently, the District and ARB amended the 2003 PM10 Plan. In December 

2003, the District Governing Board adopted the Amended 2003 PM10 Plan. On 

December 30, 2003, California submitted the Amended 2003 PM10 Plan to EPA. 

On January 9, 2004, EPA found the 2003 PM10 Plan Amendments to be 

complete. On May 26, 2004, EPA issued a final rule approving the plan, with an 

effective date of June 25, 2004 (69 FR 30006). All references to 2003 PM10 

Plan in this Extreme OADP refer to the amended plan approved by EPA effective 

June 25, 2004. 

Air quality data show an overall improvement for the SJVAB’s PM10 

nonattainment problem. The peak 24-hour PM10 exceedance value was 439 

μg/m3 in 1990 and 150 μg/m3

 in 2003 (150 μg/m3 is the standard). The estimated 

number of days exceeding the 24-hour PM10 standard has decreased from 56 

days in 1990 to 0 days in 2003. Lastly, the three year annual average PM10 

level at the peak station was 78 μg/m3 in 1991 but dropped to 56 μg/m3

 in 2003 

(50 μg/m3

 is the federal PM10 annual average NAAQS). The SJVAB is still 

nonattainment for PM10, but substantial progress has been made. 
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2.5.2 Carbon Monoxide 

CO is an odorless, tasteless, and colorless gaseous air pollutant. It is a directly 

emitted byproduct of incomplete fuel combustion. The largest portion of CO 

emissions comes from gasoline-fueled motor vehicles. Other contributors are 

fires (forest, residential, and agricultural), industrial processes, solid waste 

disposal, and fuel combustion at stationary sources. Most occurrences of 

unhealthful levels of CO are found in major urban areas in conjunction with high 

traffic levels and limited dispersion. 

Inhaled CO has no direct toxic effect on the human lungs; however, once it 

enters the human bloodstream through gas exchange in the lungs, it readily 

combines with hemoglobin, which is the substance that carries oxygen to cells in 

the body (the CO/hemoglobin affinity is about two hundred times stronger than 

the oxygen/hemoglobin affinity). Consequently, the hemoglobin becomes tied up 

with CO and is not available to transport oxygen to the body. Effects include 

dizziness, nausea, lack of coordination, headaches, impaired perception, and 

weakened heart functions; prolonged exposures to high levels can lead to death. 

People especially sensitive to CO include children (and the human fetus), the 

elderly, smokers, and those with respiratory/heart illnesses and anemia. 

Carbon monoxide usually does not persist in the atmosphere and is depleted and 

diluted through chemical reactions and dispersion. Exceedances of the federal 

standard are most likely to occur in the winter, due to lowered inversion levels 

(that trap this pollutant and cause elevated concentrations), increased fuel 

combustion for heating, and reduced atmospheric chemical reactivity due to low 

temperatures. Since CO is somewhat soluble in water, normal winter 

precipitation removes the pollutant from the atmosphere. Carbon monoxide also 

participates in the overall photochemical reaction mechanism leading to the 

production of ozone and smog. 

The federal standard for CO is 9 ppm for the 8-hour average and 35 ppm for the 

1-hour average (primary standard only). In the past, four urbanized areas in the 

SJVAB were designated as nonattainment for the carbon monoxide (CO) 

standards. The last of the four areas were redesignated to attainment in 1998 for 

both Federal and state standards. In June 2004, ARB published a draft CO 

Maintenance Plan for the attainment areas. 

2.5.3 Toxic Air Pollutants 

Other ozone precursors include various VOCs, some of which may also be 

considered toxic air contaminants (TAC). The FCAA required the District to reevaluate its existing TAC regulatory program alongside the technology-based 

standards for 189 hazardous air pollutants identified by the EPA. The federal 

TAC standards [Maximum Achievable Control Technology (MACT) standards] 

affect over 170 source categories nationwide, many of which are already subject 

to state regulation. The District has ensured that only appropriate source 

categories in the SJVAB are subject to federal enforcement action. 
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2.6 REFERENCES 

ALA 2002 American Lung Association. Annotated Bibliography of 

Recent Studies on the Health Effects of Air Pollution, 2001-

2002. 

ARB 2001 California Air Resources Board, Ozone Transport, California 

Environmental Protection Agency, Sacramento, California, 

April 2001. 

Burnett 2001 Burnett,R., Smith-Doiron, M., Stieb, D., Raizenne, M., 

Brooke, J.R., Dales, R., Leech, J., Cakmak, S., and 

Krewski, D., “Asociation between Ozone and Hospitalization 

for Acute Respiratory Diseases in Children Less than 2 

years of Age,” American Journal of Epidemiology, v153, 

no.5. 2001, pp. 444-452. 

CDFA 2002 California Department of Food and Agriculture, Agricultural 

Statistical Review, California Department of Food and 

Agriculture Resource Directory, 2002, pp. 31. 

CNN 2003 CNN.com. Report Child Asthma Rates Double. Accessed 

4/9/04, at the following web address: 

http://www.cnn.com/2003/HEALTH/02/24/children.pollution.a

p/index.html. Posted February 24, 2003. 

DRI 2003 Desert Research Institute. State Implementation Plan (SIP) 

Planning Service for the Sacramento Ozone Nonattainment 

Area. Task 4.1: Episode Selection for SIP Modeling. 

Prepared for the Sacramento Metropolitan Air Quality 

Management District. Sacramento, CA. April 2003. 

EPA 1997 United States Environmental Protection Agency. Health and 

Environmental Effects of Ground Level Ozone. Accessed 

4/9/04, at the following web address: 

www.epa.gov/rgytgrnj/programs/artd/air/quality/o3health.htm. 

Posted July 17, 1997. 

EPA 1999 United States Environmental Protection Agency. What You 

Need to Know About Ozone and Your Health. EPA-452/K99-001, July 1999. 
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Galizia 1999 Galizia, A. and Kinney,P.L. “Long Term Residence in Areas 

of High Ozone: Associations with Respiratory Health in a 

Nationwide Sample of Nonsmoking Young Adults,” 

Environmental Health Perspectives, v107, no.8, 1999. pp. 

675-679. 

Gent 2003 Gent, J., Triche, E., Holford, T., Belanger, K., Bracken, M., 

Beckett, W., Leaderer, B., “Association of Low-Level Ozone 

and Fine Particles with Respiratory Symptoms in Children 

with Asthma”, JAMA, v290, no.14, 2003, pp. 1859-1867. 

McConnell McConnell, R., Berhane, K., London, S., Islam, T., 

Gauderman, J., Avol, E., Margolis, H., and Peters, J., 

“Asthma in Exercising Children Exposed to Ozone: A Cohort 

Study,” The Lancet, v359, 2002, pp. 386-391. 

NHI 2003 National Institutes of Health. Health News. Accessed 4/9/04, 

< http://www.nhlbi.nih.gov/new/press/03-06-13.htm> Posted 

June 13, 2003. 

Ritz 2002 Ritz, B., Yu, F., Fruin, S, Chapa, G., Shaw, G.M. and Haris, 

J.A., “Ambient Air Pollution and Risk of Birth Defects in 

Southern California,” American Journal of Epidemiology, 

v155, no.1, 2002, pp 17-25. 

SCAQMD 2003 South Coast Air Quality Management District. Final 2003 

AQMP. Accessed 4/9/04, 

<http://www.aqmd.gov/aqmp/docs/2003AQMP_AppI.pdf>. 

Posted August 2003
 Chapter 3 - Emission Inventory
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3 EMISSIONS INVENTORY 

3.1 INTRODUCTION 

This chapter discusses the emissions inventory (EI) as related to ozone 

attainment demonstrations for the SJVAB. The two principal components of 

OADP EIs are a baseline year and future year projections. The projections 

reflect emissions reductions stemming from implementation of controls as well as 

emissions increases stemming from growth. Future year emissions are used as 

input to a grid-based photochemical computer model that simulates physical and 

chemical processes in the atmosphere and predicts future ozone levels. 

Comparison of the magnitude and frequency of the predicted future ozone levels 

with the national ambient air quality standards allows a demonstration of 

attainment from the emission controls. The baseline year and future year EIs 

were developed to reflect emissions of volatile organic compounds (VOCs) and 

nitrogen oxides (NOx) during the ozone season (May through October). Ozone 

is not emitted directly into the atmosphere, and thus it does not appear in an 

emissions inventory. Ozone is created through a photochemical reaction 

between VOCs and NOx in the presence of sunlight. NOx and VOCs, which are 

termed ozone precursors, are directly emitted and can be measured as emitted 

or estimated using parameters that can be easily measured; therefore, they are 

included in the EI. The EI identifies the sources and quantities of these 

precursors. VOC emissions from society’s activities generally result from 

evaporation of liquids, release of gaseous VOCs, and incomplete combustion. 

NOx emissions are primarily the result of high temperature combustion. 

Section 3.2 describes the types of emission inventories, Section 3.3 describes 

the baseline year inventory, and Section 3.4 describes development of the future 

year inventory. Section 3.5 discusses conformity, and Section 3.6 discusses 

emission inventory uncertainties. Conclusions are presented in Section 3.7. 

3.2 INVENTORY TYPES 

An EI is a compilation of emission sources and corresponding quantities of air 

pollutants emitted per unit time (e.g., tons/day) for a specified time period (e.g., 

1990, ozone season 2002, etc.). The two basic types of EIs are modeling and 

planning inventories; each has a different purpose in the overall air quality 

planning process, and each reflects a different compilation of emission sources. 

3.2.1 Modeling Inventory 

The modeling inventory typically represents emissions that occurred on specific 

days when ambient ozone levels exceeded the NAAQS at locations within the 

SJVAB. Modeling inventories are used to help understand the conditions that 

create the high ozone levels and to evaluate emission control measures needed 
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to attain the ozone NAAQS. Modeling EIs therefore include all sources of VOCs 

and NOx that could be contributing to the problem: anthropogenic (caused by 

human activity), biogenic (e.g., caused by plants, molds, and animals) and 

geogenic (e.g., caused by earth processes such as oil seeps). Biogenic and 

geogenic sources can emit significant quantities of pollutants. Modeling 

inventories, meteorological conditions, and emission control effectiveness are all 

used as input to photochemical models to demonstrate that implementation of 

specified emission control programs will result in attainment of the ozone 

NAAQS. Also, the spatial coverage of modeling inventories extends beyond the 

SJVAB boundaries to capture transport and other processes affecting high ozone 

levels on specific days. 

EIs used in the District’s attainment demonstration plans are based on data 

contained in the ARB’s California Emission Inventory Development and 

Reporting Air System (CEIDARS), the California Emission Forecasting System 

(CEFS), and the Central California Ozone Study (CCOS). The emissions 

inventory used for model calibration is “day specific.” It represents the emissions 

that occurred when the federal standard for ozone was exceeded in the SJVAB. 

The use of day specific emissions allows model results to be compared to and 

calibrated with measured ozone levels. 

Modeling inventories encompass an area larger than the SJVAB. The modeling 

domain is divided into a grid system composed of 4 Km by 4 Km grid cells 

defined by Universal Transverse Mercator (UTM) coordinates (see Chapter 5). 

Modelers allocate stationary and mobile source emissions to individual grid cells 

within this system. They locate area source emissions using readily measured 

parameters whose behavior would correlate with emissions (e.g., population 

density). In general, the modeling emission data features episodic-day emissions 

for the base year. Seasonal variations in activity levels are taken into account in 

developing gridded stationary point and area source emissions. Variations in 

temperature, hours of operation, speed of motor vehicles, or other factors are 

considered in developing gridded motor vehicle emissions. Finally emissions 

used for modeling are assigned to chemical classes depending on their reactivity 

in producing ozone in the atmosphere. Hence, “gridded” emissions data used for 

ozone modeling applications differ from the average annual day or planning 

inventory emission data in two respects: 1) the modeling region covers larger 

geographic areas than the SJVAB; and 2) emissions represent day-specific 

estimates instead of average or seasonal conditions for the base year. 

For seasonal sources, emissions were determined by calculating the number of 

operating days in 1999 during the ozone season and dividing the total emissions 

for the season by the number of days that the activity occurred during the 

season. For non-seasonal point sources, emissions for an average operating 

day were calculated by dividing the facility’s total emissions for 1999 by the 

number of operating days throughout 1999 that the facility operated. 
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Unlike area and point sources, the motor vehicle emissions inventory was 

temperature adjusted to represent a typical “summertime” day. Emissions 

factors for motor vehicles reflect temperature and activity data (vehicle miles 

traveled, speed, etc.) for six daily time periods. The emissions accounted for in 

the District’s planning inventories are based on the California mobile emission 

model EMFAC2002. 

3.2.2 Planning Inventory 

The planning inventory represents a “typical” summer day during the seasonal 

time period in which ambient air quality standards are violated. For example, the 

ozone planning inventory is based on daily emissions that occurred during the 

ozone season, May through October. Although the modeling and planning 

inventories are based on the same data, the planning inventory is better suited 

for summary representation of emissions and for fulfilling regulatory 

requirements. The planning inventory is geared towards complying with 

emission reduction requirements and the role of control measures in meeting 

those requirements; it therefore includes only anthropogenic emission sources 

and does not include biogenic or geogenic emissions. The planning inventory 

also only includes sources within the SJVAB boundaries. 

3.2.3 Data Sources and Accuracy 

The bulk of the SJVAB EI is actually estimated rather than directly measured. 

Multiplying an emission factor by an activity level produces an estimated 

emission; if the source has a pollutant control device or technique applied, 

emission estimates are reduced to reflect the efficiency of the pollution control. 

Emission factors relate air pollutant emission rates (usually mass per unit time) to 

an easy-to-measure activity level for various types of sources (typically the 

factors are available for major air pollutant sources found in many regions and 

states). For example, emission factors for engine operation may use horsepower 

or gallons of fuel consumed to determine emissions. The emission estimates for 

most point sources (specific facilities) are more reliable than the estimates for 

generic classes of sources because emissions from point sources are usually 

tested, and the test results are used to generate the emission factors. 

Furthermore, facility operators can inform the District of their actual production 

figures or fuel burned, thereby eliminating the need for the District to estimate 

this type of data. In addition, some major sources are equipped with automated 

emissions monitoring equipment that directly measures emissions to the 

atmosphere and eliminates the needs for estimations. 

Estimating area source emissions is more difficult. Point source estimating 

techniques are often used, but with less reliability. For example, determining the 

amounts of specific consumer products used within the SJVAB entails making 

estimates and assumptions and consulting a variety of data sources that might 

describe an easily-measured parameter (such as regional sales for a class of 
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product) but do not provide needed information such as location and quantity of 

use of individual products. Consequently, the resultant quality of the data is not 

as good as data from point sources and point source tests. Area source 

emissions estimates often are based on total activity during a season and do not 

provide much information about typical use, daily activity, or exact location of the 

source. 

Because of the variety of data used to compile EIs and the calculations 

performed on these data, emissions estimates vary in their accuracy. For 

example, emissions directly measured by a continuous emissions monitor are 

generally more accurate than emissions estimated from activity levels, emission 

factors and control efficiencies. Emissions data in this OADP are reported to the 

nearest 0.1 tons (200 lbs)/day (with one or two exceptions), even though this 

level of accuracy may not be representative of all of the inventory source types. 

3.2.4 Emission Source Types 

3.2.4.1 Stationary Sources 

Theoretically, stationary sources are divided into two major subcategories: point 

and area sources. However, for EI purposes, only point sources are categorized 

as stationary sources. Point sources are generally large emitters with one or 

more emissions points at a permitted facility with an identified location. 

Examples include food processing facilities, oil production and refinery facilities, 

steam generators, boilers, process heaters, stationary piston engines, glass 

manufacturing, and mining operations. The emissions from point sources are 

generally calculated using emission factors obtained from direct measurements 

(e.g., source testing), EPA’s document entitled, Compilation of Air Pollutant 

Emissions Factors (AP-42), or ARB’s material balance formula. The simplest 

method of calculating emissions is to multiply the process rate (how much or how 

often an activity occurs) by an emissions factor (mass of air pollutant emitted per 

unit time of activity) and a control factor (percent of emissions not allowed to 

reach the atmosphere). For most point sources, facility operators provide the 

process rates (activity levels) that are necessary for emission calculations. Some 

point sources are equipped with continuous emissions monitoring equipment that 

provides direct measurement of selected pollutants as they are emitted from a 

stack to the atmosphere. For these sources, emissions are directly measured 

and need not be estimated using emission factors and activity levels. 

3.2.4.2 Area Sources 

ARB and the District jointly develop the area source emission inventories, with 

the ARB responsible for about two-thirds of the sources and the District for the 

remaining one-third. Area source categories are divided into two types: 

aggregated point and area-wide. Aggregated point sources are many small point 

sources, or facilities, that are not inventoried individually, but are estimated as a 

group and reported as a single source category. Examples of aggregated point 
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sources include residential water heaters, dry cleaning operations, and 

automobile service stations. Area-wide sources include many dispersed sources 

that emit pollutants over a broad geographic area and are not reported in the 

stationary source inventory. Examples of area-wide sources include consumer 

products (e.g., nail polish, hair spray, aftershave, household cleaners, paints, 

windshield washer fluid); home-use pesticides; asphalt paving; pavementmarking paints; off-gassing of manufactured products; residential fuel 

combustion; farming operations; construction and demolition; road dust; fires; 

waste burning; and utility equipment. 

3.2.4.3 Mobile Sources 

ARB develops on-road and non-road mobile source emissions estimates, and 

maintains a comprehensive compilation of emission factors. These factors are 

combined with appropriate activity levels and estimates of control measure 

effectiveness to calculate the emissions (the computer tool used to calculate 

mobile emissions is referred to as “EMFAC”, although the term “EMFAC” is often 

used to also describe the final calculated emission estimates). As ARB releases 

new versions of EMFAC, they are named with the year of release and usually 

version number within a given year (e.g., EMFAC2002, v. 2.2). 

The mobile source category “on-road motor vehicles” includes light duty 

passenger vehicles, light- and medium-duty trucks, heavy-duty trucks (gas and 

diesel), heavy-duty urban buses (diesel) and motorcycles. Motor vehicle 

emissions occur both through the exhaust pipe and from fuel evaporation. ARB 

uses a complex methodology to calculate the number of motor vehicles, their age 

and speed distribution, and the resulting emissions of NOx, total organic gases 

(TOG), reactive organic gases (ROG), carbon monoxide (CO), sulfur oxides 

(SOx), and particulate matter (PM10). ARB uses EMFAC to develop on-road 

motor vehicle emission estimates using estimated vehicle miles traveled. 

Non-road mobile sources include off-road vehicles such as construction 

equipment, farm tractors, trains, ships, aircraft (both government, commercial, 

and private), mobile equipment (forklifts, etc.), and utility equipment (lawn and 

garden equipment and chain saws). 

3.2.4.4 Natural Sources 

In addition to man-made air pollution, there are natural sources of emissions, 

also known as biogenic sources (i.e., plants, molds, and animals,) and geogenic 

sources (such as oil seeps and other earth processes). These natural sources 

emit significant quantities of pollutants. For example, certain types of vegetation 

emit large amounts of isoprene, terpenes, and other organic compounds that are 

VOC. Emission rates depend upon plant species, season, biomass density, time 

of day, local temperature, moisture, and other factors. 
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The SJVAB biogenic VOC emissions inventory, currently estimated at 380 tons 

per day, has been the subject of recent research and refinements. Seasonal or 

annual estimates have not been prepared using this updated methodology, but it 

provides a sense of the magnitude of biogenic emissions during the summer. 

3.3 BASELINE YEAR EMISSIONS 

The District and ARB developed a well-characterized emissions inventory for 

1999 and projected it to years of interest given information on growth trends and 

control measures that occurred in specific source categories over the time 

periods of interest. SJVAB emissions for 2000 establish a baseline for evaluating 

trends out to selected future years (Table 3-1).1

 Carbon monoxide (CO) is 

included in Table 3-1 because CO can help produce ozone (though it is not 

typically described as an ozone precursor). The CO emissions in Table 3-1 do 

not set an emissions budget for conformity (the SJVAB is no longer 

nonattainment for CO). 

Planners calculate the seasonal point source emissions in the EI by applying the 

fractional monthly throughputs during the ozone season and then dividing the 

total emissions by the number of days that the activity occurred during the 

season. Planners calculate non-seasonal point source emissions (average 

operating day) by dividing the facility’s total emissions for a given year by the 

number of days per year of interest that the facility operated. 

Unlike area and point sources, the motor vehicle emissions inventory was 

temperature adjusted to represent a typical “summertime” day. Emission factors 

for motor vehicles reflect temperature and activity data (vehicle miles traveled, 

speed, etc.) for six daily time periods. EMFAC2002, Version 2.2 was used in this 

document to compute on-road motor vehicle emissions in the planning 

inventories. Table 3-1 includes the EMFAC2002, Version 2.2 results. 

Table 3-1 presents the planning EI for 2000 as well as for 2008 and 2010 (2008 

is a Rate of Progress milestone year and 2010 is the target attainment year; note 

that ROP uses 1990 as a baseline—see Chapter 7). Summer 2000 emissions 

represent the overall magnitude of emissions that led to the ozone levels 

occurring during the CCOS episode (see Section 2.4.2.3) used in this Extreme 

OADP.

2

 Appendix A presents the county-by-county 2008 and 2010 planning onroad motor vehicle emissions inventories, of which VOC and NOx emissions form 

the basis of conformity budgets developed later in this chapter. 

 

1

 Note that different baselines are used in this plan for different purposes. Chapter 7 uses 1990 

as a baseline for Rate of Progress calculations as required by the Federal Clean Air Act. Chapter 

5 uses day-specific emissions from the July/August 2000 CCOS episode as a base case to 

establish model performance. 

2

 As discussed in Section 3.2.1, the modeling inventory gives day-specific emissions by grid cell 

in the SJVAB and by reactivity class for VOC; because of its complexity and volume, it is not 

suitable for reproduction or inclusion in this Extreme OADP in either tabular or text form. 
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Table 3-1 

SJVAB 2000, 2008 and 2010 Planning Emissions Inventories

(Summer, tons/day, 1999 Base Year) 

Source Categories 20001

VOC 

2008 

VOC 

2010 

VOC 

20001

CO 

2008 

CO 

2010 

CO 

20001

NOx 

2008 

NOx 

2010 

NOx 

STATIONARY SOURCES: FUEL COMBUSTION 

Electric Utilities 0.4 0.5 0.5 2.4 2.7 2.8 3.1 3.0 3.1 

Cogeneration 0.8 0.9 1.0 7.0 9.3 9.6 9.0 6.1 6.3 

Oil and Gas 

Production 

(Combustion) 

2.7 3.2 3.2 14.4 15.9 15.7 39.6 25.9 25.4 

Petroleum Refining 

(Combustion) 0.1 0.1 0.1 0.4 0.4 0.4 1.5 1.5 1.5 

Manufacturing and 

Industrial 0.3 0.4 0.4 5.7 6.7 6.8 36.5 38.7 39.7 

Food and 

Agricultural 

Processing 

2.7 2.6 2.6 11.1 10.9 10.9 26.9 24.5 23.6 

Service and 

Commercial 1.2 1.3 1.3 3.3 3.4 3.5 13.7 14.2 14.4 

Other (Fuel 

Combustion) 0.2 0.1 1.1 0.7 0.5 0.4 1.8 1.4 1.2 

TOTAL FUEL 

COMBUSTION 8.4 9.1 10.2 45.0 49.8 50.1 132.1 115.3 115.3 

STATIONARY SOURCES: WASTE DISPOSAL 

Sewage Treatment 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Landfills 2.8 3.3 3.4 0.0 0.0 0.0 0.0 0.0 0.0 

Incinerators 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.1 0.1 

Soil Remediation 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Other 0.5 0.6 0.6 0.0 0.0 0.0 0.0 0.0 0.0 

TOTAL WASTE 

DISPOSAL 3.3 3.9 4.0 0.0 0.1 0.1 0.1 0.1 0.1 

STATIONARY SOURCES: CLEANING AND SURFACE COATING 

Laundering 0.1 0.1 0.1 0.0 0.0 0.0 0.0 0.0 0.0 

Degreasing 11.1 1.5 1.5 0.0 0.0 0.0 0.0 0.0 0.0 

Coatings & Related 

Process Solvents 13.8 16.5 17.5 0.0 0.0 0.0 0.0 0.0 0.0 

Printing 1.5 1.6 1.7 0.0 0.0 0.0 0.0 0.0 0.0 

Adhesives and 

Sealants 0.7 0.6 0.6 0.0 0.0 0.0 0.0 0.0 0.0 

Other 2.8 3.8 4.0 0.0 0.0 0.0 0.0 0.0 0.0 

TOTAL CLEANING 

AND SURFACE 

COATINGS 

29.9 24.1 25.4 0.0 0.0 0.0 0.0 0.0 0.0 

 
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Table 3-1: SJVAB 2000, 2008 and 2010 Planning Emissions Inventories- 

(cont.)

Source Categories 20001

VOC 

2008 

VOC 

2010 

VOC 

20001

CO 

2008 

CO 

2010 

CO 

20001

NOx 

2008 

NOx 

2010 

NOx 

STATIONARY SOURCES: PETROLEUM PRODUCTION AND MARKETING 

Oil & Gas 

Production 31.6 32.1 31.4 0.1 0.1 0.12 0.2 0.2 0.2 

Petroleum Refining 1.4 1.4 1.4 0.2 0.2 0.2 0.1 0.1 0.1 

Petroleum 

Marketing 6.6 7.1 7.3 0.0 0.1 0.1 0.0 0.0 0.0 

Other (Petroleum 

Production and 

Marketing) 

0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

TOTAL 

PETROLEUM 

PROD./MKTG. 

39.6 40.6 40.1 0.4 0.4 0.4 0.3 0.3 0.3 

STATIONARY SOURCES: INDUSTRIAL PROCESSES 

Chemical 1.9 2.4 2.5 0.0 0.0 0.0 0.1 0.1 0.2 

Food/Agricultural 10.7 11.5 11.8 2.2 2.1 2.1 9.2 9.0 9.0 

Mineral Processes 0.3 0.4 0.4 0.4 0.4 0.4 1.5 1.7 1.7 

Metal Processes 0.2 0.2 0.2 0.1 0.1 0.1 0.0 0.0 0.0 

Wood and Paper 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Glass and Related 

Products 0.1 0.1 0.1 0.3 0.3 0.3 12.0 9.6 10.1 

Electronics 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Other (Industrial 

Processes) 0.1 0.1 0.2 0.0 0.0 0.0 0.0 0.0 0.0 

TOTALINDUSTRIAL 

PROCESSES 

13.3 14.6 15.1 2.9 2.9 3.0 22.9 20.5 21.0 

TOTAL 

STATIONARY 

SOURCES 

94.3 92.3 94.6 48.1 53.1 53.5 155.2 136.2 136.6 
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Table 3-1: SJVAB 2000, 2008 and 2010 Planning Emissions Inventories- 

(cont.)

Source Categories 20001

VOC 

2008 

VOC 

2010 

VOC 

20001

CO 

2008 

CO 

2010 

CO 

20001

NOx 

2008 

NOx 

2010 

NOx 

AREA SOURCES: SOLVENT EVAPORATION 

Consumer Products 25.2 25.7 26.7 0.0 0.0 0.0 0.0 0.0 0.0 

Architectural 

Coatings and 

Related Process 

Solvents 

14.1 12.9 13.1 0.0 0.0 0.0 0.0 0.0 0.0 

Pesticides/Fertilizers 27.8 24.0 23.4 0.0 0.0 0.0 0.0 0.0 0.0 

Asphalt 

Paving/Roofing 2.8 3.0 3.0 0.0 0.0 0.0 0.0 0.0 0.0 

TOTAL SOLVENT 

EVAPORATION 70.0 65.6 66.3 0.0 0.0 0.0 0.0 0.0 0.0 

AREA SOURCES: MISCELLANEOUS PROCESSES 

Residential Fuel 

Combustion 0.5 0.5 0.5 5.4 5.6 5.6 3.3 3.0 3.0 

Farming Operations 59.8 68.8 71.0 0.0 0.0 0.0 0.0 0.0 0.0 

Construction and 

Demolition 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Paved Road Dust 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Unpaved Road Dust 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Fugitive Windblown 

Dust 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Fires 0.1 0.1 0.1 1.2 1.3 1.3 0.0 0.0 0.0 

Waste Burning and 

Disposal 33.8 32.8 32.6 423.1 414.1 412.2 2.9 2.9 2.8 

Cooking 0.4 0.5 0.50 0.0 0.0 0.0 0.0 0.0 0.0 

Other (Misc.) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

TOTAL 

MISCELLANEOUS 

PROCESSES 

94.6 102.7 104.7 429.6 420.9 419.1 6.2 5.9 5.8 

TOTAL AREA 

SOURCES 164.6 168.3 171.1 429.6 420.9 419.1 6.3 5.9 5.9 
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Table 3-1: SJVAB 2000, 2008 and 2010 Planning Emissions Inventories- 

(cont.)

Source Categories 20001

VOC 

2008 

VOC 

2010 

VOC 

20001

CO 

2008 

CO 

2010 

CO 

20001

NOx 

2008 

NOx 

2010 

NOx 

MOBILE SOURCES: ON-ROAD MOTOR VEHICLES 4

Light Duty 

Passenger (LDA) 47.2 23.0 19.2 459.1 240.3 202.5 40.6 19.4 16.1 

Light Duty Trucks-1 

(LDT1) 23.7 14.5 12.5 291.0 163.7 138.6 24.9 13.1 11.0 

Light Duly trucks-2 

(LDT2) 15.7 10.4 9.4 195.5 117.4 103.5 21.4 12.6 11.0 

Medium Duty Trucks 6.8 4.5 4.1 82.8 51.0 45.7 10.3 6.4 5.6 

Light Heavy Duty 

Gas Trucks-1 

(LHDV1) 

4.7 1.5 1.4 34.1 8.4 7.0 2.3 2.3 2.4 

Light Heavy Duty 

Gas Trucks-2 

(LHDV2) 

0.6 0.5 0.5 5.4 2.9 2.5 0.7 0.7 0.7 

Medium Heavy Duty 

Gas Trucks (MHDV) 4.4 2.7 2.4 39.2 19.9 16.7 2.7 2.1 1.9 

Heavy Heavy Duty 

Gas Trucks (HHDV) 2.4 1.6 1.4 42.6 21.1 17.8 4.4 2.8 2.4 

Light Heavy Duty 

Diesel Trucks-1 

(LHDV1) 

0.1 0.2 0.2 0.3 0.7 0.7 2.0 2.4 2.1 

Light Heavy Duty 

Diesel Trucks-2 

(LHDV2) 

0.2 0.2 0.2 0.4 0.5 0.5 2.2 1.8 1.6 

Medium Heavy Duty 

Diesel Trucks 

(MHDV) 

0.6 0.6 0.6 3.8 4.1 4.0 18.0 15.9 14.1 

Heavy Heavy Duty 

Diesel Trucks 

(MHDV) 

4.2 3.7 3.4 18.4 15.3 14.2 85.4 69.6 60.9 

Motorcycles 2.3 2.0 1.9 16.0 18.3 16.4 0.4 0.5 0.5 

Heavy Duty Urban 

Diesel Buses (UB) 0.2 0.2 0.2 0.7 0.7 0.7 3.6 3.5 3.5 

Heavy Duty Gas 

Urban Buses (UB) 1.0 1.1 1.1 11.5 9.9 9.6 0.9 1.0 1.0 

School Buses 0.3 0.3 0.3 4.9 3.3 3.2 2.1 2.6 2.6 

Motor Homes 0.9 0.8 0.7 25.1 18.3 15.7 1.9 1.8 1.7 

TOTAL ON-ROAD 

MOTOR VEHICLES 115.3 67.8 59.5 1230.8 695.8 599.3 223.8 158.5 139.1 
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Table 3-1: SJVAB 2000, 2008 and 2010 Planning Emissions Inventories- 

(cont.)

Source Categories 20001

VOC 

2008 

VOC 

2010 

VOC 

20001

CO 

2008 

CO 

2010 

CO 

20001

NOx 

2008 

NOx 

2010 

NOx 

OTHER MOBILE SOURCES 

Aircraft 6.9 7.2 7.3 63.6 71.4 72.7 2.3 2.4 4.03

Trains 1.2 1.2 1.1 4.3 4.8 5.0 32.6 21.3 20.8 

Ships and 

Commercial Boats 0.1 0.1 0.1 0.2 0.2 0.2 0.3 0.3 0.3 

Recreational Boats 18.6 12.5 10.4 108.5 98.5 98.0 3.7 5.3 5.3 

Off-Road 

Recreational Vehicle 1.8 1.1 1.1 15.9 16.4 16.9 0.3 0.3 0.3 

Off-Road Equipment 20.2 12.8 11.7 6 165.9 132.2 127.5 51.5 39.6 34.9 6

Farm Equipment 12.4 9.2 8.3 72.6 61.5 60.0 80.9 59.1 54.5 

Fuel Store/Handle 8.0 2.4 2.4 0.0 0.0 0.0 0.0 0.0 0.0 

TOTAL OTHER 

MOBILE SOURCES 69.2 46.5 42.4 430.9 385.0 380.2 171.5 128.4 120.13

TOTAL MOBILE 

SOURCES 184.5 114.3 101.9 1661.7 1080.8 879.5 395.3 287.0 259.23

TOTAL 

SAN JOAQUIN 

VALLEY 

443.5 374.9 367.6 2139.4 1554.8 1352.1 556.8 429.1 401.7 

1 Emissions data for all source categories came from the ARB emissions inventory spreadsheet 

prepared by the California Air Resources Board for the San Joaquin Valley, v2.11_RF932PEI as 

accessed from the Central California Ozone Study website in January 2004. This inventory 

reflects control measures in place as of September 2002. Adjustments as noted below. 

2 An entry of “0.0” means that emissions data are available but are equal to or less than 0.04 

tons/day, and thus have been rounded to 0.0 in accordance with the rounding protocol described 

in Appendix A. Totals of columns may not match sum of entries due to rounding. 

3

 Includes line item increase of 1.5 tpd for increased aircraft operations at Lemoore Naval Air 

Station (2010 NOx only). 

4 For the purposes of consistency, the on-road motor vehicle emissions inventory from the 

January 2004 CCOS inventory was replaced with the actual emissions data used in deriving the 

2008 and 2010 conformity budgets presented later in this Chapter (Table 3-4). 

5

 VOC and NOx emissions in 2010 were increased by 1.0 tpd VOC and 0.1 tpd NOx to account 

for ARB lawn and garden equipment control measures whose emissions reductions were 

inadvertently reflected in the planning inventory before ARB adopted the Statewide Strategy. 6

 VOC and NOx emissions in 2010 were increased by 0.04 tpd VOC and 0.1 tpd NOx to account 

for an adopted ARB control measure for stationary internal combustion engines whose emission 

reductions were inadvertently reflected in the planning inventory prior to adoption of the measure. 
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SJVUAPCD Chapter 3 - Emission Inventory 

3-12 

3.4 FUTURE INVENTORIES

Demonstrating attainment of ambient air quality standards at a future date 

requires development of future year inventories that are based on assumptions of 

current levels of controls on sources, growth in activity in the District, use of 

emission reduction credits (ERCs), and implementation of future programs that 

affect emissions of air pollutants. These factors are discussed in the following 

subsections. Table 3-1 summarizes the 2008 and 2010 emission inventories. 

3.4.1 Growth Factors 

Changes in the baseline emissions inventory over time result from emissions 

growth (or decline) and/or emissions control. Predicting future ozone precursor 

emission rates is traditionally accomplished by assuming that VOC and NOx 

emissions are directly related to social and economic activities and control levels. 

If social and economic activity levels increase, it is generally assumed that 

emissions will similarly increase. Indicators representing social and economic 

activity levels include population, housing, employment, barrels of oil produced, 

cubic feet of natural gas produced, and vehicle miles traveled. These indicators 

are referred to as “surrogates.” The ratio of the projected surrogate each year to 

the actual 1999 level of activity for each surrogate is referred to as its growth 

factor. Growth factors are multiplied by 1999 emissions to project future year 

emissions. A growth factor of less than one indicates a decline in an activity over 

the planning period, while a growth factor of more than one indicates an increase 

in activity. 

ARB and the District compiled growth factor estimates for the years 2008 and 

2010 for each of the eight counties within the District using the best data 

available. Although using growth factors is a standard method for projecting 

emissions, their use cannot account for all activities that might occur in an area 

during a given time frame. Moreover, they tend to be more accurate when 

applied to the Valley as a whole, rather than on a county-by-county basis. For 

example, one facility might gain in market share while another loses its market 

share even though production increases at both facilities. While the overall 

growth factor is correct, each facility had very different growth rates. 

On-road mobile source emissions growth is estimated for each class of vehicle 

by ARB based on estimates of vehicle miles traveled provided by Regional 

Transportation Planning Agencies (RTPAs) located within the District, and 

Caltrans. ARB then disaggregates this information by vehicle class and 

estimates on-road mobile source emissions using the most current version of 

EMFAC. Also, enhanced inspection and maintenance programs for motor 

vehicles are factored into the mobile source projections. These data collectively 

represent the best available estimates on a county-by-county basis of future 

activity level for stationary and mobile sources within the District. 
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3.4.2 Control Factors 

After the baseline EI is multiplied by a growth factor, it is then multiplied by a 

control factor. A control factor is a weighted average that represents the level of 

controls of one or more rules and regulations and/or programs for a group of 

sources. This control factor takes into account information other than control 

levels stated in a rule or program. Rule penetration, compliance rates, public 

awareness, and participation are considered in determining a control factor. 

Control factors need to be updated on a continuing basis as the production 

levels, industry types and size, programs, public awareness, and other conditions 

change over time. The District and ARB compiled control factor estimates using 

the best data available for each of the eight counties in the SJVAB, based on rule 

adoption schedules and program changes stated in this and other plans. 

3.4.3 Inclusion of Emission Reduction Credits (ERCS) 

3.4.3.1 Introduction 

The District requires all new and modified stationary sources that increase 

emissions in amounts in excess of emission offset thresholds to obtain emission 

reduction credits (ERCs) to offset the growth in emissions. District Rule 2201 

(New and Modified Stationary Source Review Rule) contains the offset 

requirement. Offsets represent either on-site reductions or the use of banked 

ERCs. The District expects that some pre-baseline (pre-2000 for this Extreme 

OADP) credits will be used to allow growth from permitted stationary sources. 

Appendix B presents the current list of ERCs for the SJVAB for NOx and VOC. 

The General Preamble to the Federal Clean Air Act (57 FR 13498) states that 

“the pre-baseline ERCs must be reflected as growth and included in the 

attainment demonstration “to the extent that the State expects that such credits 

will be used as offsets or netting prior to attainment of the ambient standards.” 

The August 26, 1994 memorandum from John Seitz, EPA’s Director of Office of 

Air Quality Planning and Standards, to David Howekamp of EPA Region IX 

provides two ways for inclusion of these ERCs as growth by stating that “A state 

may choose to show that the magnitude of the pre-1990 ERCs (in absolute 

tonnage) was included in the growth factor, or the state may choose to show that 

it was not included in the growth factor, but in addition to anticipated general 

growth.” 

By including the pre-baseline ERCs in the growth factor, the District has selected 

the first methodology provided in Seitz’s memorandum. However, in either case, 

the purpose is to show that 

baseline inventory + growth + ERCs (pre-baseline) - offsets - reductions 

will result in a projected inventory adequate to attain the federal 1-hour ozone 

standard and any applicable rate of progress, where 

growth = non-permitted growth + permitted growth 

offsets = ERCs (post-baseline) + ERCs (pre-baseline) 

reductions = reductions required by the measures in the Plan 
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3-14 

3.4.3.2 Growth Estimate 

The District used reports from the California Emission Forecasting System 

(CEFS) to generate emissions trends and growth estimates in this Extreme 

OADP. The California Air Pollution Control and Air Quality Management Districts 

and the California Air Resources Board (ARB) jointly developed the SIP/CCOS 

emissions inventory and associated emissions projections. Staff used the 

CEFS’s computer tools to develop projections and the emission estimates based 

on the most currently available growth and control data available at the time of 

the forecast runs. The CEFS was developed in the 1990s to assist in the 

development of air quality plans, determining how and where air pollution can be 

reduced, tracking progress towards meeting plans goals and mandates, and in 

constructing emission trends. 

A key component of CEFS is the growth data. In preparation for CCOS, the 

growth factors were enhanced in 2001. The February 26, 2001 report titled

“Development of Emissions Growth Surrogates and Activity Projections Used in 

Forecasting Point and Area Source Emissions” describes efforts undertaken to 

identify the most appropriate growth surrogates for stationary and area sources. 

The growth estimates generated by CEFS include growth in emissions requiring 

offsets under New Source Review Rule as well those that can be accommodated 

without triggering offsets. Tables 3-2 and 3-3 show total growth rates of 15 

tons/day of NOx, and 9.8 tons/day of VOCs. These tables also show the 

expected reductions for each pollutant from the measures contained or relied on 

in this Plan. As shown in Tables 3-2 and 3-3, the projected inventory for 2010 

incorporates the projected growth as well as the expected controls from the 

measures contained in the Plan. Notwithstanding slight rounding errors, the 

projected 2010 inventory equals the baseline inventory plus the projected growth 

minus the expected reductions from the controls contained in the Plan. 

3.4.3.3 Pre-Baseline Offset Use 

Under District’s New Source Review Rule 2201, new sources with emissions 

exceeding the following level must offset their emissions: 

 NOx ................................... 20,000 lbs/year 

 VOC.................................... 20,000 lbs/year 

 PM10.................................. 29,200 lbs/year 

 SOx.................................... 54,750 lbs/year 

 CO (attainment area) ............. 200,000 lbs/year 

 CO (non-attainment area) ....... 30,000 lbs/year 

Additionally, for existing facilities with emissions meeting or exceeding the above 

levels, any increase in emissions must be offset. The amount of offsets required 

was estimated by establishing the percentage of permitting actions for each 

source category that would be subject to offset requirements under Rule 2201. 
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3-15 

Table 3-2 

Estimated NOx Growth, Control, and Estimated Offset Use for Stationary Sourc

SUMMARY 

CATEGORY NAME 

2000 

Emissions 

Tons/day 

Growth Factor (%) Estimated 

Growth 

(tons/day) 

Control 

Factor (%) 

Required 

Reductions 

(tons/day) 

2010 

Emissions 

Tons/day 

R

STATIONARY SOURCES 

FUEL COMBUSTION 

ELECTRIC UTILITIES 3.1 15.3% 0.5 11.2% 0.4 3.1 

COGENERATION 9.0 38.5% 3.5 46.8% 5.8 6.3 

OIL AND GAS 

PRODUCTION 

(COMBUSTION) 

39.6 2.3% 0.9 39.4% 16.0 25.4 

PETROLEUM 

REFINING 

(COMBUSTION) 

1.5 0.1% 0.0 2.8% 0.04 1.5 

MANUFACTURING 

AND INDUSTRIAL 36.5 19.0% 7.0 9.5% 4.1 39.7 

FOOD AND 

AGRICULTURAL 

PROCESSING 

26.9 -2.5% -0.7 10.1% 2.6 23.6 

SERVICE AND COMMERCIAL 13.7 11.7% 1.6 5.9% 0.9 14.4 

OTHER (FUEL 

COMBUSTION) 0.0 0.0% 0.0 0.0% 0.0 0.0 

TOTAL FUEL COMBUSTION 130.2 114.0 
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SJVUAPCD Chapter 3 - E

3-16 

Table 3-2 

Estimated NOx Growth, Control, and Estimated Offset Use for Stationary Sources1 

SUMMARY 

CATEGORY NAME 

2000 

Emissions 

Tons/day 

Growth Factor (%) Estimated 

Growth 

(tons/day) 

Control 

Factor (%) 

Required 

Reductions 

(tons/day) 

2010 

Emissions 

Tons/day 

R

WASTE DISPOSAL 

SEWAGE TRTMNT 0.0 0.0 0.0 0.0 0.0 

LANDFILLS 0.0 0.0 0.0 0.0 0.0 

INCINERATORS 0.1 13.9% 0.0 0.2% 0.0 0.1 

SOIL REMEDTN 0.0 0.0 0.0 0.0 0.0 

OTHER 0.0 0.0 0.0 0.0 0.0 

* TOTAL WASTE DISP 0.1 0.2% 0.0 0.1 

CLEANING AND SURFACE COATINGS 

LAUNDERING 0.0 0.0 0.0 0.0 0 

DEGREASING 0.0 0.0 0.0 0.0 0 

COATINGS & REL. 

PROCESS SOLV 0.0 0.0 0.0 0.0 0 

PRINTING 0.0 0.0 0.0 0.0 0 

ADHESIVES & 

SEALANTS 0.0 0.0 0.0 0.0 0 

OTHER (CLEANING & 

SFC COATINGS) 0.0 109.1% 0.0 0.0% 0.0 0.0 

* TOTAL CLN/SFC 0.0 0.0 

PETROLEUM PRODUCTION AND MARKETING

OIL/GAS PROD. 0.2 40.4% 0.1 0.1% 0.0 0.2 

PET. REFINING 0.1 0.0% 0.0 0.0% 0.0 0.1 

PET. MARKETING 0.0 39.7% 0.0 0.6% 0.0 0.0 

* TOTAL PETROLEUM 

PROD.& MARKETING 0.3 0.4 
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3-17 

Table 3-2 

Estimated NOx Growth, Control, and Estimated Offset Use for Stationary Sources1 

SUMMARY 

CATEGORY NAME 

2000 

Emissions 

Tons/day Growth Factor (%) 

Estimated 

Growth 

(tons/day) 

Control 

Factor (%) 

Required 

Reductions 

(tons/day) 

2010 

Emissions 

Tons/day 

R

INDUSTRIAL PROCESSES

CHEMICAL 0.1 20.6% 0.0 0.2% 0.0 0.2 

FOOD AND 

AGRICULTURE 9.2 -3.0% -0.3 -0.1% -0.0 9.0 

MINERAL 

PROCESSES 1.5 17.4% 0.3 0.0% 0.0 1.7 

METAL PROCESSES 0.0 6.0% 0.0 0.0% 0.0 0.0 

WOOD AND PAPER 0.0 0.0 0.0 0.0% 0.0 0.0 

GLASS AND RELATED 

PRODUCTS 12.0 18.0% 2.2 28.9% 4.1 10.1 

ELECTRONICS 0.0 107.7% 0.0 0.0% 0.0 0.0 

OTHER (INDUSTRIAL 

PROCESSES) 0.0 36.8% 0.0 0.0% 0.0 0.0 

* TOTAL INDUSTRIAL 

PROCESSES 22.9 21.0 

** TOTAL 

STATIONARY 

SOURCES 

153.4 135.4 

GRAND TOTAL FOR 

SJVUAPCD 153.4 15.0 135.4 

1 This table represents a subset of the emissions inventory data used elsewhere in this Extreme OADP, and is used only fo

estimating emission reduction credit use. It reflects only changes that are projected to occur from 2000 to 2010 in the statiocomponent of the overall inventory. Also, it was derived from an ARB emissions inventory that is different from the Central (CCOS) emissions inventory Version 2.11 used for the remainder of this document, but that was developed with data consinventory. Consequently, emissions data presented in Table 3-2 may show minor differences from those in Table 3-1 for sshould not be directly compared with Table 3-1 or with other emissions data derived from Table 3-1. 
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SJVUAPCD Chapter 3 - E

3-18 

Table 3-3 

Estimated VOC Growth, Control, and Estimated Offset Use for Stationary Sourc

SUMMARY 

CATEGORY NAME 

2000 

Emissions 

Tons/day 

Growth Factor (%) Estimated 

Growth 

(tons/day) 

Control 

Factor (%) 

Required 

Reductions 

(tons/day) 

2010 

Emissions 

Tons/day 

STATIONARY SOURCES 

FUEL COMBUSTION 

ELECTRIC UTILITIES 0.4 37.7% 0.1 -0.1% 0.0 0.5 

COGENERATION 0.7 27.0% 0.2 -0.0% 0.0 1.0 

OIL AND GAS 

PRODUCTION 

(COMBUSTION) 

2.7 15.6% 0.4 0.0% 0.0 3.2 

PETROLEUM 

REFINING 

(COMBUSTION) 

0.1 0.0% 0.0 0.0% 0.0 0.1 

MANUFACTURING 

AND INDUSTRIAL 0.3 26.3% 0.1 0.1% 0.0 0.4 

FOOD AND 

AGRICULTURAL 

PROCESSING 

2.7 -2.7% -0.1 -0.1% 0.0 2.6 

SERVICE AND COMMERCIAL 1.2 10.5% 0.1 -0.0% 0.0 1.3 

OTHER (FUEL 

COMBUSTION) 0.0 0.0% 0.0 0.0% 0.0 0.0 

* TOTAL FUEL 

COMBUSTION 8.1 9.0 

WASTE DISPOSAL 

SEWAGE 

TREATMENT 0.0 22.0% 0.0 0.6% 0.0 0.0 

LANDFILLS 2.8 21.8% 0.6 0.0% 0.0 3.4 

INCINERATORS 0.0 0.0 0.0 0.0 
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SJVUAPCD Chapter 3 - E

3-19 

Table 3-3 

Estimated VOC Growth, Control, and Estimated Offset Use for Stationary Sources1 

SUMMARY 

CATEGORY NAME 

2000 

Emissions 

Tons/day 

Growth Factor (%) Estimated 

Growth 

(tons/day) 

Control 

Factor (%) 

Required 

Reductions 

(tons/day) 

2010 

Emissions 

Tons/day 

WASTE DISPOSAL (cont.) 

SOIL REMEDIATION 0.0 13.6% 0.0 0.0% 0.0 0.0 

OTHER (WASTE 

DISPOSAL) 0.5 26.3% 0.1 0.0% 0.0 0.6 

* TOTAL WASTE 

DISPOSAL 3.3 -0.0% 4.0 

CLEANING AND SURFACE COATINGS 

LAUNDERING 0.1 23.6% 0.0 0.4% 0.0 0.1 

DEGREASING 11.1 -7.7% -0.9 86.4% 8.8 1.5 

COATINGS & 

RELATED PROCESS 

SOLVENTS 

13.8 29.0% 4.0 2.1% 0.4 17.5 

PRINTING 1.5 16.9% 0.2 -0.0% 0.0 1.7 

ADHESIVES AND 

SEALANTS 0.7 -16.8% -0.1 -0.0% 0.0 0.6 

OTHER (CLEANING & 

SURFACE COATINGS) 2.8 43.3% 1.2 -0.0% -0.0 4.0 

*TOTAL CLEANING & 

SURFACE COATINGS 29.9 25.4 

PETROLEUM PRODUCTION AND MARKETING 

OIL/GAS PROD. 31.6 0.4% 0.1 0.9% 0.3 31.4 

PET. REFINING 1.4 0.3% 0.0 2.1% 0.0 1.4 

PET. MARKETING 6.6 21.9% 1.5 9.6% 0.8 7.3 

* TOTAL PETROLEUM 

PROD. & MARKETING 39.6 40.1 
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SJVUAPCD Chapter 3 - E

3-20 

Table 3-3 

Estimated VOC Growth, Control, and Estimated Offset Use for Stationary Sources1 

SUMMARY 

CATEGORY NAME 

2000 

Emissions 

Tons/day 

Growth Factor (%) Estimated 

Growth 

(tons/day) 

Control 

Factor (%) 

Required 

Reductions 

(tons/day) 

2010 

Emissions 

Tons/day 

INDUSTRIAL PROCESSES 

CHEMICAL 1.9 31.7% 0.6 0.0% 0.0 2.5 

FOOD & 

AGRICULTURE 10.7 13.0% 1.4 2.7% 0.3 11.8 

MINERAL 

PROCESSES 0.3 22.8% 0.1 0.0% 0.0 0.4 

METAL PROCESSES 0.2 0.4% 0.0 0.0% 0.0 0.2 

WOOD & PAPER 0.0 0.0 0.0 0.0 

GLASS & RELATED 

PRODUCTS 0.1 15.0% 0.0 0.0% 0.0 0.1 

ELECTRONICS 0.0 105.9% 0.0 0.0% 0.0 0.0 

OTHER (INDUSTRIAL 

PROCESSES) 0.1 10.0% 0.0 -0.1% 0.0 0.1 

* TOTAL INDUSTRIAL 

PROCESSES 13.3 15.1 

** TOTAL 

STATIONARY 

SOURCES 94.2 93.5 

GRAND TOTAL FOR 

SJVUAPCD 94.2 9.8 93.5 

1 This table represents a subset of the emissions inventory data used elsewhere in this Extreme OADP, and is used only fo

estimating emission reduction credit use. It reflects only changes that are projected to occur from 2000 to 2010 in the statiocomponent of the overall inventory. Also, it was derived from an ARB emissions inventory that is different from the Central (CCOS) emissions inventory Version 2.11 used for the remainder of this document, but that was developed with data consinventory. Consequently, emissions data presented in Table 3-2 may show minor differences from those in Table 3-1 for sshould not be directly compared with Table 3-1 or with other emissions data derived from Table 3-1. 
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SJVUAPCD Chapter 3 - Emission Inventory 

3-21 

For each source category, this percentage was established based on past 

permitting history, the fraction of sources in the category with emissions at or 

above the offset trigger levels, and the historical permitting activity for the source 

category. The District used the following factors in estimating the potential need 

for offsets: 

• All increases from modifications to existing sources with potential 

emissions at or above the above offset thresholds would require offsets 

(District Rule 2201). 

• New sources with emissions exceeding the above offset thresholds would 

require offsets (District Rule 2201). 

• The percentage of sources that meet any of the above criteria was 

estimated by examining past permitting history and by projecting future 

permitting based on the estimated growth. For instance, the majority of 

permitting actions with increases in emissions from oil production facilities 

come from sources with potential emissions in excess of the above offset 

thresholds. Therefore, for that source category, it was assumed that 

100% of increase in overall emissions would require offsets. 

The quantity of required offsets was then established by multiplying the expected 

growth in emissions for each source category by this percentage and the 

expected offset ratio. District rule 2201 establishes offset ratios ranging from 

1.3:1 to 1.5:1 based on the distance from the source of ERCs to the source with 

the increase in emissions. An offset ratio of 1.5:1 applies to all transactions 

where the distance is greater than 15 miles. Historically, most transactions in the 

District involve a distance of greater than 15 miles. For calendar years 2000—

2003, the average offset ratio for all permitting actions was slightly higher than 

1.4:1. Therefore, the District used an average offset ratio of 1.4:1 for these 

calculations. 

Tables 3-2 and 3-3 contain the expected growth, percentage of activities subject 

to offset requirements, and the expected quantity of offsets for each pollutant. 

Although some offsets are expected to come from post-baseline reduction, this 

Plan conservatively assumes that all offsets will be pre-baseline. The expected 

pre-baseline offset usage after 2000 through 2010, as shown in Tables 3-2 and 

3-3, is estimated as follows: 

 NOx .......................................12.1 tons/day 

 VOC ....................................... 8.1 tons/day 

 

As shown above, the quantities of pre-baseline offsets that are expected to be 

used between 2000 and 2010 are less than the estimated growth in emissions for 

each pollutant. As currently adopted, if growth in new and modified sources 

occurs at the rate estimated in this Plan, the use of offsets as provided in Rule 

2201 will ensure that permitted increases in major source emissions will not 

interfere with progress towards attainment of federal 1 hour ozone standards or 
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the achievement of the 3 percent per year reduction in ozone precursor 

emissions. As discussed in Chapter 7, the District satisfies the requirement for 

rate of progress with above-mentioned projected inventories and without taking 

credit for the ERCs required of and provided by new and modified stationary 

sources. 

3.4.3.4 Safeguards

In order to assure the use of pre-baseline ERCs do not interfere with attainment 

effort and the applicable rate of progress, this Extreme OADP incorporates the 

following safeguards: 

• The District will place a cap on the amount of pre-baseline credits that can 

be used. Although the District has relied on a number of conservative 

assumptions in estimating the usage quantity of pre-baseline credits, 

some degree of uncertainty exists. For instance, unexpected growth or 

irregular permitting activity may occur for one or more source categories. 

The cap on the use of pre-baseline ERCs will be enforced by tracking the 

use of such credits and disallowing such credits, through permitting 

actions when the above-specified levels are reached. The District Rules 

and Regulations will be amended to require tracking and enforcement of 

the above referenced cap within 12 months after EPA approval of this 

Extreme OADP. Appendix E lists the cap on stationary source growth by 

pollutant. 

• Although some ERCs will come from post-baseline reductions, this 

Extreme OADP conservatively assumes that all offsets will come from prebaseline reductions. As discussed earlier, federal law only requires the 

pre-baseline ERCs to be included in the growth and the attainment 

demonstration. This Extreme OADP assumes that all ERCs will be prebaseline ERCs and, therefore, includes them all in the projected inventory 

as growth. Using a larger than permissible projected inventory leads to 

conservative conclusions relating to the attainment and rate of progress 

demonstrations. 

• Although permissible, this plan does not take credit for reductions and 

mitigations required under the District’s New Source Review Rule. In 

particular, this Plan does not reduce the future years emissions by taking 

credit for the amount of ERCs provided through permitting actions. This 

conservative approach assures that the attainment demonstration is not 

affected by the use of pre-baseline ERCs. 
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3.5 CONFORMITY BUDGETS 

Section 176(c) of the FCAA outlines the conformity provision of the Clean Air Act. 

Federal actions are required to conform to the SIP’s purpose of eliminating or 

reducing the severity and number of exceedances of the NAAQS and achieving 

expeditious attainment of these standards. The FCAA distinguishes 

transportation actions [those undertaken by the Federal Highway Administration 

(FHWA) or the Federal Transit Administration (FTA)] from all other federal 

actions. 

Metropolitan Planning Organizations (MPOs) must make findings that the 

regional transportation plans (RTPs) and transportation improvement programs 

(TIPs) conform to the SIP. They submit this conformity finding along with the 

RTP and TIP, to FHWA and FTA for approval. The conformity finding must 

demonstrate that the emissions associated with the RTP and TIP do not exceed 

“emission budgets” that are contained in the SIP. 

The District’s Amended 2002 and 2005 Rate of Progress Plan for San Joaquin 

Valley Ozone established subarea emissions budgets for each county for ROG 

and NOx for 2005; in addition, the 2003 PM10 Plan established subarea 

emissions budgets for each county for NOx and PM for 2005, 2008 and 2010. 

This Extreme OADP establishes new subarea county emissions budgets for 

ROG and NOx for 2008 and 2010, as provided in Table 3-4 for the purposes of 

conformity. After an adequacy finding by EPA, these new budgets will apply for 

subsequent years, unless these budgets are superseded by new budgets or by 

budgets set for later years. 

Efforts have been made to incorporate the SJVAB MPO’s updated vehicle miles 

traveled (VMT) [submitted as comments in response to the release of EMFAC 

2002 and used in the Amended 2003 PM-10 Plan] into the emissions budgets. 

ARB staff conducted model runs to match the VMT data through adjustments to 

vehicle population. With this approach, emissions budgets reflect not only the 

latest VMT data, but also reflect the additional impact of those data on emissions 

from vehicle starting and from vehicle fuel evaporation. After reviewing the 

EMFAC results, District, ARB and TPA staff reduce the emissions estimates to 

account for any emissions controls that were not included in the model runs, and 

to make other adjustments as warranted to project emissions for future years. 

Table 3-4 reflects emissions reductions benefits of the California Inspection and 

Maintenance (I/M) program, statewide measures affecting mobile sources 

(Chapter 4), and reductions from the District’s Indirect Source Rules (ISR) and 

incentive programs (Chapter 4). 
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Table 3-4 

Transportation Conformity Budgets1

VOC Emissions (tons/day) NOx Emissions (tons/day) 

County 2008 2010 2008 2010 

Fresno 15.8 13.0 33.7 27.7 

Kern (SJVAB) 11.5 9.6 32.7 27.2 

Kings 2.5 2.1 6.2 5.4 

Madera 3.9 3.3 8.4 7.2 

Merced 5.0 4.0 11.4 9.1 

San Joaquin 9.3 7.7 22.4 17.9 

Stanislaus 8.5 7.0 17.4 14.0 

Tulare 8.5 6.9 18.8 15.3 

Total 65.0 53.6 151.0 123.8 

1 All emissions are expressed as summer tons/day, and were derived using EMFAC2002, Version 2.2 (April 2003) with 

updated vehicle population and vehicle miles traveled data. Emissions totals reflect the emissions reductions benefits 

from motor vehicle inspection and maintenance (I/M), state measure reductions, and reductions from the District’s Indirect 

Source Rules (ISR) and mobile source incentive programs; consequently, totals will not match those in Table 3-1 which 

do not reflect these additional control measures. The budget was established by taking the EMFAC results, subtracting 

the emissions reductions benefits, rounding up to the nearest tenth if the hundredths place was “1” or higher. See 

Appendix A for county-specific breakdown of on-road motor vehicle emissions and emissions reductions benefits. 

3.6 EMISSIONS INVENTORY UNCERTAINTIES 

A substantial amount of staff work goes into developing emissions inventories for 

SIPs. In order to prepare a plan in time to meet deadlines, many times the 

inventory used as a basis for modeling must be “frozen” in time at some point3 so 

that modeling can proceed and so that control measures can be evaluated. As 

staff works with the inventory, they often identify issues that need to be 

addressed to make the inventory more accurate, such as possible overestimates 

of source categories, underestimates of source categories, seasonal or other 

temporal changes in emissions that may not be reflected, or spatial distribution 

issues addressing how the emissions are distributed over the modeled area. 

For this Extreme OADP, the following uncertainties were identified after the 

inventory was frozen for use in plan development: inclusion of emissions from 

heavy duty trucks used to haul produce from fields to processing locations; 

spatial distribution of on-road motor vehicle emissions in the northern four 

counties vs. the southern four counties; discrepancies between two different 

methods of estimating heavy duty truck emissions in the SJVAB; the effects of 

temperature discrepancies on biogenic emissions and resultant predicted ozone 

levels; and the effects of fires on base case ozone levels and whether or not fires 

should be included in future scenarios for control measure evaluation (See 

Chapter 5). Work continues under CCOS to evaluate these and other 

uncertainties so that their magnitude can be evaluated and their effect on future 

ozone trends quantified. ARB conducts periodic multi-agency meetings to 

evaluate and discuss SIP emissions inventory issues (see Appendix D). 

 

3

 For this Extreme OADP, the inventory was frozen in November 2003. 
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3.7 CONCLUSION 

Emissions inventory data reflect the best estimates that can be made of the rates 

and chemical composition of air pollutants entering the atmosphere. Although 

some emissions are directly measured (usually those from large stationary 

sources equipped with continuous emissions monitors), most of the inventory is 

estimated using standardized techniques and methodologies. Inventories can 

change over time due to a number of factors including changes in source activity 

level, changes in emissions factors, or changes in the spatial distribution, 

chemical composition, or rate of the emissions. 

This Extreme OADP is based on two types of inventories: a planning inventory 

and a modeling inventory. Air quality planners use the planning inventory to 

study and propose control measures, to track trends in emissions for meeting 

federal Rate of Progress requirements (Chapter 7) and to track the use of ERCs, 

and to assist in demonstrating attainment (Chapter 5). In addition, the on-road 

motor vehicle emissions component of the planning inventory has special 

importance for establishing conformity budgets for transportation planning 

purposes. The modeling inventory provides day-specific information used as 

input for the photochemical model that predicts future ozone levels in the SJVAB. 

The planning and modeling inventories each have cutoff dates for the inclusion of 

control measures (i.e., control measures adopted past the cutoff date are not 

reflected in the inventories and must be subtracted from the results of inventory 

runs and model runs). 

This Extreme OADP uses the most accurate and up to date emission inventories 

possible within the time allowed to meet Federal Clean Air Act requirements. 

Many emission categories within the inventories were updated to reflect current 

data and emission factors. While changes and improvements to the SJVAB’s 

inventories are ongoing, at some point in time the planning and modeling 

inventories must be “frozen” to allow plan development to proceed (i.e., the 

inventory must be frozen so that potential future emission control measures can 

be evaluated for their effectiveness in attaining the federal 1-hour ozone 

standard). Many emission inventory improvement projects are in process or are 

planned, and the results of these and other studies will be reflected in the 

inventories used in future SIP submittals. 
❖
Chapter 4 - Control Strategy
❖
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4 CONTROL STRATEGY 

4.1 INTRODUCTION 

Federal law requires the District, as an extreme nonattainment area for the 

federal 1-hour ozone standard, to include certain provisions in the attainment 

plan. Specifically, the Federal Clean Air Act (CAA) requires that this plan must 

• “provide for the implementation of all reasonably available control measures 

as expeditiously as practicable”, (Section 172(c)(1)) 

• make “reasonable further progress.” (Section 172(c)(2)) and 

• include “enforceable emission limitations, and such other control measures, 

means or techniques...” which are needed and appropriate to demonstrate 

compliance with the federal standards (Section 172(c)(6)). 

The California Clean Air Act, as codified in the California Health and Safety Code 

(CH&SC), also requires the plan to 

• include provisions for the use of best available retrofit control technology 

(BARCT) for existing permitted sources. (CH&SC Section 40919(a)(3)) and 

• include “every feasible measure in the plan...” (CH&SC Section 40914(b)(2) 

To satisfy these CAA and CH&SC requirements, this section of the Plan includes 

control measures for stationary sources subject to District regulations (with 

associated rule development schedules) and control measures for mobile and 

area sources subject to ARB rules. It also summarizes commitments made by 

the Valley Regional Transportation Planning Agencies (RTPA) to undertake 

projects with air quality benefits. Lastly, Chapter 4 includes information about 

local, state, and federal pollution control incentive programs. 

4.2 DISTRICT RULE DEVELOPMENT SCHEDULE 

As a result of the previously Amended 2002 and 2005 Ozone Rate of Progress 

Plan (Ozone ROP Plan) and the 2003 PM10 Plan (PM10 Plan), the District is 

already committed to develop a number of control measures in the form of new 

or amended rules. The control measures in the Ozone ROP Plan are designed 

to reduce NOx and VOC emissions. During the winter months, these pollutants 

are also sources of secondary PM10, so the PM10 Plan includes control 

measures for NOx and VOC as well. 

The rule development schedule shown in Table 4-1 includes commitments from 

those plans for NOx and VOC reductions. The basis for these control measures 

is federal, state and local requirements or other considerations that are identified 

in the control measure detail section of this report. These measures do not 

include PM10 Plan commitments that would not impact ozone formation.
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SJVUAPCD Chapter 4 

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Table 4-1: District Control Measure Schedule (2004 - 2007) 5

Control 

Measure Rule Number Description 

Adopt or 

Amend 

Rule 

Pollutant

2008 

Baseline 

(tpd)7

2008 

Reductions 

(tpd)7

A 4409 New6 Oil and Gas Fugitives 2Q-2005 VOC B 4455 New6 Refinery & Chemical Fugitives 2Q-2005 VOC C 9310 New Fleet Rule - School Buses 3Q-2006 NOx D 9510 New6 3180 New6 Indirect Source Mitigation1 4Q-2005 NOx 

E 4307 New6 Small Boilers, Process Heaters, Steam Generators, 2.0 - 5.0 MMBtu/hr 2 4Q-2005 NOx 

F 4694 New6 Wineries - Fermentation and Storage 4Q-2005 VOC 

G 4352 Solid-Fuel Boilers, Steam Generators, & Process Htrs 2Q-2006 NOx 

H 47026 Stationary IC Engines 2Q - 2005 NOx 

I 4309 New6 Commercial Dryers3 4Q-2005 NOx 

J 4565 New Composting/Biosolids Operations 3 1Q-2007 VOC 

K 4602 Automotive Coating 3Q-2006 VOC 

L 4570 Concentrated Animal Feeding Operations 2Q - 2006 VOC 

M 

4662 4663 4602 4603 4604 4605 4606 4607 4653 4684 

Organic Solvent Degreasing Organic Solvent Cleaning Motor Vehicle and Mobile Equipment Coating Surface Coating of Metal Parts and Products Can and Coil Coating Operations Aerospace Assemblies and Component Coating Wood Products Coating Graphic Arts Adhesives Polyester Resin Operations 

3Q-2007 VOC 
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SJVUAPCD Chapter 4 

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Table 4-1: District Control Measure Schedule (2004 - 2007) 5(cont.) 

Control 

Measure Rule Number Description 

Adopt or 

Amend 

Rule 

Pollutant

2008 

Baseline 

(tpd) 

2008 

Reductions 

(tpd) 

N 43086 Water Heaters, 0.075 - 2.0 MMBtu/hr 3 4Q - 2005 NOx 

O 44016 Steam-Enhanced Oil Well Vents 4Q - 2006 VOC 

P 4651 Soil Decontamination 3 3Q-2007 VOC 

Q 4103 Open Burning Phase III 2Q-2007 NOx VOC 

R 4682 Polymeric Foam Manufacturing 3Q - 2007 VOC 

S 4703 Stationary Gas Turbines (< 10 MW, distributed generation) 2 3Q-2007 NOx 

T 4621, 4624 Gasoline Storage & Transfer 4Q-2007 VOC 

U New Aviation Fuel Transfer, Phase I 3 4Q-2007 VOC 

1 CCOS data is not available. Emissions and reductions based on reductions generated by funding projects with Indirect Source Mitigati2 CCOS data is not available. Emissions and reductions based on preliminary draft staff report. 3 CCOS data is not available. Emissions and reductions based on contracted emissions inventory report. 4 Rules with an average daily emissions of less than 0.05 tons/day may be included to satisfy federal and state requirements for RACT, B

Please see the control measure details for additional information. 

5 All data reflect CCOS SIP information using summer daily planning inventories, in tons per day (tpd), except as noted. 6 This control measure appears in 2003 PM10 Plan (Tables 4-17 through 4-20, as amended, December 2003), but elements of the rule (

reductions, baseline emissions, rule description, etc.) have been updated for this Extreme OADP; consequently, the control measure e

presented in the 2003 PM10 Plan for the same measure. Furthermore, the following additional PM10 Plan control measures, which arbecause they were adopted as rules before the Table was developed (ca January 2004), are used in this Extreme OADP for attainmen

progress (Chapter 7) demonstrations: Rule 4604 (Can and Coil Coating), Rule 4408 (Glycol Dehydration Systems), Rule 4610 (Glass C(Boilers, Steam Generators and Process Heaters), and Incentive Programs. Emissions reductions from these rules as given in Tables PM10 Plan were converted to summer emissions before being used elsewhere in this Extreme OADP. 7 The 2008 baseline and Emission Reductions were originally included the Extreme Ozone Attainment Demonstration Plan because the 

dependent on reductions from future rules to meet 2008 and 2010 Rate of Progress (ROP) requirements. On the day of plan adoptionROP demonstration that met the 2008 and 2010 ROP milestones with rules adopted as of September 2002, thereby eliminating the neThese commitments were inadvertently left in the plan when it was sent to EPA on November 15, 2004. State law prohibits the inclusioState Implementation Plan that are not needed to meet federal Clean Air Act requirements (California Health and Safety Code §39062removed the 2008 Commitments.
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4.2.1 District Control Measures 

Section 172 of the Federal Clean Air Act (FCAA) requires non-attainment plans 

to: “provide for the implementation of all reasonably available control measures 

as expeditiously as practical (including such reductions in emissions from 

existing sources in the area as may be obtained through the adoption, at a 

minimum, of reasonably available control technology) and shall provide for 

attainment of the national primary ambient air quality standards.” 

To determine what stationary source control measures might be feasible for 

adoption in the SJVAB, the District considered the California Air Resources 

Board’s Identification of Performance Standards for Stationary Sources (as

updated May 16, 2002); control measures committed to or successfully 

implemented in other regions [including South Coast Air Quality Management 

District, the Bay Area Air Quality Management District, and the HoustonGalveston (Texas) Area]; and control measures suggested by staff and members 

of the public at workshops held during the control measure development process. 

Some of those control measures were eliminated from the Ozone ROP Plan and 

PM10 Plan commitments, however, because: 

• the District had already adopted rules as effective as those described, 

• similar rules are currently being developed, or 

• the SJVAB has few or no sources in the affected categories. 

The District evaluated the remaining control measures, using baseline 

inventories, known control technology, potential emission reductions, and the 

feasibility of implementation by 2008. Based upon this evaluation, the District 

placed measures into the control measure schedule. From 2004 to 2007, the 

District’s rule development schedule will include the rules shown in Table 4-1. 

The schedule includes both new rules and amendments to existing rules that are 

necessary to satisfy applicable requirements including RACT, BARCT, and 

reasonable further progress toward attaining the one-hour ozone standard. 

The control measures indicated are those that the District commits to either 

developing as rules, or evaluating for possible rule development. Projects may 

be added or removed based on information received during the development of 

the Plan; detailed examination of the emission inventories and feasible control 

measures; or future local, state and federal requirements. 

The District may develop new control measure schedules in future years. These 

schedules will be reflected in future SIP amendments that would be adopted by 

the District Governing Board, submitted to ARB for review and approval, and 

then submitted to EPA as a SIP amendment. 

For the purposes of implementing this Extreme OADP, the District is committed 

to adopt and implement control measures that will achieve, in aggregate, the 

emissions reductions specified in Table 4-1 and described in Section 4.2.3. 
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Emission reductions achieved in excess of the amount committed to in a given 

year can be applied to the emission reduction commitments of subsequent years. 

The District is committed to adopt the control measures listed in Table 4-1 unless 

these measures, or a portion thereof, are found infeasible and the District adopts 

other substitute measures that achieve equivalent reductions to meet any 

required milestone. Findings of infeasibility will be made at a regularly scheduled 

meeting of the District Governing Board with proper notification. For the 

purposes of State Implementation Plan commitments, infeasibility means that the 

proposed control strategy is not reasonably likely to be available by the 

implementation date in question, the actual emission inventory is significantly 

less than originally presented in the plan, or achievement of the emission 

reductions by that date is not cost-effective. The District acknowledges that this 

commitment is enforceable under Section 304(f) of the federal Clean Air Act. 

4.2.2 Control Measures Table 

Table 4-1 summarizes ozone precursor control measures grouped according to 

their proposed rule development schedule. In order to demonstrate compliance 

with the 2010 federal ozone standard, the District must have three years of 

“clean” air quality data. Therefore, control measures must be adopted as rules 

and implemented by operators by Spring 2008, in order for the measures to 

generate air quality benefits that satisfy the ozone attainment deadline. The 

control measures were scheduled based on a number of factors including the 

size of the existing emission inventory; the feasibility of control measures for the 

class and category of source; projected emission reductions which might result; 

similar controls already required or proposed by other districts; and possible 

implementation schedules. 

Some control measures were considered that will require additional refinement of 

the emissions inventory and/or further research into feasible emission controls. 

These measures have been placed in Table 4-2 for further study. 

Table 4-1 contains control measures for the rule projects currently scheduled to 

be developed in 2004 through 2007, as well as their projected adoption dates, 

emissions inventories for 2008 and 2010, and estimated reductions. These are 

measures for which the District has an adequate emissions inventory and/or for 

which reasonable control measures have been established by the District or 

other agency. The District has already begun rule development on many of the 

rules that are listed for 2004 and 2005 adoption. 
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Table 4-2: Potential Control Measures Requiring Further Study 

Further 

Study 

Rule 

Number(s) Description Pollutant 

A 2280 Portable Equipment NOx 

B New Asphalt Plant Dryers/Heaters NOx, VOC 

C 4402, 4625 Sumps, Pits, and Wastewater 

Processing Equipment VOC 

D New Fugitive Emissions - Heavy Oil 

Stream VOC 

E 4653 Adhesives VOC 

F 4607 Graphic Arts VOC 

G 4641 Cutback Asphalt Application VOC 

H 4607 Restaurants, Under-fired 

Charbroilers VOC 

I 4902 Residential Water Heaters NOx, VOC 

J New Furnaces NOx 

K New Brandy Production VOC 

When available, emission inventory data for 2008 and 2010 was taken from the 

ARB State Implementation Plan (SIP) Emission Projects (Central California 

Ozone Study (CCOS) Domain), Version 2.11, datasets 

(http://www.arb.ca.gov/app/emsinv/ccos/fcemssumcat_cc211.php). This data 

reflects the daily summer average emissions from the various for stationary 

source categories. The future year inventory was adjusted by ARB for projected 

growth and controlled for rule requirements that would apply to the source 

category prior to the indicated year. No adjustment was made to the baseline for 

the control measures indicated in Table 4-1 but the results of the proposed 

control measures are reflected in the "reductions" column. 

As noted in Table 4-1, emissions inventory data from several sources was used 

for the measures such as Composting/Biosolids Operations, for which the CCOS 

data was not available, or for measures such Commercial Dryers, which will only 

affect a small subset of a larger industrial emissions category. The emissions 

inventory information differs from the CCOS data in that it is typically calculated 

as an annual average rather than a summertime average. If comparable CCOS 

data were not available, the alternate data was not adjusted for growth. Because 

some of the emissions categories are not addressed by current rules and 
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regulations, the emission inventories were also not controlled for the current 

applicable rules. Sources for this data include the ARB emission inventory data, 

District-contracted emissions inventory studies, and District staff reports. 

Footnotes in Table 4-1 describe the specific data sources used. 

Due to the necessary assumptions made in compiling the data for the CCOS 

inventories, the ARB emission inventory, and the contracted study inventories, 

results of the final rule development calculations may differ from each of these. 

As a routine step in the rule development process, the District generates specific 

emission baseline and reduction information. Such information is typically based 

on detailed information about actual equipment and control levels, and therefore 

is a more accurate reflection of the true emissions and reduction potentials in the 

SJVAB. Where appropriate, the more accurate data will be submitted to update 

the CCOS and ARB inventories. Future planning exercises will reflect the more 

accurate baseline inventory and emission reduction data as it is developed. 

The emission reductions indicated in Table 4-1 are based on percent reductions 

from the baseline emission inventories. These percentages reflect assumed 

control technologies, control effectiveness, and rule applicability and penetration 

rates. The percent reduction represents the District's reduction commitment for 

the particular control measure. Table 4-1 emission reduction numbers (in tons 

per day) reflect the current emission inventory data and reflect the outcome of 

the percentage commitment, but are subject to revision as the inventories are 

refined. For example, scientists and engineers are now studying the emission 

factor for the Concentrated Animal Feeding Operations category to determine if 

the current factor accurately represents VOC emissions. The outcome of that 

study will be used to update the emissions inventory and could result in a new 

estimated emissions reduction. These changes, however, will not necessarily 

impact the percent reduction that is applied to the category. 

Table 4-2 indicates the further study categories that the District will investigate for 

potential future emission reductions. Assuming controls are feasible and 

emission reductions are significant, rule development activity for these categories 

would most likely occur in 2006 or later. These projects would address categories 

for which adequate emission inventories are not currently available or for which 

emission control strategies must be further researched and developed. 

Consequently, the further study measures in Table 4-2 are not District 

commitments for specific emission reductions or for future rulemaking. Rather, 

they are areas of further study to determine the potential for future emission 

reductions. For several of these measures, staff has already begun examining 

the emissions data and conducting research on potential control measures. The 

District believes that some of the measures may have small baseline emission 

inventories that would not generate significant emission reductions. Other 

control measures may be proposed based on technology-forcing standards 

proposed by other districts and for which a particular emission standard has not 
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been demonstrated or is not commonly available. Each of the measures in Table 

4-2 will be further evaluated, and may be either placed in the rule development 

schedule or ruled out as potential control measures. 

4.2.3 2004 – 2007 Control Measures 

This section provides specific information about the control measures, as shown 

in Table 4-1, that are scheduled for rule development between 2004 and 2007. 

The District will determine the details of the resulting rules during the rule 

development process based on applicable federal, state and local requirements, 

socioeconomic factors, and other information provided by public comments. 

During the rule development process, the District examines the existing rules of 

other air districts, and in-use and emerging control technologies, to identify levels 

representing the best feasible control standard for a given measure. Emission 

reductions shown are based on implementing feasible controls on the applicable 

emission inventories. The District may adjust these reductions to reflect any new 

control technology, source data, or practices that are discovered during rule 

development process. 

4.2.3.1 Control Measure A: New Rule 4409 (Oil and Gas Fugitives) 

REASON FOR CONTROL MEASURE: New Rule 4409 is a Current Rule 

commitment in the PM10 Plan and was listed in the Ozone ROP Plan as an All 

Feasible Measure suggested by the EPA. It would reduce fugitive VOC 

emissions from crude oil and gas production operations and natural gas 

processing plants. 

AFFECTED SOURCES: Rule 4409 would apply to sources involved in the 

production of crude oil, natural gas, and natural gas liquids. There are 

approximately 200 businesses in the San Joaquin Valley that are potentially 

subject to Rule 4409. The California Department of Oil, Gas, and Geothermal 

Resources Report shows approximately 105 oil and/or gas production fields in 

the San Joaquin Valley. The District’s permit database indicates eight permitted 

natural gas processing plants. 

DESCRIPTION: Crude oil and gas production facilities and natural gas 

processing facilities contain a large number of various types of components such 

as pipes, flanges, valves, fittings, threaded connections, hatches, pressure relief 

valves, pumps, and compressors. Leakage of fluids or gases from these 

components can be expected to occur during process and transfer operations, 

causing fugitive VOC emissions. The actual percentage of leaking components 

for most of these facilities may be small, but due to the large number of 

components the fugitive VOC emissions from leaking components, in aggregate, 

could be significant. 
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Possible controls include lowering the current gaseous leak threshold of 10,000 

ppmv, eliminating some existing exemptions, improving the existing inspection 

and repair programs by increasing the frequency of inspection, and shortening 

the repair period for leaking components and replacing frequently leaking 

components with Best Available Control Technology. 

IMPLEMENTATION SCHEDULE: The rule was adopted on April 20, 2005. Full 

implementation is scheduled for the second quarter of 2006. 

EMISSIONS AND EMISSIONS REDUCTIONS: Total VOC emissions from 

sources subject to Rule 4409 are estimated to be 10.4 tons per day in 2008. 

After full implementation of Rule 4409, reductions of 4.7 tons of VOC per day are 

anticipated. 

4.2.3.2 Control Measure B: New Rule 4455 (Refinery & Chemical 

Fugitives) 

REASON FOR CONTROL MEASURE: New Rule 4455 is a Current Rule 

commitment in the PM10 Plan and was listed in the Ozone ROP Plan as an All 

Feasible Measure suggested by the EPA. Rule 4455 would replace existing 

Rules 4451 and 4452, and it would reduce fugitive VOC emissions from leaking 

components in petroleum refining and chemical manufacturing plants by 

strengthening and expanding the requirements compared to the existing rules. 

AFFECTED SOURCES: Rule 4455 would apply to businesses involved in 

petroleum refining and production of industrial organic chemicals. There are four 

petroleum refineries and one gas-liquids processing facility that would be subject 

to Rule 4455. One chemical plant currently operates in the San Joaquin Valley. 

DESCRIPTION: Petroleum facilities, gas liquids processing facilities, and 

chemical plants contain a large number of various types of components such as 

pipes, flanges, valves, threaded connections, pressure relief valves, process 

drains, pumps, and compressors. Leakage of fluids or gases from these 

components can be expected to occur during process and transfer operations, 

causing fugitive VOC emissions. The actual percentage of leaking components 

for most of these facilities may be small, but due to the large number of 

components the fugitive VOC emissions from leaking components, in aggregate, 

could be large. 

In general, the state RACT/BARCT guidelines and similar rules from other air 

districts establish lower leak thresholds, require operators to conduct more 

frequent inspections of components, and provide shorter periods to repair leaking 

components than currently allowed in Rules 4451 and 4452. Rule 4455 would 
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replace those rules and would be more effective by implementing a rigorous leak 

detection and repair program and by requiring BACT equipment to replace 

frequently leaking devices. 

IMPLEMENTATION SCHEDULE: The rule was adopted on April 20, 2005.. Full 

implementation is scheduled for the second quarter of 2006. 

EMISSIONS AND EMISSIONS REDUCTIONS: Total VOC emissions from 

sources subject to Rule 4455 are estimated to be 0.5 tons per day in 2008. Upon 

full implementation of Rule 4455, reductions of 0.2 tons of VOC per day are 

anticipated. 

4.2.3.3 Control Measure C: New Rule 9310 ( Fleet Rule – School 

Buses) 

REASON FOR CONTROL MEASURE: The PM10 Plan and Ozone ROP Plan

identified the need for on-road fleet rules to address mobile source emissions in 

the San Joaquin Valley. Rule 9310 is a new rule that would reduce NOx and 

PM10 emissions from school bus fleets and consequently reduce the public's 

exposure to toxic air contaminants (TACs) and criteria pollutants. Reductions 

would be accomplished through the use of new, cleaner vehicles or by retrofitting 

existing buses with improved engines or emission controls. 

AFFECTED SOURCES: Rule 9310 would apply to operators of school bus fleets 

for elementary and secondary schools. Based on a 2003 survey, there are 

approximately 2,755 schools buses, operating in public and private contract 

fleets, in the District. This was the single largest group of public agency fleet 

vehicles of any one particular fleet class, accounting for 45% of the total number 

of fleet vehicles in the District. 

DESCRIPTION: The new rule is designed to reduce NOx and PM emissions 

from school buses. This rule is intended to achieve greater and earlier NOx and 

PM emission reductions than would occur through the normal vehicle 

replacement process for these buses. 

Emissions from school bus fleets could be reduced in a number of ways, 

including 

• replacing existing buses with newer, cleaner buses before their 

normally scheduled retirement; 

• replacing older engines of existing buses with newer engines using 

cleaner emissions technology; 

• retrofitting emission control technology to existing buses; or 

• modifying existing buses to use cleaner-burning diesel or alternate 

fuels. 
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Generally, older-model school buses emit more TACs and other air pollutants 

than the more current models. More than one-third of the existing school buses 

are fifteen years old or older, and were manufactured to less stringent emission 

standards than those for later-model school buses. The oldest buses would 

benefit most from either complete replacement or repowering to reduce tailpipe 

emissions. 

IMPLEMENTATION SCHEDULE: Rule development is in progress with adoption 

scheduled for third quarter of 2006. Implementation will begin in the fourth 

quarter of 2007; however, due to the quantity and the cost of school buses, and 

limited school district budgets, full rule implementation is expected to occur well 

after 2010. 

EMISSIONS AND EMISSIONS REDUCTIONS: Total NOx emissions from 

sources that will be subject to Rule 9310 are estimated to be 2.5 tons per day in 

2008, with 0.1 tons/day of NOx reduced by 2010. Upon full implementation of 

this rule in 2015, reductions of 1.1 tons of NOx per day is anticipated. 

4.2.3.4 Control Measure D: New Rules 9510 (Indirect Source Mitigation 

Program) and 3180 (Indirect Source Mitigation Fee) 

REASON FOR CONTROL MEASURE: These rules are Current Rule commitments 

in the 2003 PM10 Plan and post-2003 Control Measures in the Ozone ROP Plan. In 

addition, California State Senate Bill (SB) 709, approved September 22, 2003 

requires the District to adopt a schedule of fees on area-wide and indirect sources of 

emissions that are regulated, but for which permits are not issued. Growth in 

indirect source emissions and related area source emissions offsets a substantial 

portion of the benefit of emission controls on motor vehicles and stationary sources. 

Mitigation fees provide an option to reduce emissions off-site when additional on-site 

emission reductions are not feasible. 

AFFECTED SOURCES: Phase I of the program, contained in Rule 9510 and 3180, 

will be applicable to residential development projects that generate indirect 

emissions from mobile sources and area source emissions from other on-site 

activities not subject to District permitting. Phase II and Phase III will address 

commercial/institutional and industrial development projects (respectively) that 

generate indirect emissions from mobile sources and area source emissions from 

other on-site activities not subject to District permitting. 

DESCRIPTION: Indirect sources are land use activities, such as housing 

developments, shopping malls, and industrial sites, that attract or generate motor 

vehicle trips. Indirect source emissions are not emitted directly from permitted 

equipment or activities at the location, as is the case for traditional permitted 

stationary sources such as boilers, engines or fuel storage tanks. Indirect source 
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emissions are created by motor vehicle trips to and from the site. The program is 

also considering emissions from area sources such as water heaters and landscape 

maintenance equipment. This program will have three phases at a minimum and 

will include residential, commercial, industrial, and institutional developments. 

Under the Indirect Source Mitigation Program, development projects would be 

required to mitigate a portion of their emissions with onsite mitigation and/or by 

contributing to a mitigation fund that would be used to pay for the most cost-effective 

projects to reduce emissions. The amount of the fee can be revised depending on 

the emission reductions required to meet rate of progress and the emission reducing 

projects available to fund. The program could be managed by the District or 

delegated to cities and counties. 

IMPLEMENTATION SCHEDULE: Rule adoption is scheduled for fourth quarter of 

2005. Rule implementation will begin in the first quarter of 2006. 

EMISSIONS AND EMISSIONS REDUCTIONS: The District has committed to a 

reduction of 4.0 tons per day of NOx from the Indirect Source Mitigation Program in 

the 2003 PM10 Plan. The reductions associated with Phase I through Rule 9510 

and 3180 will be a portion of that number that has yet to be determined. The NOx 

reductions are projected to come from reducing emissions from off-site mobile 

sources, such as heavy-duty trucks, school buses, and off-road equipment. 

Reductions could also be generated by development measures that reduce vehicle 

trips or miles traveled, and area source emissions from equipment and products 

used for building and landscape maintenance. The mitigation program will not be 

limited to these sources, however, and any cost-effective project that reduces 

emissions would be considered. 

4.2.3.5 Control Measure E: New Rule 4307 (Small Boilers, Process 

Heaters, and Steam Generators, 2.0–5.0 MMBtu/hr) 

REASON FOR CONTROL MEASURE: New Rule 4307 is a New Commitment 

(ID I) in the PM10 Plan and was listed in the Ozone ROP Plan as an All Feasible 

Measure suggested by the EPA. It is intended to reduce NOx and SOx 

emissions and to reduce future increases in carbon monoxide (CO) emissions 

from boilers, process heaters, and steam generators. The measure would affect 

any new or existing boiler, steam generator, and/or process heater with a rated 

heat input capacity greater than 2 million Btu/hour but less than or equal to 5 

MMBtu/hr. The PM10 Plan identified emissions from these units as a significant 

category. Since NOx and SOx emissions from smaller boilers, steam generators, 

and process heaters, exceed the de minimus threshold levels, they are subject to 

federal BACM requirements. The District currently has rules applying to similar 

equipment rated greater than 5.0 MMBtu/hr. 
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AFFECTED SOURCES: Facilities with units that are subject to this control 

measure represent a wide range of industries, including but not limited to medical 

facilities, educational institutions, office buildings, prisons, military facilities, 

hotels, and industrial facilities (including agricultural processing facilities). Due to 

the diversity of affected industries, units in this source category are located 

throughout the SJVAB. Based on population and job base, there are likely to be 

more units located in urban and suburban settings. The emissions inventory 

categories affected include Manufacturing and Industrial Fuel Combustion, and 

Service and Commercial-Other Fuel Combustion. 

DESCRIPTION: These units are not currently regulated by the District permitting 

process or a prohibitory rule. The District does not currently issue permits to 

operate for gas-fired equipment in this source category, but may do so in the 

future. Combustion modifications appropriate for small boilers, steam 

generators, and process heaters include low excess air, low NOx burners, 

water/steam injection, and flue gas recirculation (FGR). Post-combustion 

controls can include the use of selective catalytic reduction (SCR) or selective 

non-catalytic reduction (SNCR) treatment of the exhaust stream. 

IMPLEMENTATION SCHEDULE: Rule adoption is scheduled for the fourth 

quarter of 2005. Implementation is scheduled to begin in the fourth quarter of 

2007 with full BACM implementation by 2009. 

EMISSIONS AND EMISSIONS REDUCTIONS: Total NOx emissions from this 

category are estimated to be 8.8 tons per day in 2008. Upon final 

implementation of this control measure, 1.0 tons per day of NOx reductions is 

anticipated. 

4.2.3.6 Control Measure F: New Rule 4694 (Wineries – Fermentation 

and Storage) 

REASON FOR CONTROL MEASURE: New Rule 4694 is a New Commitment 

(ID K) in the PM10 Plan and a post-2003 control measure in the Ozone ROP 

Plan. It is intended to reduce VOC emissions from the fermentation of grapes in 

winery operations. The Ozone ROP Plan identified emissions from such 

operations as exceeding the major source threshold level; consequently, Federal 

RACT requirements apply to these operations. 

AFFECTED SOURCES: According to the California Department of Alcoholic 

Beverage Control (ABC), there are 109 wineries licensed to operate in the 

SJVAB. Of these wineries, 43 facilities produce 99% of the emissions; the rule is 

most likely to affect these facilities. 
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DESCRIPTION: Two winery processes that produce significant VOC emissions 

are wine fermentation and bulk wine storage. This control measure is designed 

to reduce the emissions from the fermentation and storage processes. Future 

rule development will address the VOC emissions from brandy production and 

storage. 

While limited fermentation may be conducted at any time of the year, the primary 

fermentation season occurs in the fall, during a 90-day period following the grape 

harvest. Fermentation of a single batch of wine will normally be completed in a 

three to ten day period, depending in the variety of wine and the chemistry of the 

particular batch. The process of fermentation produces VOC emissions which 

offgas to the atmosphere through tank openings. 

The District does not regulate these operations through either the permitting 

process or a prohibitory rule. Emission controls (other than process refrigeration) 

are not currently being used during the production of wines. Reduction of VOC 

could be achieved through the use of tanks with vapor collection and control 

systems, carbon adsorption, water scrubbers, catalytic incineration, 

condensation, and additional temperature control as appropriate. 

IMPLEMENTATION SCHEDULE: Rule adoption is scheduled for the fourth 

quarter of 2005. Full implementation is projected for the year 2009. 

EMISSIONS AND EMISSIONS REDUCTIONS: Total summer planning VOC 

emissions from sources subject to the wineries control measure are estimated to 

be 2.1 tons per day in 2008. Upon final implementation of the wine fermentation 

control measure, summer planning reductions of 0.7 tons of VOC per day are 

anticipated. 

4.2.3.7 Control Measure G: Rule 4352 (Solid Fuel Fired Boiler, Steam 

Generators, and Process Heaters) 

REASON FOR CONTROL MEASURE: Amending Rule 4352 is a New 

Commitment (ID H) in the PM10 Plan and a post-2003 Control Measure in the 

Ozone ROP Plan. NOx emissions from solid fuel fired boilers, steam generators, 

and process heaters, exceed the major source threshold levels, and therefore 

are subject to federal RACT requirements. This commitment is intended to 

address those requirements. 

AFFECTED SOURCES: There are 14 permitted units in this category within the 

District , with half of the units located in the District’s Southern Region, and the 

remaining units split between the Central and Northern Regions. Facilities in this 

category generate utility and industrial power (electricity and heat) by burning 

solid fuels including petroleum coke, municipal solid waste, tires or biomass 
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wastes (including wood, vine clippings, leaves, grass, and other by products of 

the farming and food processing industries). 

DESCRIPTION: Rule 4352 (Solid Fuel-Fired Boilers, Steam Generators, and 

Process Heaters) regulates the NOx and CO emissions from this category by 

specifying allowable emission rates. Rule 4352 currently contains the old 

definition for the major source NOx threshold so it applies only to units at facilities 

emitting over 50 tons of NOx per year. The rule is being amended to include the 

current major definition and ensure that all major sources are subject to this rule. 

The rule’s current emission limits may be made more stringent if amended to be 

consistent with current state's " all feasible measure" requirements. Existing 

facilities are already operating at or below the "all feasible" NOx limit so no NOx 

reductions would result from incorporating that limit. 

IMPLEMENTATION SCHEDULE: Adoption of Rule 4352 is scheduled for the 

second quarter of 2006, and full implementation is scheduled for the first quarter 

in 2009. 

EMISSIONS AND EMISSIONS REDUCTIONS: Total NOx emissions from 

sources subject to this control measure are estimated to be 3.8 tons per day in 

2008. Because existing facilities are already compliant with the "all feasible" 

measure NOx emission level, no actual reduction is anticipated. 

4.2.3.8 Control Measure H: Rule 4702 (Stationary IC Engines) 

REASON FOR CONTROL MEASURE: Amending Rule 4702 is a New 

Commitment (ID N) in the PM10 Plan and a post-2003 Control Measure in the 

Ozone ROP Plan. This rule currently controls NOx emissions from stationary, 

spark-ignited IC engines. Rule 4702 would be expanded to cover all internal 

combustion engines rated greater than 50 brake horsepower, including those 

used in agricultural operations. 

AFFECTED SOURCES: It is estimated that there are approximately 4,500 diesel 

fueled internal combustion engines, rated greater than 50 brake horsepower, 

used in agricultural irrigation operations in the SJVAB. The number of sparkignition internal combustion engines, rated greater than 50 brake horsepower 

and used in agricultural operations is currently estimated at approximately 530 

units (engines powering wind machines could significantly increase this number; 

note that these machines typically do not operate during ozone season, so this 

omission is not important for this Extreme OADP. 

DESCRIPTION: Rule 4702 currently controls emissions from spark-ignition 

stationary IC engines by requiring them to meet specific NOx emission limits 
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when operating. All engines used in agricultural operations were previously 

exempted from Rule 4702 pursuant to state law, (CH&SC 42310(e)). That law 

was rescinded effective January 1, 2004 and the District is currently amending 

Rule 4702 to address this equipment category and other compression ignition 

engines. 

NOx emissions reduction can be achieved by making such engines, as well as all 

diesel-fueled engines, subject to NOx emission limits in Rule 4702. Many 

farmers have recently installed new, cleaner-burning engines with funding under 

the Moyer program. Further reductions can be achieved by increasing the 

stringency of NOx emission limits to meet recently adopted Best Available 

Retrofit Control Technology (BARCT) standards and by making the standards 

applicable to certain engines now exempted from the rule. 

There are several possible options that are commonly used to control engine 

emissions. The option with the highest reduction potential is to replace existing 

engines with electric motors and many locations already have hookup for electric 

motors. Other strategies would include replacing old engines with newer cleaner 

engines; retrofit older engines with add-on exhaust control devices; or converting 

existing engines to a cleaner-burning fuel or alternate fuels. The emission limits 

and compliance schedule for agricultural engines will be developed pursuant to 

the requirements of CH&SC 40724 and will reflect the most stringent technically 

and economically feasible of the candidate control options. 

 IMPLEMENTATION SCHEDULE: CH&SC 40724 mandated the schedule for 

rule development for such engines. Therefore, on or before July 1, 2005, the 

District must propose to adopt the final rules at a noticed public hearing, and rule 

implementation must commence on or before January 1, 2006. The rule was 

adopted on June 16, 2005. 

EMISSIONS AND EMISSIONS REDUCTION: The NOx emissions from internal 

combustion engines rated greater than 50 brake horsepower and used in 

agricultural irrigation operations, are estimated to be 21.0 tons per day in 2008. 

Upon full implementation, it is anticipated those NOx emissions would be 

reduced by 8.4 tons per day. 

4.2.3.9 Control Measure I: New Rule 4309 (Commercial Dryers) 

REASON FOR CONTROL MEASURE: This new rule is a New Commitment (ID 

C) in the PM10 Plan and a post-2003 Control Measure in the Ozone ROP Plan. 

NOx and SOx emissions from industrial and commercial dryers exceed the “de 

minimus threshold” levels, therefore, are subject to federal BACM requirements. 
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AFFECTED SOURCES: Dryers are used to remove water from process material 

by heating which causing evaporation of the water. Most dryers in the SJVAB 

are used to remove moisture from fruits, nuts, vegetables, cotton, and also from 

clothing at laundries and dry cleaning plants. Facilities with units that are subject 

to this control measure represent a wide range of industries, including but not 

limited to cotton ginning, nut, fruits and vegetable processing, dairy products, 

laundry cleaning services, and concrete manufacturing. Units in this source 

category are located throughout the eight county area of the SJVAB. 

DESCRIPTION: These units are currently subject to District permitting 

requirements, but not a specific prohibitory rule. The new rule would establish 

NOx and SOx emission standards for dryers subject to permitting requirements. 

Differing emission standards may be established based on the heat input 

capacity of the dryer, and whether the unit is new or existing. Dryers are typically 

direct-fired, meaning that the exhaust directly contacts the material being heated. 

To reduce particulate contamination, dryers are predominantly fired on natural 

gas or propane. Emission controls appropriate for dryers include use of PUC 

quality natural gas, excess air controllers, low-NOx burners, and flue gas 

recirculation (FGR). 

IMPLEMENTATION SCHEDULE: Rule adoption is scheduled for the fourth 

quarter of 2005. Full BACM implementation for NOx and SOx is projected for the 

year 2009. 

EMISSIONS AND EMISSIONS REDUCTION: Total NOx emissions from 

sources subject to the Dryer control measure are estimated to be 8.8 tons per 

day in 2008. Upon final implementation of the dryer control measure, a reduction 

of 1.0 tons per day of NOx is anticipated. 

4.2.3.10 Control Measure J: New Rule 4565 (Composting/Biosolids 

Operations) 

REASON FOR CONTROL MEASURE: This new rule is identified in the Ozone 

ROP Plan as requiring additional emissions inventory development. This rule is 

designed to reduce VOC emissions created during the composting of biosolids 

including sewage sludge, agricultural waste, and other greenwaste. 

AFFECTED SOURCES: This category would address emissions from new and 

existing sources involved with composting biosolids or mixtures of biosolids 

including emissions arising from the beneficial use or disposal of sewage sludge 

derived from the treatment of municipal wastewater, whether from within the 

District and imported from outside the District. Beneficial uses include land 

application, composting, and use as landfill cover, among others. Disposal 

methods include surface disposal, landfilling, and incineration. Facilities 
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involved with these activities are classified as Biosolids Management (EIC 199-

995-0260-0000). 

DESCRIPTION: This project would investigate the emissions and controls for 

composting biosolids to determine if emission controls are feasible and if VOC 

reductions are achievable. Biosolids are primarily generated as waste 

byproducts from municipal wastewater treatment, livestock operations, 

agricultural operations and commercial and residential landscaping. Many 

factors increase the potential emissions inventory for this category. These 

factors include: 

• Growing populations in Valley communities increases demands on 

municipal wastewater treatment as well as generating more 

landscaping waste material. 

• New and expanded confined animal feeding operations generate more 

livestock waste. The South Coast Air Quality Management District 

(SCAQMD) is currently working on a rule amendment to have the 

removal of livestock waste from the South Coast Air Basin as a control 

option, which may increase the District’s inventory for this category. 

• Recent changes to the CH&SC will phase out traditional open burning 

of agricultural waste, increasing pressure to compost. 

• State and federal landfill regulations promote composting of green 

waste and other biodegradable materials to extend landfill capacities. 

VOC emission controls are currently under investigation and could include vapor 

collection and control systems, forced aeration, and windrow of materials to 

generate beneficial soil amendments, 

IMPLEMENTATION SCHEDULE: Adoption for this control measure will be the 

first quarter of 2007 with full implementation projected for the year 2010. 

EMISSIONS AND EMISSIONS REDUCTIONS: Total VOC emissions from 

sources subject to this rule are estimated to be 0.7 tons per day in 2008. Upon 

full implementation of this rule, a reduction of 0.1 tons of VOC per day is 

anticipated. 

4.2.3.11 Control Measure K: Rule 4602 (Automotive Coating) 

REASON FOR CONTROL MEASURE: Amending Rule 4602 was listed in the 

Ozone ROP Plan as an All Feasible Measure suggested by the EPA. This 

control measure is intended to reduce VOC emissions from coating used in 

automotive coating operations by incorporating more stringent material limits. 
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AFFECTED SOURCES: The measure would affect any new or existing 

operations involved with coating automobile, parts, and accessories. 

DESCRIPTION: Rule 4602 controls emissions from automobile and automotive 

parts and products coating operations by specifying coating material VOC limits, 

allowable application equipment, and emission control options. CAPCOA has 

proposed that districts adopt a uniform rule for this category based on the most 

stringent coating material limits required by the various districts. Amendments to 

Rule 4602 would incorporate those new standards and help establish a uniform 

automotive coating requirement throughout California. 

IMPLEMENTATION SCHEDULE: Adoption of Rule 4602 amendments is 

scheduled for the third quarter of 2006, and full implementation is scheduled for 

the first quarter in 2009.

EMISSIONS AND EMISSIONS REDUCTIONS: Total VOC emissions from 

sources subject to Rule 4602 are estimated to be 1.6 tons per day in 2008. Upon 

full implementation of this rule, a reduction 0.1 tons of VOC per day is 

anticipated. 

4.2.3.12 Control Measure L: New Rule 4570 (Concentrated Animal 

Feeding Operations) 

REASON FOR CONTROL MEASURE: New Rule 4570 is a New Commitment 

(ID A) in the PM10 Plan and a post-2003 Control Measure in the Ozone ROP 

Plan. It is intended to reduce VOC emissions from Concentrated Animal Feeding 

Operations (CAFOs). This is also a requirement of CH&SC Section 40724.6. 

AFFECTED SOURCES: Rule 4570 would affect operations including dairies, 

cattle feedlots, poultry ranches, and other agricultural operations involving animal 

husbandry. The exact number of affected facilities will be determined during the 

rule development process based on exemption levels derived from the costeffectiveness of available controls. 

 DESCRIPTION: Operations involved with the raising of fowls or animals were 

previously exempted from District permitting pursuant to state law (CH&SC 

42310(e)) that was rescinded effective January 1, 2004. VOC emissions may be 

reduced by controlling emissions from feedlots and from supporting operations 

such as waste treatment lagoons. 

The BACM and BARCT emission limits and compliance schedule for CAFOs will 

be developed pursuant to the requirements of CH&SC 40724.6 and will reflect 

the technical and economic feasibility of candidate control options. 
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 IMPLEMENTATION SCHEDULE: CH&SC 40724.6 mandates the schedule for 

rule development for CAFOs. Therefore, on or before July 1, 2006, the District 

must propose to adopt the final rules at a noticed public hearing, and rule 

implementation must commence on or before January 1, 2007. 

EMISSIONS AND EMISSIONS REDUCTIONS: Total VOC emissions from 

sources subject to Rule 4570 are estimated to be 60.9 tons per day in 2008. 

Upon full implementation of this rule, a reduction of 15.8 tons of VOC per day is 

anticipated. These emission estimates are based on the currently accepted 

emission factors. Research in this area is being conducted which may lead to 

more accurate emission factors. The emissions and emission reductions may be 

updated in the future to reflect the most accurate information and such 

information would be incorporated into future plan updates. 

4.2.3.13 Control Measure M: Rule 4662 (Organic Solvent Degreasing 

Operations); Rule 4663 (Organic Solvent Cleaning, Storage, 

and Disposal); Rule 4602 (Motor Vehicle and Mobile Equipment 

Coating); Rule 4603 (Surface Coating of Metal Parts and 

Products); Rule 4604 (Can and Coil Coating Operations); Rule 

4605 (Aerospace Assemblies and Component Coating); Rule 

4606 (Wood Products Coating); Rule 4607 (Graphic Arts); Rule 

(Adhesives); and Rule 4684 (Polyester Resin Operations) 

REASON FOR CONTROL MEASURE: Amending these rules was identified as a 

state required "All Feasible Measure". This control measure is intended to 

reduce VOC emissions from organic solvents used in parts and equipment 

cleaning by incorporating more stringent VOC content limits. 

AFFECTED SOURCES: The measure would affect any new or existing 

operations involved using organic solvents for parts or equipment cleaning. 

DESCRIPTION: Rule 4662 controls VOC emissions from organic solvent 

degreasing operations by specifying solvent VOC limits, allowable application 

equipment, and emission control options. Rule 4663 controls VOC emissions 

from organic solvents used to clean parts and equipment outside of the 

degreasers covered by Rule 4662. The other rules address solvents used to 

prepare surfaces and clean equipment used in the applicable operation 

addressed by the rules. Since these rules were last amended, other air districts 

have started requiring lower-VOC solvents (25 grams VOC per liter). 

Amendments to these rules would incorporate this new standard and help 

establish a uniform organic solvent cleaning standard for businesses in 

California. 
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IMPLEMENTATION SCHEDULE: Amendments of these rules is scheduled for 

the third quarter of 2007 with full implementation scheduled for the fourth quarter 

in 2008.

EMISSIONS AND EMISSIONS REDUCTIONS: The emissions from sources 

affected by the control measure are estimated at 4.9 tons VOC per day in 2008. 

Upon final implementation of the proposed control measure, a reduction of 1.3 

tons of VOC per day is anticipated. 

4.2.3.14 Control Measure N: New Rule 4308 (Water Heaters, 0.075–2.0 

MMBtu/hr) 

REASON FOR CONTROL MEASURE: This new rule is a New Commitment (ID 

J) in the PM10 Plan and a post-2003 control in the Ozone ROP Plan. NOx 

emissions from industrial, commercial and institutional water heaters in the 

SJVAB appear to be large enough to warrant control through new emission 

control measures. 

AFFECTED SOURCES: Facilities with such units represent a wide range of 

industries, including medical facilities, educational institutions, office buildings, 

prisons, military facilities, hotels, and industrial facilities. Due to the diversity of 

industries, units in this source category are located throughout the District, but 

primarily in urban and suburban settings. Thus the sources likely to be affected 

by this rule are not confined to a particular geographic area within the SJVAB nor 

are they confined to a particular economic sector. 

DESCRIPTION: The new rule would likely affect new commercial, industrial, or 

institutional water heaters with a rated heat input capacity between 75,000 Btu/hr 

and 2 MMBtu/hr. These heaters typically use fuel combustion to heat water 

needed for industrial, commercial, or institutional processes. Affected units are 

similar in principle to residential water heaters, but combust fuel at greater rates 

and produce greater quantities of hot water. For this particular control measure, 

NOx prohibitory rules may be coupled with a financial incentive program to 

accelerate the replacement or retrofit of higher-polluting units. The District does 

not control these emissions either through the permitting process or through a 

prohibitory rule, and the District does not anticipate issuing permits for these 

units in the future. 

IMPLEMENTATION SCHEDULE: Rule adoption is scheduled for the fourth 

quarter of 2005. Standards will apply to new units commencing in the first 

quarter of 2007. Full implementation is expected to take 20 to 30 years. 

EMISSIONS AND EMISSIONS REDUCTIONS: Total NOx emissions from 

sources subject to the Water Heaters control measure are estimated to be 1.4 
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tons per day in 2008. By 2010, through implementation of Control Measure N, 

the District anticipates a reduction of 0.2 tons per day of NOx from that amount 

(such that the 1.4 tons/day would be reduced to 1.2 tons/day).

4.2.3.15 Control Measure O: Rule 4401 (Steam-Enhanced Oil Well 

Vents) 

REASON FOR CONTROL MEASURE: Amending Rule 4401 is a New 

Commitment (ID L) in the PM10 Plan and a post-2003 Control Measure in the 

Ozone ROP Plan. VOC emissions from steam enhanced crude oil production 

well vents are significant and the rule can be strengthened to generate emission 

reductions. 

AFFECTED SOURCES: This control measure would reduce VOC emissions 

from steam-enhanced crude oil production wells and associated vapor collection 

and control systems. 1998, there were approximately 23,000 active steam 

enhanced crude oil production wells in the SJVAB. Most of the steam enhanced 

crude oil production wells are located in Kern County. As the wells operate 

throughout the year, emissions occur uniformly during the year. Rule 4401 

prohibits the operation of steam enhanced crude oil production wells unless the 

VOC emissions from oil production well vents are reduced by at least 99 percent 

by weight. This level of control can be achieved through the operation of a vapor 

collection and control system. The rule also requires that well vent vapor 

collection and control systems be maintained in good repair, with standards for 

specified allowable number of leaks depending upon the number of wells 

connected to the systems. Limited numbers of cyclic wells that meet specified 

conditions are currently exempted from the rule. Sources are also subject to 

Rule 4002 (National Emissions Standards for Hazardous Air Pollutants). 

DESCRIPTION: Further emission reductions can be achieved by lowering the 

exemption thresholds to make more sources subject to the rule. The rule is 

enforced through District permit and enforcement programs and would include 

inspections, annual on-site emission source testing, and record keeping. 

IMPLEMENTATION SCHEDULE: Adoption for this control measure is 

anticipated by the fourth quarter of 2006 and full BACM implementation is 

projected by 2010. 

EMISSIONS AND EMISSIONS REDUCTIONS: Total VOC emissions from 

sources subject to the Steam-Enhanced Crude Oil Production Well Vents control 

measure are estimated to be 13.2 tons per day in 2008. Upon full 

implementation of this rule, a reduction of 1.4 tons of VOC per day is anticipated. 
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4.2.3.16 Control Measure P: Rule 4651 (Soil Decontamination) 

REASON FOR CONTROL MEASURE: Amending Rule 4651 is identified in the 

Ozone ROP Plan as requiring additional emissions inventory development. This 

rule is designed to reduce VOC emissions created during activities in the 

remediation of contaminated soils. 

AFFECTED SOURCES: This rule applies to projects for remediation of 

contaminated soils. Soil contamination from organic materials occurs due to 

leaking storage and handling systems, operating losses, and accidental spills. 

Remediation projects are normally short-lived, typically ranging from a few hours 

to a year, depending on the extent of the contamination. Due to the unplanned, 

unexpected and random nature of spills, it is not possible to quantify a specific 

number of sources. 

DESCRIPTION: This project would upgrade the control requirements for soil 

remediation operations. Soil remediation is normally conducted using either insitu techniques, in which the contaminated soil is left in place, or ex-situ 

techniques, in which the soil is excavated then treated and replaced, or 

permanently removed from the site. In-situ remediation techniques include soil 

vapor extraction, bioremediation, and liquid displacement. Ex-situ remediation 

techniques include limited aeration, thermal desorption (drying); and landfilling. 

VOC emissions generated by remediation projects can be controlled by a variety 

of common VOC controls such as capture and thermal destruction, biofiltration 

beds, carbon adsorption, condensation, and burial in sealed drums or in 

impermeable landfills. 

Past in-situ projects have predominantly relied on soil vapor extraction and either 

carbon adsorption or thermal destruction, but bioremediation has also gained 

favor for smaller projects. Bioremediation uses either naturally-occurring or 

specifically-introduced microbes to consume soil contaminants. Ex-situ 

remediation favors limited soil aeration for small or low-level concentration. 

Larger projects typically involve excavation and then landfilling the soil as a 

hazardous material. A limited survey of landfill operators indicated that as much 

as 90% of the contaminated soil received in 2002 was from sources outside the 

SJVAB. 

IMPLEMENTATION SCHEDULE: Adoption for this control measure is 

anticipated in the third quarter of 2007 with full implementation for VOC control 

projected for the year 2009. 

EMISSIONS AND EMISSIONS REDUCTIONS: Total VOC emissions from 

sources subject to this control measure are estimated to be less than 0.05 tons 

per day in 2008. Upon full implementation of this rule, a reduction of less than 
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0.05 tons of VOC per day is anticipated. These figures are subject to revision 

since the current emissions inventory may not have captured all of the 

contaminated material originating from sources outside of the District. 

4.2.3.17 Control Measure Q: Rule 4103 (Open Burning Phase III) 

REASON FOR CONTROL MEASURE: Amending Rule 4103 is intended to 

reduce NOx and VOC emissions from the open burning of agricultural waste 

materials as required by recent amendments to the California Health and Safety 

Code (CH&SC), which are described below. 

AFFECTED SOURCES: Rule 4103 regulates and coordinates the use of open 

burning while trying to minimize impacts on the public. Affected sources are 

agricultural operations throughout the Valley which use open burning to dispose 

of agricultural waste, eliminate pests, and control plant diseases. 

DESCRIPTION: Rule 4103 prohibits agricultural burning on days that the District 

declares to be no-burn days. No-burn days are days during which meteorological 

conditions are not conducive to good ventilation and mixing, but they are not 

necessarily days expected to experience high ozone concentrations. Open 

burning is controlled on days when the ozone standard is in jeopardy of being 

exceeded. This rule also prescribes conditions under which burning must be 

conducted to minimize smoke and controls would be instituted on those days 

when emissions of NOx and VOC contribute to exceedances of the ozone 

standard. 

Open burning is now required be phased out between 2005 and 2010, pursuant 

to the schedule in CH&SC 41855.5(a). CH&SC 41855.6 allows the District to 

postpone the commencement date of a burn prohibition, provided several 

conditions exist, including the lack of economically feasible alternatives to 

burning. NOx and VOC emissions reduction will be achieved by the new 

requirement. CH&SC 41855.5(d)(1) requires the District develop a rule to 

regulate limited open burning for disposal of diseased crops and weed control. 

IMPLEMENTATION SCHEDULE: CH&SC 41855.5 mandated the schedule for 

rule development for these projects. On or before January 1, 2005, the District 

must propose to adopt the final diseased-crop burning rule at a noticed public 

hearing, and rule implementation must commence on or before January 1, 2006. 

Provisions of the open burning restrictions are self-implementing and will begin in 

June 2005 with full implementation by 2010. The District will adopt rule 

amendments before the applicable restriction dates which address appropriate 

provisions for selected materials for which there are no reasonable alternatives to 

burning. 
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EMISSIONS AND EMISSIONS REDUCTION: Adoption for this control measure 

will be phased in during 2005 and 2007 with full implementation projected for the 

year 2010. Total emissions from sources subject to this control measure are 

estimated to be 2.3 tons of NOx and 5.8 tons of VOC per day in 2008. Upon full 

implementation of this rule, a reduction of 1.1 tons per day of NOx and 2.9 tons 

per day of VOC is anticipated in 2010. The exact reductions realized will depend 

on the extent to which open burning practices can be replaced by cost-effective, 

technologically feasible alternatives. 

4.2.3.18 Control Measure R: Rule 4682 (Polymeric Foam 

Manufacturing) 

REASON FOR CONTROL MEASURE: This category was listed in the Ozone 

ROP Plan as an "All Feasible Measure" suggested by the EPA. Amending Rule 

4682 is intended to reduce VOC emissions from manufacturing polymeric foam 

and foam products by specifying material VOC content limits and emission 

control devices. 

AFFECTED SOURCES: This category is primarily concerned with VOC 

emissions from the manufacturing of polystyrene, polyethylene, and 

polypropylene foam products, specifically consumer foam products such as 

coffee cups, food containers and packing material. There are ten manufacturers 

of these foam products located within the District. 

DESCRIPTION: Plastic foam products include a wide range of materials, 

including packaging for food and fragile products, building insulation, and a 

variety of other consumer items. Foams are manufactured by utilizing blowing 

agents, commonly hydrocarbons, which form vapor-filled “cells” within the plastic. 

After manufacturing, foam products contain residual blowing agent, which diffuse, 

while stored at the facility and after being transported from the facility. 

Rule 4682 limits emissions from polystyrene foam, polyethylene, and 

polypropylene manufacturing, but only for selected operations and equipment 

within the process. This rule would be expanded to include VOC emission 

reduction or control from product curing areas and general product storage, 

similar to those employed by several of the existing sources. 

Possible controls for this category include switching to an alternative, non-VOC 

blowing agent or employing capture and control systems for the VOC emissions. 

All ten manufacturers within the SJVUAPCD are still utilizing primarily VOC 

blowing agents (either directly or in the form of EPS beads). 
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IMPLEMENTATION SCHEDULE: Adoption of Rule 4682 amendments is 

scheduled for the third quarter of 2007, and full implementation is scheduled for 

the fourth quarter in 2009.

EMISSIONS AND EMISSIONS REDUCTIONS: Total VOC emissions from 

sources subject to Rule 4682 are estimated to be 0.3 tons per day in 2008. Upon 

full implementation of this rule, less than 0.1 tons per day of VOC reductions are 

anticipated. 

4.2.3.19 Control Measure S: Rule 4703 (Stationary Gas Turbines) 

REASON FOR CONTROL MEASURE: This category is being identified by 

public comment as warranting additional control measure development. Existing 

Rule 4703 addresses NOx emission limits for stationary gas turbines. This 

control measure would specifically examine controls for turbines rated less than 

10 MW and used for distributed power generation. 

AFFECTED SOURCES: Stationary gas turbines are used for mechanical power, 

electrical power generation, and steam and heat generation roles in oil 

production and refining, food processing, petroleum transportation, irrigation 

district water pumping, and commercial power generation. 

DESCRIPTION: Rule 4703 limits NOx emissions from turbines. Existing 

turbines in the SJVAB generally control NOx emissions through water or steam 

injection, dry low-NOx combustion technology, selective catalytic reduction, or 

some combination thereof. Since this rule was last amended in 2002, CARB 

published emission standards for turbines used in electrical power generation. 

The CARB standards apply to new or modified turbines but may be attainable by 

existing turbines depending on the development of new burner technology. The 

control measure would examine the feasibility of CARB NOx and CO limits for 

stationary gas turbines, rated <10.0 MW. Turbines rated greater than 10 MW are 

subject to requirements similar to the CARB limits. 

IMPLEMENTATION SCHEDULE: Adoption for this control measure is 

anticipated in the third quarter of 2007 with full implementation for NOx control 

projected for the year 2010. 

EMISSIONS AND EMISSIONS REDUCTIONS: The emissions from sources 

affected by the control measure are estimated at 2.5 tons NOx/day. Upon final 

implementation of the proposed control measure, a reduction of 0.6 tons of NOx 

per day is anticipated. 

4.2.3.20 Control Measure T: Rule 4621 (Storage and Transfer of 

Gasoline) and Rule 4624 (Organic Liquid Loading) 
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REASON FOR CONTROL MEASURE: Amending Rules 4621 and 4624 is a 

Post-2003 Control Measure in the Ozone ROP Plan. It is designed to reduce 

VOC emissions from gasoline terminals and bulk plants which result from 

transfer equipment and operations. 

 

AFFECTED SOURCES: Rule 4621 applies to bulk plants storing gasoline in 

large, aboveground tanks, and transferring the gasoline to delivery trucks via 

loading racks. There are fugitive VOC emissions from the fittings on the tanks, 

piping (valves and flanges), and from the loading rack operations (displaced 

vapor space from the delivery trucks). 

DESCRIPTION: Rules 4624 and 4621 contains VOC emission control 

performance limit for tanks and equipment used to store and transfer organic 

liquid, specifically gasoline. Since the last rule update, the standards for control 

of VOC fugitive emissions have become more stringent. Strengthening the 

current rule standards is feasible and would result in additional emission 

reductions. Possible control enhancements include increased inspection and 

maintenance frequencies, tank seal repair or replacement, and retrofitting old 

systems with newer technologies. 

IMPLEMENTATION SCHEDULE: Adoption for this control measure is 

anticipated in the fourth quarter of 2007 with full implementation for VOC controls 

projected for the year 2010. 

EMISSIONS AND EMISSIONS REDUCTIONS: The emissions from sources 

affected by the control measure are estimated at 3.3 tons VOC per day in 2008. 

Upon final implementation of the proposed control measure, a reduction of 0.9 

tons of VOC per day is anticipated. 

4.2.3.21 Control Measure U: New Rule (Aviation Fuel Transfer, Phase I) 

REASON FOR CONTROL MEASURE: This category is a Post-2003 Control 

Measure in the Ozone ROP Plan. The new rule would reduce fugitive VOC 

emissions created during Phase 1 aircraft refueling operations. Phase 1 

operations include filling aviation fuel bulk storage tanks using primary fuel 

delivery trucks as well as filling an airport’s fuel delivery trucks from the bulk 

storage tanks. It does not include filling an aircraft’s on-board fuel tanks. 

AFFECTED SOURCES: This measure would affect operations with bulk aviation 

fuel storage, including military, civilian, and private airports or air fleet services. 

These tanks typically hold either aviation gasoline or a variety of kerosene-based 

jet fuel. There are 43 airports in the SJVAB that sell one or both types of these 

fuels. 
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DESCRIPTION: This operation would investigate the emission inventory and 

feasible control measures for bulk aviation fuel storage tanks. Fugitive VOC 

emissions are released from these tanks due to spillage and vapor displacement 

during Phase 1 operations and from venting through relief valves to prevent 

excessive pressure from diurnal heating. 

Rule 4621 addresses Phase 1 requirements for tanks holding motor vehicle fuel, 

but not aviation fuel. Also, while Rule 4623 addresses fueling motor vehicles, it 

does not apply to fueling aircraft since aircraft do not have uniform fueling points 

and the Phase 2 equipment is not certified for that use. 

Fugitive emissions can be controlled with pressure-vacuum relief valves on 

storage tanks, submerged fill tubes to reduce splashing, and vapor recovery or 

destruction systems similar to those used for Phase I motor vehicle fueling 

operations. 

IMPLEMENTATION SCHEDULE: Adoption for this control measure is 

anticipated in the fourth quarter of 2007 with full implementation for VOC control 

is projected for the year 2010. 

EMISSIONS AND EMISSIONS REDUCTIONS: The emissions from sources 

affected by the control measure are estimated at 0.2 tons VOC per day in 2008. 

Upon final implementation of the proposed control measure, a reduction of less 

than 0.05 tons of VOC per day is anticipated. 

4.2.4 Potential Control Measures Requiring Further Study 

This section provides information about the possible future control measures, as 

shown in Table 4-2, which require further study. Exact details of the resulting 

rules will be determined during the rule development process based on 

applicable federal, state and local requirements, socioeconomic factors and 

specific information provided by the public comments. Some of these are control 

measures with small baseline inventories that would be the least effective in 

achieving significant emission reductions in an expeditious manner. These 

control measures will be further evaluated and may be eliminated as potential 

controls. 

4.2.4.1 Further Study Project A: Rule 2280 (Portable Equipment 

Registration Program) 

REASON FOR CONTROL MEASURE: Amending Rule 2280 is a Post -2003 

Control Measure in the Ozone ROP Plan. This control measure could reduce 

NOx emissions from fuel combustion by registered portable equipment. 
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AFFECTED SOURCES: Rule 2280 applies to portable equipment that is 

operated at various locations in the District and are not registered under the state 

portable equipment program. Such equipment, primarily portable engines, is 

used in many industries for a variety of tasks including electrical power 

generation, pumping, concrete production, abrasive blasting, and providing 

mechanical power. District emission estimates are calculated by ARB using their 

Off-Road Model. Current ARB and the District registries for these types of 

equipment may be incomplete due to units that are not registered with either 

agency or which could be registered with other districts. 

DESCRIPTION: Portable engines create NOx emissions by burning diesel fuel, 

gasoline, natural gas, or propane/liquefied petroleum gas. Such units are 

required to register with either the District or with ARB and are subject to the 

emission standards of the applicable portable engine registration program. New 

units are subject to emission standards set by ARB and EPA for the current year 

of manufacture. 

Emissions from older diesel engines can be significantly higher (12 grams 

NOx/bhp-hr) than currently manufactured diesel engines (5.9 grams NOx/bhphr). Starting in 2006, the new engine standard will drop to 3.0 gram (NOx + 

VOC)/bhp-hr for larger engines, with all new engines meeting that standard by 

2008. It is important to note that manufacturers may meet the emission 

standards on a production-averaged basis and that individual engines or engine 

types may have higher emissions. 

Spark-ignited engines are not expected to generate comparable emission 

reductions since these engines typically meet or exceed the applicable EPA and 

ARB standards. 

The state portable equipment regulation program is currently under revision to 

address the health risks associated with emissions of diesel particulate 

emissions. These emissions can be effectively controlled with either diesel 

oxidation catalyst, and catalyzed diesel particulate filters. Both catalysts also 

reduce 50-90% of VOC emissions, used in conjunction with lower-sulfur fuel. The 

diesel fuel sulfur limit will be lowered to 15 ppmv effective September 1, 2006. 

Similar catalysts for NOx reduction are under development for off-road engine 

applications and may be suitable for portable engine applications after further 

refinement. 

It is also feasible to generate NOx reductions through the replacement of 

existing, older portable engines with newer units according to an advanced 

retirement schedule. 
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4.2.4.2 Further Study Project B - New Rule (Asphalt Plant 

Dryers/Heaters) 

REASON FOR CONTROL MEASURE: This category is a Post-2003 Control 

Measure in the Ozone ROP Plan. This new rule could reduce NOx and VOC 

emissions asphalt production operations. There are currently no District rules 

specifically addressing asphalt production equipment. 

AFFECTED SOURCES: This control measure would apply to asphalt production 

facilities operating in the District with material heating equipment. 

DESCRIPTION: Asphalt is produced using a mixture of mineral and petroleum 

components. During production, the mineral components, gravel and crushed 

rocks, is heated to remove excess moisture before mixing with the petroleumbased binding agent. Heat may also be used to heat the petroleum binder during 

mixing and storage. A direct-fired heater is typically used for the drying/mixing 

process, so the heater exhaust is contaminated with PM10 and VOC released 

from the heated products. PM10 and VOC emissions, commonly seen as blue 

smoke, may also result from the material handling and storage equipment. 

Significant NOx emissions can also result from combustion of fuel for the 

heaters. 

Possible control measures include clean burning fuel and low-NOx burners for 

the heaters, capture and controls for the blue smoke emissions, and catalytic 

particulate filters to reduce fugitive VOC and PM10 from the exhaust stream. 

This control measure is being addressed as part of Control Measure I. 

4.2.4.3 Further Study Project C: Rules 4402 and 4625 (Sumps, Pits, 

and Wastewater Processing Equipment) 

REASON FOR CONTROL MEASURE: This category is a Post-2003 Control 

Measure in the Ozone ROP Plan. Amending Rules 4402 and 4625 would reduce 

VOC emissions from oilfield sumps, pits, and wastewater processing equipment. 

AFFECTED SOURCES: Rules 4402 and 4625 apply to oil and gas production 

sumps, pits and wastewater processing equipment. There approximately 200 

businesses in the approximately 105 oil and/or gas production fields in the 

SJVAB. 

DESCRIPTION: Oil and gas production operations generate large quantities of 

wastewater and sand as a waste product of the primary extraction. Many of 

these facilities use open pits to separate oil, water and sand generated during oil 

and gas production. Most primary separation is now accomplished in controlled 
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separation tanks, but secondary and final separation can still occur in open pits. 

The District is updating the emissions inventory of those sumps, including both 

heavy and light crude oil facilities. The District will also explore feasible control 

options that could generate additional VOC emission reductions. 

4.2.4.4 Further Study Project D - New Rule (Fugitive Emissions – 

Heavy Oil Stream) 

REASON FOR CONTROL MEASURE: This category requires additional 

emissions inventory development. Additional controls could reduce fugitive VOC 

emissions from equipment used in heavy crude oil production, transport, and 

refining. Heavy crude oil is defined as oil having an API gravity of less than 30

degrees. The District currently has no rules specifically addressing these heavy 

crude equipment emissions. 

AFFECTED SOURCES: This rule would apply to sources involved with heavy 

crude oil crude oil production, transport and refining. 

DESCRIPTION: This category requires an emissions inventory of fugitive volatile 

organic compounds from leaking components that carry streams of heavy crude 

oil that are located in crude oil production and processing facilities and crude oil 

refining facilities. Heavy crude oil components are currently exempt from existing 

District Rules 4403, 4451, and 4452 as well as new Rules 4409 and 4455 that 

are currently under development. District Rule 4401 addresses casing gases 

associated with heavy crude oil production but not components on liquid streams. 

The District does not currently have information on the number of heavy crude oil 

components. Estimates of the VOC emissions from leaking components are 

related to the total number of components and can be calculated using EPA, 

ARB or CAPCOA methodologies. 

Possible controls include establishing allowable the gaseous leak threshold(s), 

creating an inspection and repair programs with a specific minimum frequency of 

inspection, stating the maximum repair period for leaking components, and 

requiring replacement of frequently leaking components with Best Available 

Control Technology. 

4.2.4.5 Further Study Project E: Rule 4653 (Adhesives) 

REASON FOR CONTROL MEASURE: This category was listed in the Ozone 

ROP Plan as an All Feasible Measure suggested by the EPA. Amending Rule 

4653 could reduce VOC emissions from use of adhesives by specifying material 

VOC standards and/or requiring the use of alternate emission control system. 
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AFFECTED SOURCES: Adhesive materials are used in a wide variety of 

industries including commercial production facilities, construction activities, and 

maintenance and repair operations. Rule 4653 exempts users of less than 20 

gallons of adhesives per year so most affected sources will be commercial users 

in the manufacturing or construction fields. 

DESCRIPTION: Rule 4653 controls VOC emissions resulting from adhesive 

usage. VOC emissions result from the solvents used to pre-clean materials 

being bonded, from the adhesive material as it cures, and from solvents used to 

clean the finished product and application equipment. The existing material VOC 

content limits and exemptions will be examined to determine if stricter standards 

can be developed similar to those recently proposed by other air districts. 

4.2.4.6 Further Study Project F: Rule 4607 (Graphic Arts) 

REASON FOR CONTROL MEASURE: This category is a Post-2003 Control 

Measure in the Ozone ROP Plan. Amending Rule 4607 would reduce fugitive 

VOC emissions from graphic arts operations involved in the coating of paper, 

fabric and film coating and those involved in screen printing. 

AFFECTED SOURCES: The measure would affect any new or existing 

operations involved with graphic arts, paper or fabric coating, and screen 

printing. 

DESCRIPTION: Rule 4607 controls emissions from graphic arts operations by 

specifying coating material VOC limits, cleaning solvent VOC limits, allowable 

application equipment, evaporative loss minimization practices, and emission 

control options. Since this rule was last amended, other air districts have adopted 

more stringent VOC limits for certain coatings categories. Amendments to this 

rule could incorporate those new standards and help establish a uniform graphic 

arts requirement throughout California. 

4.2.4.7 Further Study Project G: Rule 4641 (Cutback Asphalt 

Application) 

REASON FOR CONTROL MEASURE: This category is a Post-2003 Control 

Measure in the Ozone ROP Plan. Amending Rule 4641 could reduce VOC 

emissions from cutback asphalt application. 

AFFECTED SOURCES: This control measure would apply to operators involved 

with the manufacture and use of cutback asphalt, slow cure asphalt and 

emulsified asphalt. Use of these asphalts includes roadway paving and 

maintenance operations, parking area construction, and dust control. 
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DESCRIPTION: Cutback asphalt is a paving grade of asphalt liquefied with 

petroleum distillates and generally classified as medium or rapid cure as defined 

in Rule 4641. Rule 4641 controls VOC emissions by limiting the use of asphaltic 

materials and allowable application temperature. While the VOC content of 

asphaltic roof coating material is regulated under Rule 4601, further emission 

reductions may be possible by extending this rule to include asphalt roofing 

operations. Such operations heat the asphalt to allow application on large 

industrial facilities. The heating of the asphalt in large kettles results in fugitive 

VOC emissions. Possible controls for such kettles include close-fitting lids, 

tightly controlled operating temperatures, and afterburners. Some operators 

already use lids and operating temperature limits to reduce smoke and odors. 

The afterburners, however, are uncommon for this application and may require 

early retirement of existing kettles. 

4.2.4.8 Further Study Project H: Rule 4692 (Restaurants – Under-fired 

Charbroilers) 

REASON FOR CONTROL MEASURE: This category is a Post-2003 Control 

Measure in the Ozone ROP Plan. Amending Rule 4692 would reduce fugitive 

VOC emissions from restaurants using charbroiling equipment for food 

preparation. 

AFFECTED SOURCES: This control measure would affect any new or existing 

operations involved with under-fired charbroilers. 

DESCRIPTION: Rule 4692 currently applies to restaurants using chain-driven 

charbroilers. At the time the rule was adopted in March 2002, the only feasible 

control was not applicable to under-fired charbroilers. An under-fired charbroiler 

is a grill in which food is placed on an iron grate above a heat source. As the 

food cooks, fats or marinades drip onto heat source producing smoke that 

provides the characteristic charred flavor. In the late 1990’s, studies on 

charbroiler emission factors found that under-fired charbroiling is the method that 

produces the largest amount of PM and VOC emissions. 

Due to the enclosed nature of a chain-driven charbroiler, it is possible to equip 

such equipment with an exhaust catalytic converter to control the VOC 

emissions. Under-fired charbroilers, however, are more open units with 

significantly lower exhaust temperatures that are not compatible with catalytic 

converter controls. 
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4.2.4.9 Further Study Project I: Rule 4902 (Residential Water Heaters) 

REASON FOR CONTROL MEASURE: Amending Rule 4902 was identified as 

under the Significant Source Category in the PM10 Plan and a Post-2003 Control 

Measure in the Ozone ROP Plan. 

AFFECTED SOURCES: Residential water heaters are typically fired on natural 

gas or propane, emitting NOx emissions from the combustion of the fuel. These 

units are located throughout the District in urban, suburban, and rural settings. 

DESCRIPTION: These units are currently regulated by the District under Rule 

4902. That rule requires new and replacement heaters to be certified with NOx 

emissions of less than 40 nanograms per Joule (0.093 lb NOx per million BTU) of 

heat output. The South Coast AQMD Rule 1121 will require residential water 

heaters to meet a 10 nanograms per Joule NOx standard in 2005. That standard 

is not considered to have been demonstrated as technologically feasible, but 

may be so demonstrated in the future. If such equipment is manufactured and 

readily available, the District could achieve a 75% NOx reduction by adopting a 

similar standard. That standard would only apply to new or replacement water 

heaters so units installed prior to the any new standard taking effect would 

remain for their useful life. 

4.2.4.10 Further Study Project J - New Rule ( Furnaces) 

REASON FOR CONTROL MEASURE: : This category is a Post-2003 Control 

Measure in the Ozone ROP Plan. It was designated as a control measure to 

reduce NOx emissions from industrial furnaces. 

AFFECTED SOURCES: Industrial furnaces are typically fired on natural gas or 

propane, emitting NOx emissions from the combustion of the fuel. These units 

are located throughout the District in a variety of industries which require high 

temperatures for operations such as smelting, curing materials, heat treating 

metals, ceramic firing, and cleaning impurities from metal products. 

DESCRIPTION: Rule 4305 and 4306 regulate boilers, steam generators and 

process heaters but specifically excludes furnaces. Furnaces typically use a 

direct-fired heater where the material being heated directly contacts the exhaust 

from the burner. This contact can lead to the heater exhaust becoming 

contaminated with PM10 and VOC released from the heated products. 

Significant NOx emissions can also result from combustion of fuel for the 

heaters. 
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Possible control measures include clean burning fuel and low-NOx burners for 

the heaters and catalytic particulate filters to reduce fugitive VOC and PM10 from 

the exhaust stream. 

4.2.4.11 Further Study Project K: New Rule (Brandy Production) 

REASON FOR CONTROL MEASURE: Brandy production is a potentially 

significant source of VOC emissions. New control measures could be designed 

to reduce VOC emissions created during the production of brandy, including 

distillation, aging and bottling. 

AFFECTED SOURCES: The California Department of Alcoholic Beverage 

Control (ABC) maintains a database of all facilities permitted to produce alcoholic 

beverages in California. The database contains facility specific information 

covering permitted production volumes and licensed operation of alcohol stills. 

DESCRIPTION: Brandy production is not currently regulated by the District 

permitting process or addressed by a prohibitory rule. VOC emissions in brandy 

production are created during distillation, aging, and bottling. Brandy is typically 

aged for 2 to 10 years in oak barrels and this is considered the largest source of 

VOC emissions from this process. 

Emission controls (other than process refrigeration) are not currently being used 

during the production of wines. Reductions of VOC could be achieved by 

equipping distillation equipment, storage facilities, and processing areas with 

vapor collection and control systems, carbon adsorption, water scrubbers, 

catalytic incineration, condensation, and additional temperature control, as 

appropriate. 

4.2.5 Reasonably Available Control Technologies (RACT) 

Section 172(c)(1) of the federal Clean Air Act requires nonattainment plans to: 

“provide for the implementation of all reasonably available control measures as 

expeditiously as practical (including such reductions in emissions from existing 

sources in the area as may be obtained through the adoption, at a minimum, of 

reasonably available control technology) and shall provide for attainment of the 

national primary ambient air quality standards.” 

For areas designated as extreme non-attainment status, RACT control measures 

would apply to sources with emissions greater than 10 tons per year. As a prior 

severe nonattainment area, the District already had RACT for sources greater 

than 25 tons. Therefore, staff only evaluated the existing permitted sources with 
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baseline inventories between 10 and 25 tons per year of NOx or VOC. Based 

upon this evaluation, the District identified the following RACT control measures: 

4.2.5.1 Dryers and Dehydrators 

NOx emissions from large industrial dryers are not currently addressed by 

existing rules but are scheduled for development in Table 4-1 as Control 

Measure I, Commercial Dryers. 

4.2.5.2 Flares 

NOx emissions from flares at major sources are addressed by Rule 4311 

(Flares). Sources emitting between 10 and 25 tons per year would become 

subject to this rule when the definition of "Major Source" is amended in Rule 

2201 (New and Modified Stationary Source Review). 

4.2.5.3 Jet Engine Test Cells 

NOx emissions from jet engine test cells are difficult to control through traditional 

means due to the high flow, low NOx concentration, and low temperature of the 

exhaust stream. A review of existing BACT clearinghouses failed to produce 

viable control measures. The emissions from the source located in the District 

will be limited by a Federal Operating Permit that is enforceable through Title V of 

the federal Clean Air Act. Given the lack of available controls and the federal 

enforceability of the existing limits, the District will monitor potential future 

controls for this category, but does not plan to schedule a control measure at this 

time. 

4.2.5.4 Fumigation - Agricultural Products 

The California Department of Pesticide Regulation has authority over field 

application of Methyl Bromide (MeBr) for soil fumigation. The District has 

authority over application of MeBr released from post-harvest fumigation of 

agricultural products. In 1999, the EPA has developed a schedule for the phaseout of MeBr in accordance with the 1987 Montreal Protocol. While some 

exceptions are currently being considered for critical uses, a critical use cap will 

significantly eliminate these emissions and negate the need for any rule-making 

action. 
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4.2.6 Clean Fuels or Advanced Control Technology 

Section 182(e)(3) of the federal Clean Air Act directs extreme nonattainment 

areas to require: 

"that each new, modified, and existing electric utility and industrial and 

commercial boiler which emits more than 25 tons per year of oxides of nitrogen - 

(A) burn as its primary fuel natural gas, methanol, or ethanol (or comparable 

low polluting fuel), or 

(B) use advanced technology (such as catalytic control technology or other 

comparably effective control methods) for reduction of emissions of 

nitrogen" 

District Rules 4305, 4306, and 4352 address NOx emission limits for the boilers 

in this category. 

Most of the boilers under Rules 4305 and 4306 are fired on natural gas and 

therefore satisfy the requirement of paragraph (A) above. 

Liquid-fuel fired boilers are also addressed by those rules and the applicable 

NOx emission limits satisfy the requirement of paragraph (B) above. 

Solid-fuel fired boilers are addressed by Rule 4352 and the applicable NOx 

emission limits satisfy the requirement of paragraph (B) above. 

Therefore, the District already complies with this requirement and there is no 

need to include additional control measures in this plan to satisfy the section of 

the federal Clean Air Act. 

4.3 FUTURE STUDY MEASURES 

The California Clean Air Act requires districts to develop ambient air quality 

standard attainment plans that consider “the full spectrum of emission sources 

and focus particular attention on reducing emissions from transportation and 

area-wide emission sources.” (Health and Safety Code, Section 40910). In 

particular, districts responsible for air basins designated as having “serious,” 

“severe,” or “extreme” air pollution, “shall, to the extent necessary to meet the 

requirements of the plan,...” include in their attainment plans “[m]easures to 

achieve the use of a significant number of low-emission motor vehicles by 

operators of motor vehicle fleets.” [Health and Safety Code section 40919(a)(4)]. 

Although ARB is responsible for setting vehicle emission standards, ARB and 

districts such as the SJVUAPCD have the authority to ensure that cleaner 

vehicles are employed. 
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Appendix F summarizes control measure concepts suggested by stakeholders 

during or after the first two sets of workshops held for this Extreme OADP. 

Control measures listed in Tables 4-1 and 4-2, as well as the ideas for future 

measures listed below, capture a number of these concepts. The District will 

consider these and other ideas for control measures to be used in the 

development of future ozone attainment demonstration plans. Section 4.3.1 

addresses mobile sources, Section 4.3.2 addresses other types of sources 

(particularly as suggested by stakeholders during public review of the Draft 

Extreme OADP—see Appendix H), and Section 4.3.3 describes ideas for nontraditional methods of reducing air pollution, termed “sustainable incentives.” 

4.3.1 Mobile Sources 

ARB is adopting or developing several mobile source rules. These rules address 

emissions from refuse haulers, urban transit vehicles, and other heavy duty 

vehicles; vehicle idling limits; diesel fuel sulfur limits; toxic emissions from 

transportation refrigeration units; and other similar measures. The District is not 

currently planning to pursue any enhanced requirements to the mobile source 

rules that ARB has adopted or is developing. 

Stakeholders have identified a number of potential non-traditional mobile source 

emission control measure ideas for future study. The District will investigate the 

feasibility of additional programs that reduce emissions from mobile sources. 

These measures would address sources commonly outside District jurisdiction, 

and thus would necessitate teaming with other agencies that have more direct 

authority over these sources. Several special programs have been suggested 

that could reduce mobile source emissions, including the following: 

• Gross emitters, both passenger and heavy-duty vehicles, can produce ten 

times the emissions of newer vehicles. An effective program for reducing 

emissions from this source category would have the following key elements: 

(1) a remote sensing program that identifies and targets only the grossemitting vehicles that are used on a regular basis; (2) adequate financial 

incentives to encourage retirement of the gross-emitting vehicle; and (3) use 

of a voucher (or similar system) to ensure that incentives can only be used to 

purchase a vehicle with lower emissions than the one being replaced. 

• Emissions from heavy-duty vehicles increase with higher operating speeds, 

so reductions of NOx, VOC, and diesel PM may be possible with stricter 

enforcement of the existing speed limits on public roads, highways and 

freeways. The District could work to develop funding sources for special CHP 

patrols along Highway 99 for increased enforcement of truck speed limits. 

• The ARB Heavy-duty Vehicle Inspections program for conducting roadside 

testing of heavy-duty vehicles primarily focuses on Highway 99 and Interstate 

5, and is very limited in scope due to current state budget problems. The 
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District could seek special funding to revitalize and strengthen this program to 

increase its geographic coverage and to include anti-smoke inspection; RPM 

recording; snap-acceleration test; visual inspection of emissions, and fuel 

testing to ensure use of California diesel. These roadside inspections can 

identify gross-polluters that may otherwise escape the normal inspection 

requirements. This area of further study is also of particular interest given the 

greater potential for foreign-registered trucks to pass through the SJVAB in 

light of the June 2004 U.S. Supreme Court decision regarding the North 

American Free Trade Agreement; foreign-registered trucks may have 

substantially different emissions profiles than U.S. registered trucks. 

• Through-truck traffic on Highway 99 can produce significant emissions along 

the most densely populated portion of the Valley. Re-designation of Highway 

99 between Manteca and Wheeler Ridge as a “no through-truck route" and 

designating Interstate 5 as sole truck route for through-Valley truck traffic 

would mitigate the impact of the trucks without unduly impacting the interstate 

commerce. This measure would also reduce congestion for local traffic, 

decrease intra-valley travel time, and reduce the associated emissions. 

• Heavy-duty vehicles may idle at truck stops for hours at a time to run 

refrigerators and provide power for operator air conditioning during meal 

breaks and rest stops. Emissions from idling trucks at truck stops can be 

reduced with alternative power systems such as auxiliary power units, thermal 

storage systems, and truck stop electrification. Each of these supplies power 

and other needed amenities to truck stop customers but with a lower 

emissions burden than idling each truck’s diesel engine. 

• ARB’s emission reduction program for mobile sources is highly dependent on 

fleet turnover. Fleet turnover could be enhanced by adjusting the California 

vehicle license fee and registration fee such that as vehicles age, they 

become more expensive to register. New vehicles, which at any given time 

are the lowest emitters, would be the least expensive to register. 

Consideration could also be given to giving further fee reductions to vehicles 

with emissions ratings of ATPZEV or better that are registered and used in 

the state’s dirtiest air basins. 

4.3.2 Other Sources 

Stakeholders have suggested a number of control measure ideas that do not 

involve the mobile source emission category. Principal among these are ideas 

for using the vegetation in and around urban areas to help manage air quality 

with the recognition that such vegetation can function as both a source of ozone 

precursor emissions as well as a sink for ozone. Major ideas suggested were: 

• Study the role of urban landscaping and agriculture in the SJVAB’s air 

quality, perhaps through CCOS. The study should include the concept of 
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vegetative buffer zones, especially hardwood forests, around urban areas 

experiencing high ozone levels. 

• Create urban tree planting guidelines for highways, parks and private 

development that emphasize air quality improvements (e.g., areas with 

high asthma rates would encourage low pollen, low allergenic species); 

• Develop an education program for agencies, schools, the public, nurseries 

and landscapers that provides information on 

o biogenic emissions from various plants used in urban landscapes, 

o the role of these plants in contributing to ozone production, and 

o equipment emissions from maintaining various types of landscapes 

(e.g., a lawn requires more cutting and leaf blowing than an area 

planted with groundcovers). 

• Identify sources of funding for public agencies to make landscape 

changes that improve ozone air quality. 

4.3.3 Sustainable Incentives 

Alternative approaches for reducing emissions, as discussed in the following 

paragraphs, have been suggested for consideration by a number of parties. The 

District is considering how to work these ideas for alternative approaches into its 

control strategy where feasible. 

To promote the implementation of practices that reduce air pollution from a 

variety of sources, including exempt sources, industry suggested the 

development of sustainable incentives. The concept of sustainable incentives 

includes financial measures, programs, and/or prohibitory rule alternative 

compliance plans that provide an economic mechanism to fund air pollution 

reduction measures. Sustainable incentives may be in the form of private 

industry and/or foundation grants, federal and/or state government grants, tax 

credits, prohibitory rule incentives, and other programs. 

The concept of sustainable incentives is based upon existing programs such as 

the federal farm bill’s “Environmental Quality Incentives Program (EQIP); the 

State’s Carl Moyer Program; the District’s Heavy-Duty Program (see next 

section), and other programs that offset the implementation cost of pollution 

reduction measures. Many of these existing programs operate within the 

framework of a partnership involving private industry, the public, and public 

agencies. 

As proposed by industry, the concept of sustainable incentives revolves around a 

market-based approach to pollution reduction using measures that are 

economically sound and that are supported by scientific research. Basic 

concepts could include 
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• Local air pollution control/air quality management districts, 

EPA, and ARB would assist local municipalities and other 

public agencies in acquiring additional funding. The funding 

would be used to implement emission reductions; expand 

existing incentive programs, such as EQIP and Carl Moyer; 

and offset mitigation cost needs of the local transportation 

agencies and communities. Such funding could be 

generated from either governmental sources in the form of 

grants or from industrial sources in the form of alternative 

compliance fees or penalties. 

• These regulatory agencies would consider suggestions for 

alternative emission reduction programs that generate 

equivalent emissions reductions to those identified in 

prohibitory rules, but are less costly to implement. Such 

programs would obtain emission reductions by contributing 

to such programs as EQIP, by reducing onsite emissions, 

or by allowing the use of valid emissions reductions from 

secondary sources located in the immediate vicinity of 

those sources seeking the use of the alternative emission 

reductions. 

4.4 DISTRICT INCENTIVE PROGRAMS 

The District has operated incentive programs since 1992. The programs have 

expanded in funding and increased in sophistication over the years. Incentive 

program funding has been derived from several sources. Current programs use a 

combination of state and local funds including ARB's Carl Moyer Program, San 

Joaquin Valley Emergency Clean Air Attainment Program (VECAP) funds, State 

Peaker Power Plant Offset (State ERC) funds, and District Department of Motor 

Vehicles Surcharge Fees (DMV Fees). Of these funding sources, only DMV fees 

are under the sole control of the District. The District has achieved significant, 

cost-effective emission reductions from a variety of grant programs. The District 

has awarded over $80 million to projects that have resulted in over 33 tons of 

lifetime emission reductions at a cost-effectiveness of approximately $6,500/ton. 

The District is currently operating two programs aimed at reducing ozone 

precursor emissions: the Heavy-Duty Engine Emission Reduction Incentive 

Program (Heavy-Duty Program) and the Electric Lawnmower Incentives 

Program. Each of these is discussed below, followed by a discussion of future 

programs 
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4.4.1 Heavy-Duty Engine Emission Reduction Incentive Program 

The Heavy-Duty Engine Emission Reduction Incentive Program (Heavy-Duty 

Program) is by far the District's largest and most successful incentive program. 

The Heavy-Duty Program accepts applications for a wide variety of engines that 

power vehicles or equipment. Heavy-duty trucks, buses, and heavy off-road 

engines are significant sources of nitrogen oxides (NOx) emissions within the 

Valley. Although the District does not have the authority to regulate vehicle 

tailpipe emissions, it can provide monetary incentives to reduce emission from 

these sources. It provides funding for new purchases, engine re-powering, or 

retrofits. Emission reductions are obtained when the project applicant purchases 

vehicles and engines that are cleaner than required by current emission 

standards or installs an emission certified retrofit kit on an existing engine. The 

District pays the differential cost of purchasing the lower emitting technology 

compared to conventional technology up to a cost-effectiveness cap of $13,600 

per ton for NOx. The program is primarily aimed at NOx reductions, but many 

projects also achieve fine particulate matter (PM 10) reductions. 

The first projects that were funded under the Heavy-Duty Program began 

operating in 1998. Since then, additional funds have been allocated each year to 

the program and additional projects have become operational. Project life varies 

from 7 to 20 years depending on the application. The average project life is 7.7 

years based on the mix of projects received to date. 

SIP submittals for the SJVAB typically have not included emission reductions 

from the Heavy-Duty Program. However, the 2003 PM10 Plan did include 

reductions in the mobile source category from the Heavy Duty Engine incentive 

program. This Extreme OADP uses a similar approach for incentive-based 

emissions reductions. 

4.4.2 Electric Lawnmower Incentives 

The District held lawnmower exchanges in 2001 and 2002. A total of 2260 

electric, rechargeable mowers were distributed at a 50 percent discount to 

residents in Bakersfield, Fresno, Merced, Modesto, Stockton and Visalia. The 

events were made possible through support and sponsorship from Black and 

Decker; the California Air Resources Board; California Integrated Waste 

Management Board; Fresno, Merced, Stanislaus and Tulare counties; and the 

cities of Bakersfield, Fresno and Modesto. For 2004, the District funding 

provided similar incentives in the form of discount coupons for electric and pushtype lawn mowers; 327 mowers were sold in 2004 under the coupon program. 
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4.4.3 Future Programs 

The Mobile Source Emission Reduction Incentive Program (MSIP) is the most 

developed of the future programs. Although not yet approved by the Governing 

Board as of July 2004, MSIP provides incentives for specific projects that will 

reduce motor vehicle emissions within the District. The purpose of the MSIP is to 

assist the District in attaining the requirements of the California Clean Air Act. 

This is accomplished by allocating funds to cost-effective projects that have the 

greatest motor vehicle emission reductions, thereby creating long-term air quality 

benefits for the San Joaquin Valley. All projects must have a direct air quality 

benefit to the District. Any portion of a project that does not directly benefit the 

District within its boundaries will not be allowed for funding or in calculating 

emission reductions. Principal MSIP components that are envisioned at this time 

include the Light- and Medium-Duty Vehicle Component, the E-Mobility 

(Telecommunications) Component, the Bicycle Infrastructure Component, the 

Public Transportation and Commuter Vanpool Subsidy Component, and the 

Alternative Fuel Vehicle Mechanic Training Component. 

4.5 PUBLIC EDUCATION 

Engaging the public in efforts to reduce emissions is a key element of the ozone 

attainment demonstration strategy. Education increases public support for new 

and controversial regulations. Helping people understand the complex issues 

underlying the ozone problem further improves this support. There are many 

actions that individuals can undertake to reduce emissions that cause ozone. 

When members of the public are aware that they can make a difference and are 

convinced that the problem is real, many people will change their behavior in a 

positive way. 

The District's educational program has expanded and evolved over the years. It 

uses a variety of media and techniques to ensure the widest possible 

dissemination of air quality information. It uses direct marketing approaches with 

traditional media including television, radio, and print. It networks with other 

agencies, educational institutions, organizations, industry groups, and the news 

media in educational efforts. It produces educational materials, such as videos, 

brochures, and fact sheets that provide focused information to targeted 

audiences. 

While this section of the Extreme OADP does not specify emissions reductions 

that can be used for attainment demonstrations or rate of progress 

demonstrations, it is a very important component of the District’s overall air 

quality management program. The following sections describe key elements of 

the District’s Public Education program that help reduce emissions. 
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4.5.1 Outreach Program

The District’s outreach program contains traditional approaches and approaches 

that are unique to the SJVAB. An overview of the District’s program is provided 

below. 

Spare the Air - The District’s Spare the Air Program is a voluntary program that 

encourages businesses and residents to avoid pollution-producing activities on 

days when high ozone levels are expected, primarily during the summer season. 

In addition to extensive multi-media English and Spanish language campaigns, 

information regarding the program is communicated to employers through 

comprehensive employer packets (bilingual), and Spare the Air fairs throughout 

the Valley. The District notifies participating employers and the public, via faxes, 

news broadcasts, and radio announcements, when it is predicted that the ozone 

standard will be exceeded the following day. The public is asked to postpone or 

avoid such activities as using oil-based paints, solvents, aerosol spray cans, and 

gasoline-powered lawn equipment, and avoid making unnecessary vehicle trips. 

Educational Videos – The District is working on development of educational 

videos for improving air quality. A recent project focuses on topics such as why 

we have air quality problems in the SJVAB, where the pollution comes from, the 

impact of air pollution on public health, agricultural crops and natural vegetation, 

and District Rules and Regulations. The District has produced three other 

educational videos; two of these videos describe commute alternatives, and the 

third explains the District’s Spare the Air program. 

Valleywide Public Service Announcements and Paid Advertising - Public Service 

Announcements (PSAs) have been created for use on television and radio 

stations throughout the SJVAB. These short PSAs (30-60 second) remind the 

public to use public transportation, share rides to work (rideshare), walk to lunch, 

buy nonvolatile consumer products, etc., as their contribution to improving air 

quality. Also, through enhanced public outreach, the District has strengthened its 

Smoking Vehicle Program, which encourages the public to report vehicles with 

excessive visible emissions. An extensive public outreach campaign also 

informs SJVAB residents about the Spare the Air program. 

Pollutant Standard Index (PSI) Predictions - Daily PSI predictions are faxed 

directly to local television, radio, and newspaper media to educate the public 

about air quality and advise them of days with poor air quality so that activities 

can be modified. The widest possible distribution of no burn day information is 

critical to obtaining a high level of compliance. The District has a staff 

meteorologist to provide more accurate air quality predictions for the SJVAB. 

Forecasts now use more detailed information specific to the local daily conditions 

in the SJVAB. 
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Air Quality Symposium - The District holds the Air Quality Symposium about 

every other year. A wide variety of organizations, businesses and individuals 

participate. Past versions of the symposium, have drawn over 200 attendees. 

The events include keynote speakers, general sessions, breakout sessions on 

topics of special interest, and air quality exhibits. The 2004 Symposium is 

scheduled for September 29-30, 2004 in Bakersfield, and the theme is exploring 

unique solutions to the clean air challenges that face us all. 

4.5.2 District Publications 

Information Pamphlets – The District continues to develop new and updated 

brochures to address air quality issues in the SJVAB. Current brochures include 

the following: Automotive Checkbook (vehicle maintenance record book), the 

Smoking Vehicle Program, and Air Pollution Health Effects. 

Newsletter – The Valley Air News is a monthly publication of the District widely 

distributed throughout the SJVAB. The newsletter highlights current activities of 

the District, summarizes Governing Board actions, highlights commendable 

efforts by Valley businesses in reducing air pollution beyond what is required, 

and discusses other relevant air quality issues. 

4.5.3 Youth Education 

As part of the youth education program, schools are able to contact the District office 

to request classroom presentations on a variety of topics. Children of the SJVAB 

also have the opportunity to become a member of the Clean Air Kids Club and 

have newsletters and other information sent directly to their homes regarding air 

pollution and what they can do to help prevent it. 

Environmental curriculum and special activities have been provided to primary 

schools since the fall of 2000. In 2004, the District will expand the environmental 

curriculum to include a component for middle and high school students. The 

District is also participating in a growing program that involves the flying of flags 

at schools to indicate the air quality status for a given day during the school year. 
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4.5.4 Events/Activities 

The District works with local groups such as the American Lung Association and 

rideshare agencies to promote annual events that reinforce clean air activities, such 

as the following: 

Event Lead Organization Time of Year

Earth Day Local Earth Day Sponsors April 

Clean Air Month American Lung Association May 

Rideshare Week Local Rideshare Committee October 

Car Care Month Calif. State Automobile Assn. 

and American Lung Association 

October 

A wide variety of local activities are conducted by organizations and agencies 

throughout the Valley. Such activities include the annual Clean Air Rally sponsored 

by Project Clean Air and the annual Conservation Fair by the County of San 

Joaquin. The District participates in many of these events and encourages activities 

that increase public awareness of air pollution and public participation in programs 

or activities to reduce air pollution. The District has scheduled a Community Day for 

October 2004 as a way for members of the community to visit the District’s Central 

Office, learn how the District operates, and learn how to effectively participate in the 

public process for improving air quality. 

4.6 OVERVIEW OF REGIONAL TPA RACM 

4.6.1 Introduction 

The San Joaquin Valley is a single air quality nonattainment area containing 

eight Metropolitan Planning Organizations (MPOs), which are also regional 

transportation planning agencies (RTPAs or TPAs) within the Valley. The Valley 

is home to many diverse communities containing predominantly rural as well as 

predominantly urban areas peopled by individuals from many different parts of 

the world. This overview describes the process led by the Valley RTPAs to 

identify and implement potentially reasonably available control measures 

(RACM) affecting local transportation activity. 

Each RTPA covers a county with numerous cities, public interest groups, transit 

agencies, and a ridesharing agency in some cases. Collectively, the Valley 

RTPAs have conducted a thorough RACM process that addresses the entire San 

Joaquin Valley. In order to ensure thoroughness, the RTPAs have coordinated 

with each other through a Valleywide committee that meets biweekly/monthly to 

discuss their individual progress on RACM, obtain input and feedback from the 

other agencies on the committee, and share other relevant information. They 

also provide documentation regarding the local government control measures 

and meetings held at the county level to the group through a RACM website. 
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Another feature of the coordination is development of a common format for 

providing documentation on the RACM process. The Valleywide committee is 

composed of each RTPA, the District, Caltrans, ARB, EPA, the Federal Highway 

Administration, and the Federal Transit Administration. This committee provides 

regular opportunity for the eight Valley RTPAs to obtain input from each other 

and the other agencies involved in developing the Extreme OADP for the Valley. 

The Valley RTPAs have limited legal authority to implement emission reduction 

measures. However, their status as regional transportation planning agencies 

places them in a position to help coordinate and facilitate consensus among their 

member jurisdictions, which do have authority to implement some measures. 

Therefore, the RTPAs led a process to identify and evaluate potential measures 

affecting local transportation activity. The Valley RTPAs recognize the 

importance of clean air for their communities and are doing their part in helping to 

find ways to improve the air. The RTPA role in this RACM process is to lead 

local agencies in (1) the identification and implementation process for measures 

that may reduce ozone precursor emissions associated with local transportation 

activity that may be implemented at the local level; and (2) documenting reasons 

for not implementing measures that are not economically or technically feasible. 

The individual jurisdictions within each county have primary control of funding and 

implementation for local government control measures associated with 

transportation. However, since the Valley RTPAs are all part of one nonattainment 

area they have coordinated their process together in order to share ideas offered by 

the public and jurisdictions to provide consistency for the entire process including 

approaches to documentation. Figure 4-1 gives an overview of the local 

government control measure process used for this plan. 

4.6.2 Overview of Existing Measures

The Valley RTPAs and their member agencies have long been involved in 

examining ways to contribute to improvements in air quality through 

implementation of local measures as well as provision of funding for measures 

being implemented by the Air District. In general, the existing control measures 

include transit improvements, ridesharing and ride-matching programs, 

telecommuting, compressed workweeks, bicycle programs, pedestrian programs 

(such as street design to encourage walking), traffic flow improvements, and 

numerous land-use programs. In addition, Valley RTPAs have a history of 

supporting mobile source reduction incentives. Nearly all counties in the Valley 

have also allocated funding to alternative fuel projects. Money has been 

allocated to local school agencies for clean fuels infrastructure, as well as to the 

Air District’s Heavy-Duty Motor Vehicle Emission Reduction Program for clean 

fuels municipal or public fleet purchases. 
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In addition, since 1992 the Valley RTPAs have maintained a Work Program 

agreement with the Air District that includes elements related to exploration of 

local government control measures and ongoing collaboration on air quality 

planning activities. The Valley RTPAs are legal entities that allocate CMAQ 

monies. Air quality and emissions benefits play a key role in the ranking process 

of each RTPA’s selection of CMAQ projects. 

It is important to note that the Valley RTPAs and member jurisdictions completed 

a process to identify and implement Reasonably Available Control Measures 

(RACM) for the Severe Area Ozone Plan in April 2002. Although this Plan was 

never finalized, the control measures were incorporated in the Amended 2002 

and 2005 Rate of Progress Plan for San Joaquin Valley Ozone. The control 

measures evaluated focused on the specific transportation control measures 

listed in Section 108(f) of the Clean Air Act. Collectively, local governments 

adopted a broad range of commitments to implement control measures. These 

extensive commitments demonstrate the level of effort that is being made by the 

local jurisdictions to reduce emissions and to improve air quality. 

The resolutions adopted by the respective entities to commit to implement local 

government control measures are included in the Regional Transportation 

Planning Agency Commitments for Implementation Document, April 2002. The 

document is available for public review at the central San Joaquin Valley Unified 

APCD office located in Fresno and was included in the Amended 2002 and 2005 

Rate of Progress Plan for San Joaquin Valley Ozone. 
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Figure 4-1 

OVERVIEW OF LOCAL GOVERNMENT CONTROL MEASURE PROCESS

FOR THE EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN

STEP 1: 

RTPAs request member jurisdictions to adopt RACM 

resolutions in November 2003. Transmit model resolution 

package, including existing RACM commitments to all local 

jurisdictions. 

STEP 2: 

RTPAs and member jurisdictions adopt resolutions in 

accordance with the model resolution package and submit to 

RTPAs for compilation. 

Each implementing agency passes resolution describing the 

measures to be implemented 

• Measure description 

• Legal Authority for implementation 

• Funding for measures 

• Enforcement 

Each implementing agency also describes reasons for 

rejecting any measures 

• Technologically or economically 

infeasible 

• Otherwise unreasonable 

STEP 3: 

Air Quality Consultant prepares Commitment document and 

submits to the Air District. 
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4.6.3 Suggested measures

In order to maximize input from individual cities and other jurisdictions, as well as 

the public, the RTPA-level RACM process has been conducted on an individual 

county level, with Valley-wide coordination provided through a consultant. Each 

RTPA conducted the RACM process in 2003/2004 in a manner consistent with 

their individual committee structures and public processes. 

This RACM process used the previous RACM process (dated April 2002) to the 

extent possible. The Suggested Measures that were considered at that time 

included existing local government control measures in the SJVAB and example 

control measures in other ozone nonattainment areas. The list was organized by 

category using the specific transportation control measures listed in Section 

108(f) of the Clean Air Act. 

It is important to note that the only other Extreme Ozone Nonattainment Area in 

the country is the South Coast Air Basin (SCAB) in California. RTPA staff and 

consultants reviewed the transportation control measures included in the SCAB 

2003 Air Quality Management Plan to see if the South Coast Air Quality 

Management District adopted any new measures not previously considered in 

the SJVAB. Inspection of the SCAB 2003 Air Quality Management Plan

determined that the list of control measures for consideration was taken from the 

Regional Transportation Planning Agency Commitments for Implementation 

Document, April 2002 (this is the description of commitments developed for the 

Amended 2002 and 2005 Rate of Progress Plan for San Joaquin Valley Ozone). 

It was determined that the South Coast Air Quality Management District added 

no new measures to this list for consideration. Therefore, no new measures 

were available to the San Joaquin Valley for consideration in the Extreme Ozone 

Attainment Demonstration Plan RACM process. 

The summary of commitments and submitted resolutions (with existing 

commitments and reasoned justification) were transmitted to each jurisdiction to 

be used as the starting point. Each measure listed on the Summary of 

Commitments should either have a commitment or reasoned justification for each 

implementing entity. 

In general, the local jurisdictions reviewed the adopted resolution package to 

determine if existing commitments could be strengthened. Examples of 

strengthening included extending the implementation schedule for the measure 

through 2010 or including additional financial resources. If the existing 

commitment is not ongoing (e.g., implementation expires in 2005) and/or cannot 

be strengthened, then reasoned justification should have been developed. 

In addition, the local jurisdictions reviewed the adopted resolution package to 

determine if any measures that were previously found not feasible are now 
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feasible for implementation. If so, a new commitment for implementation should 

have been developed. If not, the reasoned justification should have been 

updated accordingly. 

4.6.4 Adopted measures 

Each RTPA member jurisdiction has identified measures that are technologically 

and economically feasible for implementation by that entity. The appropriate 

governing body has adopted formal resolutions to commit to implement control 

measures. If a jurisdiction decided that a measure was not feasible for 

implementation, the jurisdiction documented the “reasoned justification” for nonimplementation, as required by EPA for the RACM process. This justification is 

based on technological or economic infeasibility. 

The resolutions adopted by the respective entities to commit to implement local 

government control measures are included in the corresponding Regional 

Transportation Planning Agency Commitments for Implementation Document

(Volumes 4 and 5, dated March 2004) [Appendix C (uncirculated) to this Plan]. 

The document is available for public review at the District’s office in Fresno, the 

ARB’s office in Sacramento, and EPA’s Region 9 office in San Francisco. 

Collectively, a broad range of commitments to implement control measures were 

adopted by the local governments. These extensive commitments demonstrate 

the level of effort that is being made to improve air quality. It is important to note 

that specific emissions reduction targets for each of the measures have not been 

included in this Extreme OADP. However, in many cases these commitments 

will produce emission reductions above and beyond what has been quantified in 

the Extreme OADP. These adopted control measures represent additional 

efforts by the local jurisdictions to reduce emissions and improve air quality. 

4.6.5 Public Participation 

The 1992 Transportation & Air Quality Planning Guidelines, which address public 

participation, are issued jointly by the U.S. Environmental Protection Agency and 

the U.S. Department of Transportation. These guidelines are designed to 

encourage an effective public participation program for the development and 

implementation of the State Implementation Plan (SIP). According to the 

guidelines, the objectives of the public participation program should be to: 

1. Promote public awareness of the air pollution problem, the SIP revision 

process, and the effects of various transportation control measures; 

2. Encourage active participation from a variety of interest groups in the 

plan preparation process; 

3. Promote public understanding and agreement on the transportation 

control measures necessary to improve air quality; 
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4. Provide for the identification of both interested and affected 

constituencies; 

5. Ensure that the agencies and elected officials are responsive to these 

constituencies; and 

6. Encourage a spirit of openness and trust among elected officials, 

agencies, and the public. 

Public Involvement Process for Transportation and Air Quality

Passage of the Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) 

expanded emphasis on public involvement in the metropolitan planning process. 

The intent of the public involvement provisions in ISTEA is to increase public 

awareness and involvement in transportation planning and programming. ISTEA 

requires that the metropolitan planning organization provide citizens, affected 

public agencies, representatives of transportation agencies, private providers of 

transportation and other interested parties a reasonable opportunity to comment 

on proposed transportation plans and programs. These provisions have been 

continued under the Transportation Equity Act for the 21st Century (TEA-21). 

Title VI Considerations

Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of 

race, color and national origin by recipients and sub-recipients of federal funds 

and prohibits exclusion from participation, denial of benefits, or being subjected 

to discrimination under any program or activity receiving federal financial 

assistance. Additional federal and state laws and directives prohibit 

discrimination on the basis of age, gender, handicap or disability. The Executive 

Order of 1994 on Environmental Justice encourages consideration of 

environmental justice concerns, especially the impact of programs and activities 

on low-income and minority populations. The Act and its related laws and 

directives hereinafter are called, collectively, Title VI. 

Decision Making Structure and Public Participation

The San Joaquin Valley contains eight counties. The transportation planning 

process in each county is conducted by an MPO or RTPA. Each transportation 

planning agency performs planning functions in accordance with applicable 

transportation and air quality planning guidelines and Title VI considerations. 

These eight agencies are leading the process to identify, evaluate and implement 

potential RACM measures pertaining to the transportation sector that may be 

implemented on a local level. 

Workshops

The District conducted public workshops on developing an Ozone Attainment 

Demonstration Plan on July 23, 2003 and on January 6 and 7, 2004. The July 
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2003 workshop presented an overview of the air quality plan development 

process. One public comment addressed the RACM process, and asked if 

RTPAs would revisit prior RACM commitments for the Extreme OADP. The 

January 2004 Workshop include a presentation addressing the status of the TPA 

RACM process. No public comments were received on the RTPA RACM 

process from the January workshops. The District also conducted public 

workshops on the Draft Extreme OADP on August 12 and 13, 2004. The 

presentation on control measures at these workshops included a summary of the 

completed RACM process. No public comments were received on the completed 

RACM process and corresponding commitment documents. 

The SJVAB RTPAs have developed a website (located at 

http://www.fresnocog.org) to serve as a resource for each county, as well as to 

provide the public with detailed information on the RACM process. This page 

contains relevant RACM guidance documents, agendas, and minutes for the 

biweekly/monthly RTPA meetings coordinating the RACM process. 

4.7 STATE EMISSION REDUCTIONS FOR THE SJVAB1

4.7.1 Introduction 

Motor vehicles and equipment under State and federal jurisdiction, while 

responsible for about 55 percent of ozone-forming gases in the SJVAB in 2004, 

are also contributing the majority of the emission reductions needed for 

attainment. Adopted State and federal regulations for cleaner engines and fuels 

are driving down Valley emissions of ozone precursors – reactive organic gases 

(ROG, also referred to as VOC elsewhere in this Plan) and oxides of nitrogen 

(NOx) – by over 225 tons per day (tpd), or over 35 percent, between 2000 and 

2010. 

To provide additional statewide emission reductions needed to achieve the 

federal health-based air quality standards, ARB adopted the 2003 State and 

Federal Strategy for the California State Implementation Plan (Statewide 

Strategy) on October 23, 2003. ARB submitted the Statewide Strategy to EPA 

for approval as a revision to the California SIP on January 4, 2004. 

The Statewide Strategy identifies the Board’s near-term regulatory agenda to 

reduce ozone and particulate matter by developing and adopting defined new 

measures from 2002 through 2009, with implementation prior to the 2010 ozone 

season. It includes commitments for the Board to consider 19 specific statewide 

measures, plus the Bureau of Automotive Repair’s planned improvements to the 

 

1

 ARB staff prepared this section, and the District did not change the text other than to format it 

for consistency with the remainder of the Extreme OADP and to conduct minor editing. 
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Smog Check program and the continuation of the Department of Pesticide 

Regulation’s approved SIP obligation2 to reduce volatile emissions from 

pesticides. The Statewide Strategy includes a process to identify longer-term 

solutions for additional reductions from sources under State/federal/local control. 

The defined control measures in the Statewide Strategy cover on-road vehicles, 

off-road equipment, ports and harbor-craft, fuels and refueling, and consumer 

products. Measures to clean up the existing fleet of mobile sources complement 

lower emission standards for new engines and consumer products. Other 

measures would reduce vapor emissions from gasoline storage and refueling. 

These defined measures are listed in Table 4-3. The Statewide Strategy, which 

includes detailed descriptions of each of the measures, is available at 

http://www.arb.ca.gov/planning/sip/stfed03/stfed03.htm. 

The Statewide Strategy discusses the need to obtain continued funding for the 

Carl Moyer incentive program to supplement regulatory actions requiring clean 

up of the existing fleet of diesel vehicles and equipment. New State funding for 

the Moyer program would enable additional clean engine projects and provide 

emission reductions to be credited towards the State’s obligation. 

When adopting the Statewide Strategy, the Board delegated to the ARB 

Executive Officer the responsibility to quantify the appropriate benefits from the 

near-term measures for other areas that need further reductions in the 2010 

timeframe and to reflect these benefits in the regional SIPs. ARB staff estimates 

that the near-term measures in the Statewide Strategy will provide 15 tpd ROG 

and 20 tpd NOx in the San Joaquin Valley in 2010. ARB previously committed to 

achieve 10 tpd of new NOx reductions as part of the PM10 Plan, which is a 

subset of the 20 tpd NOx discussed here. 

4.7.2 Current Implementation Status 

ARB has already started to implement the Statewide Strategy. Several of the 

measures in the Strategy are comprehensive approaches for the source 

category, encompassing multiple rulemakings or other actions that will contribute 

to the total reductions expected. As of July 1, 2004, ARB has taken action on the 

following measures: 

• The low sulfur diesel fuel regulation adopted in July 2003 fulfills SIP measure 

FUEL-2.

• The small off-road engine emission standards adopted in September 2003 

fulfill SIP measures SMALL OFF-RD-1 and SMALL OFF-RD-2.

 

2

 40 CFR Part 52, Federal Register, January 8, 1997, pages 1150-1187. 
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• The particulate matter control measure for diesel-powered solid waste 

collection vehicles adopted September 2003 fulfills part of SIP measure ONRD HVY DUTY-3. 

• The voluntary emission control software upgrade program for diesel trucks 

approved in March 2004 fulfills part of SIP measure ON-RD HVY DUTY-3. This 

voluntary measure includes a regulatory backstop to ensure that the 

anticipated emission reductions occur by 2010. 

• The engine manufacturer diagnostics requirements for new diesel trucks 

adopted in May 2004 fulfill part of SIP measure ON-RD HVY DUTY-3. 

• The consumer products regulation adopted in June 2004 fulfill SIP measure 

CONS-1. 

• By 2004, ARB had begun implementing an expanded community-based 

inspection program for diesel trucks and buses, fulfilling SIP measure ON-RD 

HVY DUTY-1. 

In addition to these defined SIP measures, ARB adopted three controls for diesel 

stationary engines, portable engines, and transportation refrigeration units in 

February 2004 that will contribute to meeting the State’s obligations. 

4.7.3 ARB Commitments for Extreme OADP for SJVAB 

ARB commits to adopt and implement measures to achieve, at a minimum, 15 

tpd ROG and 20 tpd NOx emission reductions in the San Joaquin Valley Air 

Basin by the 2010 ozone season. ARB will adopt measures to achieve these 

reductions between 2002—2009. ARB may meet this commitment by adopting 

one or more of the control measures in Table 4-3, by adopting one or more 

alternative control measures, or by implementing incentive program(s), so long 

as the aggregate emission reduction commitment is achieved. 
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Table 4-3. Defined State Measures from the 2003 Statewide Strategy 

Strategy 

(Agency) Name 

LT/MED-DUTY-1 

(ARB) 

Replace or Upgrade Emission Control Systems on Existing Passenger 

Vehicles 

LT/MED-DUTY-2 

(BAR) 

Improve Smog Check to Reduce Emissions from Existing Passenger & 

Cargo Vehicles 

ON-RD HVY DUTY-1 

(ARB) 

Augment Truck and Bus Highway Inspections with Community-Based 

Inspections 

ON-RD HVY DUTY-2 

(ARB) Capture and Control Vapors from Gasoline Cargo Tankers 

ON-RD HVY DUTY-3 

(ARB) Pursue Approaches to Clean Up the Existing and New Truck/Bus Fleet 

OFF-RD CI-1 

(ARB) 

Pursue Approaches to Clean Up the Existing Heavy-Duty Off-Road 

Equipment Fleet (Compression Ignition Engines) 

OFF-RD CI-2 

(ARB) 

Implement Registration and Inspection Program for Existing Off-Road 

Equipment to Detect Excess Emissions (Compression Ignition Engines) 

OFF-RD LSI-1 

(ARB) 

Set Lower Emission Standards for New Off-Road Gas Engines (Spark 

Ignited Engines 25 hp and Greater) 

OFF-RD LSI-2 

(ARB) 

Clean Up Existing Off-Road Gas Equipment Through Retrofit Controls 

and New Emission Standards (Spark-Ignition Engines 25 hp and 

Greater) 

SMALL OFF-RD-1 

(ARB) 

Set Lower Emission Standards for New Handheld Small Engines and 

Equipment (Spark Ignited Engines Under 25 hp such as Weed 

Trimmers, Leaf Blowers, and Chainsaws) 

SMALL OFF-RD-2 

(ARB) 

Set Lower Emission Standards for New Non-Handheld Small Engines 

and Equipment (Spark Ignited Engines Under 25 hp such as 

Lawnmowers) 

MARINE-1 

(ARB) 

Pursue Approaches to Clean Up the Existing Harbor Craft Fleet –

Cleaner Engines and Fuels 

MARINE-2 

(ARB) 

Pursue Approaches to Reduce Land-Based Port Emissions – 

Alternative Fuels, Cleaner Engines, Retrofit Controls, Electrification, 

Education Programs, Operational Controls 

FUEL-1 

(ARB) Set Additives Standards for Diesel Fuel to Control Engine Deposits 

FUEL-2 

(ARB) 

Set Low-Sulfur Standards for Diesel Fuel for Trucks/Buses, Off-Road 

Equipment, and Stationary Engines 

CONS-1 

(ARB) Set New Consumer Products Limits for 2006 

CONS-2 

(ARB) Set New Consumer Products Limits for 2008-2010 

FVR-1 

(ARB) Increase Recovery of Fuel Vapors from Aboveground Storage Tanks 

FVR-2 

(ARB) Recover Fuel Vapors from Gasoline Dispensing at Marinas 

FVR-3 

(ARB) Reduce Fuel Permeation Through Gasoline Dispenser Hoses 

PEST-1 

(DPR) Implement Existing Pesticide Strategy 
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4.8 Contingency Measures 

In general, contingency measures are control measures that go into effect, 

without further action by the State or the EPA Administrator, if planned emission 

controls fail to reach desired goals and targets. The FCAA defines two types of 

contingencies: (1) “specific measures to be undertaken if the area fails to make 

reasonable further progress, or to attain the national primary ambient air quality 

standard by the attainment date applicable under this part” [Title I, Part D, 

Section 179 (c)(9)] and (2) “specific measures to be undertaken if the area fails to 

meet any applicable milestone” [Title I, Part D, Section 182(c)(9)]. 

For the SJVAB, the concept of contingency measures is almost a moot point, for 

several reasons. First, areas such as the SJVAB that have been aggressively 

developing and implementing emission control measures over the past twenty 

years have already achieved most of the emissions reductions that are within the 

authority of the District to control and that are technically and economically 

feasible. In essence, the “low-hanging fruit” has already been picked. The 

likelihood of identifying new source categories under District authority to control, 

with attendant large emission reductions, is very small; any control measures 

beyond what have been identified in this Plan and within the District’s authority to 

implement are likely to have relatively small emissions reductions3

, and thus 

would be of minimal value as contingency measures. 

Second, prior to the next ROP milestone year for 1-hour ozone, the District will 

be developing three major air quality plans as SIP submittals that will control 

ozone precursor emissions: the 2006 PM10 Plan, the 2007 8-hour Ozone 

Attainment Demonstration Plan, and the 2008 PM2.5/Regional Haze Plan. The 

PM10 Plan is required in the final rule approving the 2003 PM10 Plan (69 FR 

30035), and the dates for submittal of the 8-hour Ozone Plan and the 

PM2.5/Regional Haze Plan are driven by EPA final rule language stating that 

plans are due three years after the effective date of designations (final rules not 

yet published). Each of these plans will develop additional control measures for 

ozone precursor emissions independent of this Extreme OADP, and thus will 

help in meeting ROP milestones and/or attainment goals for the federal 1-hour 

ozone standard if needed. The magnitude of reductions from control measures 

outside of the Extreme OADP is likely to exceed what is needed for the Extreme 

OADP for contingency measures.4

 Therefore, control measures developed for 

 

3

 Note that 14 of the 21 new District control measures listed in Table 4-1 of this Plan achieve 

reductions in ozone precursor emissions of 1.0 tons/day or less each for 2010; the total 2010 

reductions estimated from these 14 measures are about 5.8 tons/day compared to a total SJVAB 

2010 inventory of over 760 tons/day VOC and NOx combined. 

4

 For example, Reynolds, Blanchard and Ziman identify, through photochemical grid modeling, 

that NOx emissions must be reduced to about 10% of 1999 base case values to attain the 8-hour 

ozone standard in the SJVAB (“Understanding the Effectiveness of Precursor Reductions in 

Lowering 8-hr Ozone Concentrations, J. Air & Waste Man., 53: 195-205, February 2003). 
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these other plans serve the same function as contingency measures developed 

exclusively for the Extreme OADP. 

Third, EPA plans to revoke the federal 1-hour ozone standard before the next 1-

hour ROP milestone year for the SJVAB (2008), so the concept of contingency 

measures for federal 1-hour ozone standard requirements has diminished 

importance for the SJVAB (i.e., once the standard is revoked on June 15, 2005, 

EPA is not obligated to determine if an area has met the 1-hour standard by the 

area’s attainment date [40 CFR 51.905(e)]). 

Fourth, because the District is using “long-term measures” as part of its control 

strategy (see Section 4.8), it is required by the federal Clean Air Act to identify 

the contingency measures with reductions equal to those achieved by long-term 

measures no later than three years before implementation of proposed plan 

provisions [Section 182(e)(5) of the federal Clean Air Act]. For the District, this 

would involve not only identifying the long-term measures, but also redoing this 

Extreme OADP with whatever new information and tools are available related to 

the formation of ozone in the SJVAB. Thus, an additional planning requirement 

related to long-term measures provides another level of contingency in that the 

District will reevaluate the SJVAB 1-hour ozone attainment control strategy in 

20075

, well in advance of the next ROP milestone year (2008) or the attainment 

year (2010), and will add new measures as warranted by the updated 

assessment of ozone air quality at that time. This represents the functional 

equivalent of contingency measures as defined in the federal Clean Air Act. 

4.9 LONG-TERM MEASURES

Section 182(e)(5) of the Federal Clean Air Act allows EPA to approve provisions 

of an implementation plan for an Extreme Area that anticipate the development of 

new control techniques or improvement of existing control technologies, and an 

attainment demonstration based on such provisions. This provision of the federal 

Clean Air Act is dependent upon the state demonstrating that such provisions are 

not needed for incremental emissions reductions in the 1990-2000 time frame, 

and that the state has submitted enforceable commitments to develop and adopt 

contingency measures to be implemented if the anticipated future technologies 

do not achieve planned emission reductions. The state must submit these 

contingency measures to EPA no later than three years before proposed 

implementation of the plan provisions and approved or disapproved by EPA in 

accordance with Section 110 of the federal Clean Air Act. The contingency 

measures must be sufficient to achieve the emissions reductions needed for 

ROP or attainment demonstration purposes. For this Extreme OADP, ozone 

 

5

 If EPA revokes the 1-hour standard as planned, then the District would not update the 1-hour 

Extreme OADP in 2007, but instead would develop the 8-hour OADP for submittal in June 2007. 
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precursor emission reductions must be implemented no later than Spring 2010 to 

affect ozone levels in the attainment year of 2010. Thus the District would need 

to identify the Section 182(e)(5) contingency measures no later than spring of 

2007. 

Because of other ongoing and planned major SIP submittals, the District will fulfill 

the intent of the Section 182(e)(5) contingency measure requirements by 

identifying and implementing control measures above and beyond the Extreme 

OADP that will help attain the federal 1-hour ozone standards. The District has a 

legally enforceable commitment to revise the PM10 Plan and submit it to EPA by 

March 31, 2006 (69 FR 5431), and a regulatory requirement to submit an 8-hour 

OADP by June 15, 2007. Each of these would create ozone precursor emission 

reductions that are beyond the scope of this Extreme OADP by Spring 2007, and 

would thus meet the intent of contingency measures for Section 182(e)(5). For 

this Extreme OADP, the magnitude of the long-term measures is fairly small (a 

few tons/day each of VOC and NOx), and represents a small percent of the 2010 

inventory (see Section 5.6). Consequently, the control measures developed for 

the other plans mentioned above would easily cover the magnitude of reductions 

required for the long-term measures. 
❖
Chapter 5 – FUTURE OZONE AIR QUALITY
❖
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5 FUTURE OZONE AIR QUALITY 

5.1 INTRODUCTION AND SUMMARY 

Air quality models are used to predict ozone concentrations in future years. 

These models simulate the formation, transport, and removal of ozone from the 

lower atmosphere. The models are computer programs that estimate the 

contribution of ozone from emissions, winds, temperature, dispersion, removal, 

and chemical changes. 

Modelers used state of the art procedures to perform modeling for this plan. 

These procedures included: implementing a comprehensive measurement 

program, formulating and formatting model ready data inputs, running the model, 

comparing the model prediction to the base case, developing future year 

emissions scenarios, and running those with the model to predict future ozone 

levels. The goal of these modeling exercises is to formulate a controlled 

emissions scenario where ozone levels will achieve the federal 1-hour ozone 

standards. Appendix D provides more information on the modeling conducted for 

this Extreme OADP. 

5.2 PARTICIPANTS 

The use of ozone models for developing air quality plans requires both scientific 

and organizational procedures. For this plan, most of the development and initial 

implementation of the modeling was done under the direction of the San Joaquin 

Valley Study Agency. The Technical Committee of the San Joaquin Valley Study 

Agency, which consists of governmental and industry representatives from 

Central California (including the District, the Bay Area Air Quality Management 

District [BAAQMD], and the Sacramento Metropolitan Air Quality Management 

District [SMAQMD]), formulated and reviewed procedures for conducting the 

modeling for this plan. This body of expertise was supplemented by experienced 

and specialized consultants hired through the Study Agency to address specific 

questions related to SIP development. ARB developed modeling procedures for 

the future years and conducted the modeling. 

5.3 MODEL CHOICE 

Several photochemical models are available to assess the emissions reductions 

needed to achieve the one hour ozone NAAQS. These include the Community 

Multiscale Air Quality (CMAQ), SARMAP Air Quality Model (SAQM), and the 

Comprehensive Air quality Model with Extensions (CAMx) model. EPA has 

approved each of these models for use in SIPs. During the course of the SIP 

modeling effort, modelers ran each one of these models and then compared the 

output to observations. The CAMx model was judged to perform slightly better 
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than the others, and this model has the capability of diagnosing internal 

operations that give the final pollutant results. CAMx has computer coding that 

can evaluate, within each grid cell at a given time for each physical and chemical 

process, the amount of ozone produced. This algorithm, called process analysis 

(PA), can diagnose problems in the model. For meteorological inputs to the air 

quality model, weather models called MM5 (Meso-scale Model 5) and Calmet 

were used. These models are discussed below. Other meteorological models 

were run, but this model resulted in the best overall performance for winds and 

temperatures. 

5.4 MODEL BASE CASE 

In order to estimate the amount of emissions reductions needed to achieve 

ambient air quality standards, modelers first establish a modeling base case. 

This is a historical episode that represents near worst-case weather conditions. 

Modelers select the episode by analyzing ozone and other pollutant 

concentrations, pollutant transport, dispersion, and day-specific emissions. The 

goal of this analysis is to determine the representativeness of the episode for 

testing emission reduction strategies. 

Modelers considered five episodes for representing ozone episodes in the San 

Joaquin Valley. These episodes occurred during 1999, 2000, and 2002. The 

episodes in 2000 are part of the Central California Ozone Study (CCOS). During 

CCOS, scientists made extensive measurements of ozone, hydrocarbons, oxides 

of nitrogen, and other chemical species from ground-based sites and from 

aircraft. Additionally, lower air profilers measured continuous winds and 

temperatures aloft. Episodes outside of CCOS had much less meteorological 

and pollutant data to initialize and verify models. Consequently, members of the 

Technical Committee were highly interested in using CCOS episodes for SIP 

development. Candidate episodes for SIP analysis included: 

• July 11-12, 1999 

• June 17,18, 2000 

• July 29-August 2, 2000 

• September 17-21, 2000 

• August 9-16, 2002 

State and local agencies and their consultants working for CCOS simulated all of 

these episodes using one or more of the computer models described above. The 

focus of these modeling efforts was for the San Joaquin, Bay Area, and 

Sacramento SIPs. In addition to the ARB, contractors from private firms, NOAA, 

and academia worked on various aspects of modeling these episodes. 

Of the CCOS episodes, where extensive air quality and meteorological data was 

available, the July/August 2000, episode was determined to be the most 

representative of the transport and formation of ozone in the Central California 
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Region. During CCOS, numerous air quality and meteorological measurements 

were taken that would produce more confidence in photochemical modeling 

results. For example, aircraft and ground based hydrocarbon measurements 

were taken that could be used to start the models. Lower air profilers that 

measured the winds and temperatures in the lower atmosphere achieved better 

coverage of the SJVAB and collected data more frequently than routine 

measurements. Technical Committee members identified some issues with this 

episode (notably the presence of wildfires), but the consensus was that shifting 

resources to other episodes had no demonstrable benefits. 

Because of the issues identified for the July/August 2000 episode, the District 

was also interested in the September 17-21, 2000 episode for potential use in the 

SIP. Consequently, the District contracted modeling of this episode through the 

Study Agency. After considerable study, the performance of this episode was 

found to not meet performance criteria for use in the SIP, so it was not pursued. 

Weather causing poor dispersion and light transport of pollutants during the JulyAugust 2000 episode was typical of high ozone events in Central California. 

High pressure dominated the region and the magnitude of that pressure was 

typical of high ozone events. This weather pattern caused light winds, strong 

inversions, and poor dispersion throughout the episode. Study Agency and 

outside contractors along with staff concluded that the July-August 2000 episode 

meteorology was typical of ozone episodes in the SJV. Therefore, the episode 

was deemed useful for evaluation of emission reductions. 

The July-August 2000, episode exhibited weather features that were similar to 

high ozone events analyzed historically. Observed winds showed morning 

upslope, nighttime downslope, local eddies, and marine wind flows. Figure 5-1 

shows winds in the morning and afternoon of July 30, 2000. Morning down-slope 

and afternoon up-valley flow are evident in this simulation. Marine flow is also 

evident in the afternoon in the northern SJV. A prominent feature of the 

afternoon simulation is the up valley wind flow into the SJV from the Bay Area, 

which brings marine air into the Northern SJV; however, the air becomes quite 

modified and hot by the time it reaches Fresno. High velocity downslope winds 

are evident in the morning simulation near Fresno. The Fresno eddy (Section 2) 

is not obvious in the morning simulation, but there is some hint of it in the data 

because the winds are easterly in east Fresno County and westerly in west 

Fresno County. Modelers produced meteorological simulations using a hybrid of 

the Meso-scale Model 5 (MM5) and the Calmet model. NOAA developed the 

MM5 simulation under contract to the study agency. ARB and consultants 

working for the districts in Central California also conducted MM5 runs. 

Technical Committee members evaluated the MM5 runs, and found differences 

between observed vs. predicted meteorology that could not be resolved by 

additional MM5 runs. For this reason, the Technical Committee explored a 

hybrid approach in which results from another model (Calmet) are used to modify 

the MM5 results to see if predictions of meteorological parameters more closely 
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match observed values for these parameters. Calmet is an observational based 

model where surface and aloft meteorology are interpolated. For the modeling 

exercise in this Plan, modelers used Calmet as the basis for the wind simulation, 

and adjusted the results using MM5 results in areas where no observations were 

available. 

The process to develop and validate an air quality model generally is very 

complex and resource intensive, and the development of the July/August CCOS 

episode was no exception. Technical Committee members and consultants 

spent a great deal of time and effort in the development and review of the 

modeling inputs, and in the application and validation of the air quality model. 

Many stakeholders participated in this process, including representatives of local 

air districts and transportation planning agencies in the region, and members of 

the CCOS Technical Advisory Committee. The modeling for this episode is an 

ongoing effort, since it will eventually support many uses in addition to one-hour 

ozone SIP planning, and since it will continue to reflect new information and 

improvements in the science. However, the modeling results presented in this 

document satisfy accepted model performance criteria and are acceptable and 

appropriate for use in SIP planning. 

Figure 5-1 

Wind Field for July 30, 2000 at 5:00am and 3:00pm PST 
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The Technical Committee has raised several issues regarding the use of the 

July-August 2000 episode in this Plan. Although the Southern Region near 

Bakersfield observed 1-hour ozone levels near design values (see Chapter 2), 

the Central Region near Fresno did not. The model predicts 1-hour ozone levels 

near design values in the Fresno area, but these have not been verified by 

observations. Earlier versions of the modeling showed lower predicted ozone 

levels; later model runs with the hybrid meteorology described above produced 

higher predicted 1-hour ozone levels near Fresno. Although some members of 

the Technical Committee raised issues regarding the merging of modeled and 

observational data1, no better solution was found. The better agreement of the 

simulated regional 1-hour ozone peaks and the measured design value near 

Fresno, using the hybrid approach, is a principal advantage of the hybrid. 

Figure 5-2 shows the maximum ozone simulated in the base case (July/August 

2000). Concentrations in the San Joaquin Valley are approximately 140 ppb 

near Bakersfield and Fresno. Typical design values (see Section 2) for the 

period from 2001-2003 are 150 ppb near Bakersfield at Arvin and 151 ppb near 

Fresno at Parlier. The large ozone plume east of Tulare was due to a large 

wildfire called the Manter fire. Although the model showed fire effects in the 

SJVAB on the last day of the simulation (August 2), on July 30 the fire effects 

were minimal on the floor of the valley. Figure 5-3 shows the effects of the fires 

on simulated ozone concentrations. 

5.5 FUTURE YEAR PROJECTIONS 

Once the model has been validated by comparing predicted and observed 

concentrations, the model can be used to predict future air quality. Future year 

emissions projected in a process described in Chapter 3 are processed to 

provide input to the model. The first step in estimating reductions to achieve the 

federal 1-hour ozone standards is to forecast emissions for the attainment year, 

which for this plan is 2010. The 2010 emissions estimate was run through the 

model. The model showed that the projected 2010 emissions did not attain the 

federal 1-hour ozone standards. Because of fire emissions impacts in the model 

on the days later in the episode, July 30 at the beginning of the episode was 

chosen to do future year analyses. The model forecast that the highest 

concentrations in the San Joaquin Valley would be 128 ppb near Fresno and 136 

ppb near Bakersfield. Figure 5-4 shows the model response to 2010 emissions 

estimates using meteorology from July 30, 2000. 

 

1

 For example, the air quality model is resolved to 4km X 4km grids. Some believe that the 

meteorology and air quality model resolution should match, and that only meteorological model 

physics should drive the analysis. 
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Figure 5-2 

Maximum Ozone Concentration for CCOS Episode, July 30—August 2, 2000
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Figure 5-3 

Change in Maximum Ozone Concentration Due to Wildfires, July 30, 2000
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Figure 5-4 

Maximum Predicted Ozone Levels, 2010, Without Additional Controls
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5.6 ATTAINMENT DEMONSTRATION 

Attainment demonstration refers to estimating the amount of ozone precursor 

emission reductions needed for the model to project attainment of the federal 1-

hour ozone standards. After validation of the model, and some emissions 

adjustments for inventory improvements, modelers calculate the amount of 

reductions needed to attain the federal 1-hour ozone standards. 

Once a base 2010 emission scenario was established, modelers established 

reductions in emissions of ozone precursors across the modeling region from the 

2010 emissions forecast. These cuts consist of reducing the amounts of VOC 

and NOx emissions in the region by a percentage, running these emissions 

through the model, and recording and plotting the ozone levels predicted by the 

model for these combinations of emissions. Repeating this process many times 

produces a data set of predicted ozone levels for a given location as a function of 

VOC and NOx emissions inventories. Plotting the predicted ozone levels as a 

function of various VOC and NOx emissions produces a carrying capacity 

diagram2

, an example of which is shown in Figure 5-5. The carrying capacity 

diagrams for Fresno and Bakersfield revealed that both VOC and NOx emissions 

reductions were needed to demonstrate attainment of the federal 1-hour ozone 

standards using the July 30 episode day. Plots for other days near the end of the 

simulation, especially August 2, showed that in the Bakersfield area ozone was 

limited by VOC emissions and reductions in NOx did not significantly change 

ozone levels. Because fire emissions affected the end of the episode on August 

2, that day was not used for attainment demonstration. 

Figure 5-5 presents the carrying capacity diagram for July 30, 2010 in 

Bakersfield. The axes represent fractions of the 2010 NOx and VOC emissions 

inventories that produce various ozone levels in (represented by the numbers on 

the curves that are shown; units are in parts per billion). Since the federal 1-hour 

ozone standards are 0.12 ppm, any ozone value of 124 ppb or less on Figure 5-5 

represents attainment of the federal 1-hour standards. Planners thus look at 

what combinations of fractions of the 2010 VOC and NOx inventories support 

ozone levels that attain the standards. For example, a NOx inventory of 85% of 

the total used in the modeling3

, coupled with a VOC inventory also at 85% of the 

modeled inventory, would demonstrate attainment because the intersection of 

lines drawn perpendicular to the respective axes from these points intersect to 

the left of (and hence are lower than) the curved line labeled “125”4

. 

 

2

 The name stems from the level of emissions that the atmosphere can “carry” and still 

demonstrate attainment. 

3

 An inventory that is 85% of the total used in the modeling reflects an overall emission reduction 

of 15% for that ozone precursor. 

4

 A value of “125” or higher (to the upper right) represents nonattainment. 
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Figure 5-5. Carrying Capacity Diagram for Bakersfield on July 30, 2010 

Planners used Figure 5-5 for this Extreme OADP by first estimating emissions 

reductions that have been identified since completion of the emissions inventory 

used in the modeling for this Extreme OADP (the gridded photochemical 

modeling described above reflects emissions controls in place as of September 

2002). Thus, for this Extreme OADP, any control measure commitments 

identified after September 2002 represent additional reductions that contribute to 

the overall total reductions needed for attainment. These measures include (1) 

District control measures and state and federal measures identified for the 2003 

PM10 Plan approved by EPA effective June 25, 2004, (2) District measures 

adopted after the inventory cutoff but before the PM10 Plan and not reflected in 

the PM10 Plan, and (3) any additional District, state, and federal measure 

commitments developed for this Extreme OADP.

5

 Planners added these 

emissions reductions for each of VOC and NOx and used the resulting totals to 

 

5

 Note that Table 4-1 only supplies some of the emissions reductions needed for the attainment 

demonstration; others come from the 2003 PM10 Plan, incentives, and state emission control 

measures. For these reasons, the sum of reductions in Table 4-1 does not match the sum 

needed to demonstrate attainment in Table 5-1. 
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TABLE 5-1 

SJVAB FEDERAL 1-HOUR OZONE ATTAINMENT CONCEPT 

2010 Summer 

Planning Inventory

(tons/day) Category 

VOC NOx 

2010 Baseline Inventorya 367.6 401.7 

District Rules-- Post-Inventory and Pre-PM10 Planb 0 0.1 

Update to Estimated 2010 State Commitments in PM10 Planc 2.5 14.9 

Update to Estimated 2010 District Commitments in PM10 Pland 9.4 26.3 

Total Updated 2010 Commitments in PM10 Plan 11.9 41.2 

New ARB 2010 Commitments in Extreme OADPe 15.0 10.0 

New District 2010 Commitments in Extreme OADPf 21.3 1.9 

Total New 2010 Commitments from Extreme OADP 36.3 11.9 

Total Reductions through PM10 Plan and Extreme OADP 48.2 53.2 

Reductions Needed from Long-Term Measures 5 5 

Total Reductions 53.2 58.2 

Total Reductions as % of 2010 Inventory 14.5% 14.5% 

 

a

 See Table 3-1; CCOS Summer Inventory, Version 2.11, January 2004; reflects control 

measures through September 2002. 

b

 Represents District Rule 4313 for Lime Kilns, which is estimated to provide 0.1 tpd of 2010 NOx 

reductions. This rule was not included in the emissions reductions used in the 2003 PM10 Plan; 

it was adopted in March 2003 after the September 2002 cutoff date for the inventory. 

c

 Based on updates to estimated annual emissions reductions in the 2003 PM10 Plan, Tables 

4-14 and 4-17. State measures reflect 2.5 tpd of VOC reductions from I/M enhancements that 

are not shown in the 2003 PM10 Plan, and 4.9 tpd of NOx reductions from Smog Check II that 

are shown in the 2003 PM10 Plan. d

 Based on updates to estimated emissions reductions from District measures given in the 2003 

PM10 Plan, as shown in Table 4-1 in this Extreme OADP (Footnote 6). Also includes emissions 

reductions from control measures in the PM10 Plan that were adopted as rules before creation of 

Table 4-1 (Rules 4604, 4408, 4610, 4306, and incentives—see Footnote 6 in Table 4-1) 

converted to summer totals thru the EIC codes affected by the control measure categories using 

summer and annual CCOS inventories. Residential wood combustion emissions excluded. 

e

 New state measures above and beyond those in the 2003 PM10 Plan; see Table 4-3 in the 

Extreme OADP.

f

 New District measures above and beyond those in the 2003 PM10 Plan; does not include 

measures affected by Footnote d above. Only includes Table 4-1 measures that were not in the 

2003 PM10 Plan. 
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compute the percentages by which the 2010 NOx and VOC emission inventories 

were reduced by the control measures. As shown in Table 5-1, adding the 

emission reductions from these three components gives a total VOC emission 

reduction of about 48.2 tons/day and a total NOx emission reduction of about 

53.2 tons/day. These inventories represented about 87% of the VOC inventory 

used in the modeling and about 87% of the NOx inventory used in the modeling. 

Plotting these data on Figure 5-5 showed that the intersection of the two controls 

resulted in a predicted ozone level that is clearly on or to the right of the “125” 

nonattainment line, thereby indicating nonattainment. 

This predicted nonattainment led the District to identify additional emissions 

reductions, which when added to the totals discussed above, would be sufficient 

to demonstrate attainment. The District determined that 5 tons per day of VOC 

emissions reductions and 5 tons per day of NOx emissions reductions, when 

added to the totals already shown in Table 5-1 from specific District and State 

measures identified through this Extreme OADP, would be sufficient to 

demonstrate attainment. Addition of 5 tons per day to each of the VOC and NOx 

categories produced total reductions of 53.2 tons per day of VOC and 58.2 tons 

per day of NOx (Table 5-1). These reductions result in a VOC emissions 

inventory that is 85.5% of the VOC inventory used in the modeling and a NOx 

emissions inventory that is about 85.5% of the NOx inventory used in the 

modeling. Plotting these percentages on Figure 5-5 shows that the lines 

intersect to the left of the “125” nonattainment line, indicating a predicted 2010 

ozone level that is in attainment with the federal 1-hour ozone standards. The 

resulting 2010 emissions inventory that demonstrates attainment of the federal 

1-hour ozone standards in the SJVAB is about 314 tons per day of VOC and 

about 344 tons per day of NOx. 

In accordance with the federal Clean Air Act and as described in Section 4.9, 

these additional emissions reductions needed to demonstrate attainment are 

placed into the category of “Long-Term Measures” that will be identified in 2007 

(see Section 4.9). No specific control measures producing these reductions are 

identified at this time. As discussed in Section 4.9, the District needs to identify 

these measures no later than the spring of 2007. Because of other major SIP 

commitments that are scheduled to occur prior to this date (e.g., the 2006 PM10 

Plan and the 2007 8-hour Ozone Attainment Demonstration Plan), specific 

control measures with reductions of this magnitude are expected to be identified. 

Put another way, the emissions reductions achieved through the Amended 2002 

and 2005 Rate of Progress Plan for San Joaquin Valley Ozone, when modeled 

out to 2010, are insufficient to attain the federal 1-hour ozone standards in the 

SJVAB. Additional reductions are needed for attainment. Adding together the 

additional reductions from District and state measures in the 2003 PM10 Plan

and the Extreme OADP (including the “Long-Term Measures”) produces a total 
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SJVUAPCD Chapter 5 – Future Ozone Air Quality 

5-13 

emission reduction that is sufficient to demonstrate attainment of the federal 1-hr 

ozone standards in the SJVAB in 2010 for the types of weather conditions 

observed during this episode. 

5.7 Modeling Caveats and Future Work

Three major caveats exist regarding the modeling that has been done for this 

plan. The first is that emissions from major wildfires are in the base case, but not 

in the future year attainment runs. This approach was used because no reliable 

and defensible technique exists for predicting the location, duration and intensity 

of future wildfires. Consequently, the predicted ozone levels for 2010 receive 

some “benefit” from lack of ozone precursor emissions from major wildfires. 

Studies done for this plan show that the magnitude of the fire effect is minimal for 

the day actually used for attainment demonstration (July 30, 2010). The second 

caveat is that the measured ozone values in Fresno were not near the highest 

concentrations that historically have occurred. The justification for using this 

episode was that the peak may have occurred away from a monitoring site, and 

the modeled peak may be more indicative of what actually occurred in the JulyAugust 2000 episode. The third caveat is that the meteorological fields for this 

episode were developed by using a hybrid approach that combined observational 

and physics-driven meteorological models. This hybrid was used because it 

resulted in the best agreement between simulated and observed ozone. It is 

possible that the combination of these could have resulted in compensating 

errors where the meteorological field made up for underestimations in the 

inventory and other problems. 

In spite of all of these caveats, the modeling used for this plan is based on the 

best available information and science as of Spring 2004. Future work under 

CCOS will improve our understanding of ozone production in the SJVAB. As 

noted in Section 3, other future tasks will address improvements in the emissions 

inventory. Together, these improved data and modeling tools will lead to 

stronger modeling exercises for future ozone attainment demonstration plans. 

Toward this end, work is currently underway by ARB, SJVAPCD, SMAQMD, 

BAAQMD, and the consultants for these organizations to improve photochemical 

modeling in Central California. A systematic plan funded by the Study Agency 

has been formulated that describes the analyses of emissions, meteorology, 

chemistry, and model formulation to improve the model performance. Most of 

the funding for this overall CCOS modeling plan has been approved, and the 

analyses will be implemented over the next few years. 
❖
Chapter 6 – OUTREACH
❖
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6 OUTREACH 

6.1 INTRODUCTION 

Public participation is vital to good air quality and education is crucial to good 

public participation. When government agencies, major industries, educators, 

businesses, and the general public work together, advancements are made to 

improve air quality. The Air District makes every effort to improve public 

education initiatives and to promote better community cooperation to deal with air 

pollution problems, as described in Section 4.5. 

This section describes outreach that was conducted for the Extreme OADP. 

Outreach tools include workshops, the Citizen’s Advisory Committee, Governing 

Board presentations, and web site postings. 

6.2 PRE-DRAFT PLAN WORKSHOPS 

Prior to issuing the Draft Extreme OADP, the District held two rounds of public 

workshops on developing the Plan. The dates of these workshops were, July 23, 

2003 for the 1st round and January 6 and 7, 2004 for the second round of 

workshops. The workshop held on July 23, 2003 covered the technical issues 

associated with the Extreme OADP. About 35 people attended through the 

Fresno site, 12 at Bakersfield, and 12 at Modesto. The workshop began at 1:30 

pm and ended at 4:45 pm. The comment period for this workshop ended on 

August 7, 2003. Stakeholders submitted about 30 comments in response to 

information presented at this workshop. The District summarized the comments 

and provided responses on its website. Two general topics dominated the 

comments: the transition from the 1-hour ozone standards to the 8-hour ozone 

standards, and the timing for making the request to be classified as extreme 

nonattainment for the federal 1-hour ozone ambient air quality standards. 

The January 6th and 7th workshops presented more specific information related to 

the Extreme OADP, and also provided a Status Report on the development of 

the Ozone Attainment Demonstration Plan for the San Joaquin Valley Air Basin. 

The District posted the Status Report on December 31, 2004, and noticed its 

availability in the same notices used to announce the workshops. The Status 

Report identified the District and state control measures to appear in the Extreme 

OADP, and discussed preliminary photochemical modeling results and their 

implication for attainment demonstration. About 30 people attended the first 

workshop (January 6, 2004) and about 20 attended the second workshop 

(January 7, 2004). The comment period for these workshops ended on January 

23, 2004. Participants at the two workshops made over forty verbal comments, 

and several other stakeholders submitted written comments. The District 

summarized the comments and developed responses to these comments that 
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6-2 

were posted on the District website at www.valleyair.org . The topics generating 

the most comments were the preliminary photochemical modeling results, the 

need to examine emissions controls on a sub-regional level, the rule 

development process, and the timing of plan development versus EPA’s likely 

schedule for submitting the Extreme OADP to them. 

On December 5, 2003, the District held its last workshop on the reclassification of 

the SJVAB to extreme nonattainment, and much of the discussion dealt with the 

content and timing of the Extreme OADP. Stakeholders and participants offered 

several suggestions for control measures to consider. Comments and responses 

were submitted as part of the December 18, 2003 Governing Board package for 

requesting reclassification to extreme nonattainment. 

6.3 CITIZEN’S ADVISORY COMMITTEE 

The Citizen’s Advisory Committee (CAC) consists of 24 primary and 24 alternate 

members. Each of the following groups has one unpaid representative from each 

county in the SJVAB: the Industry/Agriculture, Environment and City. Citizens 

Advisory Committee Meetings are generally held on the first Tuesday of each 

month at 10:00 a.m. at the Central Region Office with video-teleconference links 

to Modesto and Bakersfield. On July 1, 2003 District staff briefed the CAC on 

ozone and on development of the Extreme OADP. 

6.4 DISTRICT GOVERNING BOARD 

During 2003 and 2004, District staff briefed the Governing Board a number of 

times on various issues related to the 1-hour ozone Extreme OADP. These 

briefings were done at regularly scheduled monthly Governing Board meetings 

as well as at other public Governing Board meetings. On May 16, 2002, the 

Governing Board discussed the issue of severe vs extreme nonattainment, and 

adopted the 2002 and 2005 Rate of Progress Plan that served as a springboard 

for the Extreme OADP. On June 20, 2002, the Governing Board directed District 

staff to prepare a plan demonstrating attainment of the federal 1-hour ozone 

standard in the SJVAB by November 15, 2010 (the attainment date for areas 

classified as extreme nonattainment). On December 19, 2002, the Governing 

Board adopted the Amended 2002 and 2005 Rate of Progress Plan for San 

Joaquin Valley Ozone, which also provided information for use in the Extreme 

OADP. On February 20, 2003, District staff briefed the Governing Board on the 

schedule for developing the Extreme OADP and the implications of severe vs 

extreme nonattainment timelines. On August 21, 2003, staff provided the 

Governing Board with an update on the timing for requesting EPA to reclassify 

the SJVAB as extreme nonattainment. On December 18, 2003, the Governing 

Board formally requested EPA to reclassify the SJVAB as extreme 
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nonattainment. Agendas and minutes for Governing Board meetings are found 

on the District’s web site at www.valleyair.org . 

6.5 WEB SITE POSTINGS 

On its web site, the District has information pertaining to ozone, including maps, 

current plans, workshop postings, and other ozone related information. This 

information is available to the public 24 hours a day, seven days a week. 

Workshop documents are available, two weeks prior to the workshops, to give 

the public time to review the staff report and draft version of the plan. Also 

available is the current 1-hour ozone adopted plan, archived workshops, adopted 

rules and regulations, federal regulations and Guidance documents. The web 

site also includes information on the federal 8-hour ozone standard and the 

proposed state 8-hour ozone standard as it becomes available. 

The web site provides links to other government and private web sites with 

information such as air quality research studies (CCOS, IMS 95, SARMAP), 

other air districts; ARB and EPA. The web site provides links to information on 

the designation and classification of the San Joaquin valley and other air basins. 

Through the use of the web the district is able to effectively reach many more 

people at very low cost. The Internet allows the Air District to notify the public, 

especially those that fall into the sensitive group category, when the air quality is 

unhealthy. 

6.6 STUDY AGENCY 

The District used the regular meetings of the San Joaquin Valley Study Agency 

Policy Committee to keep stakeholders informed of the schedule for developing 

the Extreme OADP and the regular meetings of the Technical Committee to 

discuss the modeling supporting the attainment demonstration in the Extreme 

OADP. On June 29, 2004, members of the Technical Committee participated in 

an all-day meeting on the photochemical modeling used in the Extreme OADP. 

6.7 DRAFT EXTREME OADP

The District released the Draft Extreme Ozone Attainment Demonstration Plan

(OADP) for public review on July 30, 2004. In conjunction with releasing the 

plan, the District announced a series of three workshops to be held on the Draft 

Extreme OADP on August 12 and 13, 2004. The District mailed about 1200 

notices to the ozone plan mailing list announcing plan availability and workshop 

dates, and also used the notice as a legal advertisement that appeared in the 

eight major San Joaquin Valley newspapers. District staff conducted the 

workshops in person in the Central Region (Fresno), and via videoteleconference links to Bakersfield and Modesto. About 27 people attended the 
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6-4 

first day of workshops (August 12, 2004) and about 20 attended the second day 

workshop (August 13, 2004). The August 12 workshops were held at 1:00 pm 

and 6:30 pm, and the August 13th workshop was held at 10:00 am. The evening 

workshop on August 12th was a community meeting geared toward simplified 

presentations and discussions of the topics. The comment period for the Draft 

EOADP ended on August 27, 2004. Participants at the three workshops made 

over fifty verbal comments, and several other stakeholders submitted written 

comments. No formal written comments were received from the U.S. 

Environmental Protection Agency (EPA), the California Air Resources Board 

(ARB), or the San Joaquin Valley Air Basin (SJVAB) Transportation Planning 

Agencies. 

Major issues raised in verbal comments during the workshops and in stakeholder 

meetings after the workshop include the following: lack of time to review and 

comment on the Draft Extreme OADP; the need for the District to consider subregional modeling for this plan and especially for future ozone attainment 

demonstration plans; the fate of control measures in the Extreme OAPD if EPA 

revokes the federal 1-hour ozone standard as planned on June 15, 2005; and the 

increasing need for the District to consider non-traditional and alternative means 

of emissions controls for future attainment demonstration plans. Written 

comments also included all of these issues, as well as the need for and means of 

developing an indirect source rule. Appendix H summarizes the comments and 

responses submitted to the District during public review of the Draft Extreme 

OADP. 

6.8 PROPOSED EXTREME OADP 

The Proposed Extreme OADP is scheduled to be considered for adoption by the 

District Governing Board on October 8, 2004. Notices for this hearing and for the 

availability of the Proposed Extreme OADP were published in all eight major 

Valley newspapers on September 4-7, 2004. At the September 16, 2004 

Governing Board meeting, the Governing Board received and filed the Proposed 

Extreme OADP, together with an Errata Sheet detailing some minor adjustments 

in emissions calculations in the Plan. The Governing Board directed staff to 

make the necessary revisions to the proposed plan and to make the revised 

proposed plan available in advance of the October 8, 2004 meeting. The 

comment period on the Proposed Extreme OADP closed on September 24, 

2004. In addition, the District posted the Proposed Extreme OADP, public 

hearing notice, and related documents on its web site in time to provide a 30-day 

public review period before the October 8, 2004 hearing. 
Chapter 7 – RATE OF PROGRESS DEMONSTRATION
❖
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SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-1

7 RATE OF PROGRESS 

7.1 INTRODUCTION 

The Federal Clean Air Act (FCAA) specifies that ozone nonattainment areas 

must submit to EPA SIP revisions documenting that emissions of volatile organic 

compounds (an ozone precursor—see Chapter 2) are declining at rates that 

meet or exceed levels specified in the FCAA. These SIP revisions are termed 

Rate of Progress (ROP) Plans. The FCAA identifies two types of ROP 

requirements: (i) a 15% VOC emission reduction to be achieved from 1990 to 

1996 (termed the “15 percent Rate of Progress Plan”) and (ii) an actual VOC 

emission reduction of at least three percent per year averaged over each 

consecutive 3-year period beginning November 15, 1996 until the area’s 

attainment date (termed the “Post-1996 Rate of Progress Plan”). EPA guidance 

allows substitution of NOx emissions (the other significant ozone precursor—see 

Chapter 2) for VOC emissions in the Post-1996 Rate of Progress Plan, provided 

certain conditions are met (EPA 1993, EPA 1994b). The three percent per year 

requirement should be viewed as a minimum annual emission reduction; the 

underlying requirement for a nonattainment area’s SIP is to achieve attainment 

by the requisite date, even if the emission reductions necessary to achieve 

attainment exceed three percent per year (EPA 1994a). The SJVAB has met all 

ROP Plan requirements through 2005 (SJVUAPCD 1994; SJVUAPCD, 1995; 

SJVUAPCD, 2000, SJVUAPCD, 2002). 

This section provides the remaining ROP Plan requirements for the SJVAB out to 

its projected attainment date of November 15, 2010 for the federal 1-hour ozone 

standard. It then shows that prior ROP Plan calculations are still valid given the 

most recent emissions inventory information. As discussed in Chapter 3, 

emissions inventories change over time to reflect implementation of control 

measures, adjustments to improve accuracy, and other factors. Consequently, 

the most recent inventories are generally believed to be more accurate, even for 

past years. Therefore, Section 7.6 re-examines the ROP calculations in the most 

recent SJVAB ROP Plan in light of current planning emissions inventories for the 

SJVAB to demonstrate that the ROP requirements are still met. It also looks 

back at 2002 and determines that ROP requirements for 2002 were met as 

projected. 

7.2 1990 RATE-OF-PROGRESS BASELINE INVENTORIES 

The FCAA requires that milestone year emission reductions be based on the 

1990 baseline emission inventory. As noted in prior ROP Plans (SJVUAPCD 

2002), the 1990 emission inventory has been reconstructed to account for 

updated information and new air quality models. Table 7-1 summarizes the total 

reconstructed 1990 baseline year emissions inventory, which serves as the 
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SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-2

starting point for all other FCAA-required inventories. As noted in Chapter 3, 

emissions inventories represent tons/day emissions for the ozone season (May 1 

through October 31) for the year in question. 

Table 7-1 

1990 ROP Baseline Year Inventory (tons/day) 

Emission Sources VOC NOx 

Point Sources 193.0 289.7 

Area Sources 153.9 6.5 

Other Mobile 72.6 211.3 

On-road Mobile 213.7 297.6 

TOTAL 633.2 805.1 

Finally, the FCAA specifies the “baseline” from which each milestone’s emission 

reduction is calculated [Title I, Part D, Section 182 (b)(1)(C) and (D)]. This 

baseline is termed the 1990 Adjusted Base Year Inventory. It is defined as “the 

total amount of actual VOC or NOx emissions from all anthropogenic sources in 

the area during the calendar year of the enactment of the Clean Air Act of 1990”, 

minus the emissions that would be eliminated by federal motor vehicle control 

program (FMVCP) regulations promulgated by January 1, 1990, and Reid Vapor 

Pressure (RVP) regulations promulgated by the time of enactment [FCAA, Title I, 

Part D, Section 182 (b)(1)]. Consequently, the FMVCP and RVP emissions must 

be subtracted from the 1990 emissions in order to develop a baseline inventory 

for ROP demonstration. Furthermore, the 1990 adjusted base year inventory 

must be recalculated relative to each ROP milestone (2008 and 2010) because 

the emission reductions associated with the FMVCP increase each year due to 

fleet turnover. The only adjustment needed is to recalculate mobile source 

emissions, using a mobile source emission factor for each year, multiplied by 

1990 VMT. This yields the adjusted emissions for each of these years that are 

subtracted from the 1990 actual emissions to determine 1990 adjusted baseline 

year inventories. Table 7-2 shows the calculations for VOC; no adjustments are 

needed for NOx because the FMVCP and RVP deductions are zero for NOx 

emissions. As shown in Table 7-2, these adjustments reduce the base year VOC 

inventory of 633.2 tons/day to the adjusted base year inventories of 553.0 

tons/day for 2008 and to 548.5 tons/day for 2010. The 1990 adjusted base year 

NOx inventory is 805.1 tons/day for each of 2008 and 2010. ARB provided the 

numeric values for the FMVCP and RVP emission reductions. The ratio of 

baseline year NOx to VOC emission inventories is 1.27 (805.1/633.2=1.27). 
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SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-3

The FCAA does not allow emissions credits toward the 51 percent reduction from 

corrections stemming from the Reasonably Available Control Technology (RACT) 

and federally-mandated Inspection and Maintenance (I&M) programs [Title I, Part 

D, Section 182(b)(1)(D)]. The District is claiming no reductions for federallymandated I&M corrections for the 2008 ROP demonstration. Any emissions 

reductions to satisfy RACT requirements in this plan are less than 0.05 tons/day 

(see Table 4-1) and are too small to be reflected in the ROP results. 

Table 7-2 

1990 Adjusted Base Year VOC Inventory Calculations (tons/day) 

Emissions Inventory Adjustment 2002 2005 2008 2010 

1990 Rate of Progress Base Year 

Inventory (VOC) 

633.2 633.2 633.2 633.2 

Minus FMVCP/RVP Reductions 53.6 70.1 80.2 84.7 

1990 Adjusted Base Year VOC 

Inventory 

579.6 563.1 553.0 548.5 

7.3 FUTURE YEAR (2008 AND 2010) INVENTORIES 

In order to demonstrate that the 2008 and 2010 target levels for VOC and NOx 

emissions can be met, emissions are projected to 2008 and 2010 using 

techniques presented in Chapter 3. Table 3-1 summarizes the VOC and NOx 

inventories for 2008 and 2010. The emission inventories were projected from the 

1999 actual emission inventory and do not include any reductions from rules or 

regulations adopted subsequent to 2002 (see Table 7-3). These adopted 

emission reductions are incorporated into the ROP demonstration in Sections 7.4 

and 7.5. 

7.4 1990-2008 MILESTONE (51 PERCENT) DEMONSTRATION 

Because the 1990 Base Year Emission Inventory was reconstructed, this report 

addresses the rate of progress from 1990 to 2008 and from 1990 to 2010. The 

FCAA requirements for demonstrating rate of progress require an initial 15 

percent reduction in 1990—1996 emissions, followed by subsequent reductions 

of 3 percent per year averaged over consecutive 3 year periods; consequently, 

the District will demonstrate achievement of a 51 percent reduction in emissions 

for the 2008 rate of progress [42 percent for 1990—2005 plus 9 percent for 

2006—2008] and a 57 percent reduction in emissions for the 2010 rate of 

progress (51 percent between 1990—2008 plus six percent for 2008—2010). 
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SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-4

TABLE 7-3 

Reductions From Adopted Rules and Regulations 

Not Included in the 2008 and 2010 Planning Inventories1

NOx 

Reductions 

(tons/day) 

VOC 

Reductions

(tons/day) Rule Description Action 

Date 2008 2010 2008 2010 

4604 Can and Coil 

Coatings 2003-2007 NA NA 0.4 0.4

4610 

Glass Coating 

Operations 2003-2007 NA NA 0.2 0.2 

4408 Glycol Dehydration 

Systems 2003-2007 NA NA 1.8 1.8 

4306 

Boilers, Steam 

Generators & 

Process Heaters 

2003-2007 7.1 7.1 NA NA 

None Incentive Programs 2003-2007 5.2 5.0 NA NA 

4313 Lime Kilns March 2003 0.1 0.1 NA NA 

Total 12.4 12.2 2.4 2.4 1

 Reflects estimates for adopted District measures as given in Tables 4-17 – 4-20 in the 2003 PM10 Plan for the San 

 Joaquin Valley Air Basin. 

7.4.1 Required 51 Percent Reduction for 2008 

As specified in the FCAA [Title I, Part D, Section 182 [c](2)] the total emissions 

reductions required for 2008 are equal to 51 percent of the adjusted base year 

inventory. The 51 percent reduction calculated for the adjusted base year 

inventory (Table 7-2) is therefore calculated to be 282.0 tons/day (51 percent of 

553.0 tons/day is 282.0 tons/day). Subtracting the 51 percent emission reduction 

of 282.0 tons/day from the 1990 adjusted base year emissions inventory of 553.0 

tons/day gives a target 2008 emissions inventory of 271.0 tons/day. In other 

words, achieving the 51 percent reduction from the adjusted baseline would 

produce a 2008 emissions inventory of 271.0 tons/day. If the actual 2008 

emissions inventory is greater than this total, then VOC emissions reductions 

alone are insufficient to meet regulatory requirements, and reductions in NOx 

emissions must be sought in order to meet the 51 percent ROP requirements.

7.4.2 2008 Rate of Progress Demonstration 

7.4.2.1 VOC Emissions Reductions 

As noted in Section 7.2 and presented in Table 3-1, the 2008 actual VOC 

emissions inventory for the SJVAB is estimated to be 374.9 tons/day. Emission 

reductions from post-2002 District control measures reduce this total by an 

additional 2.4 tons/day (Table 7-3) and expansion of the Enhanced I/M program 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-5

contributes another 3.1 tons/day in reductions, which results in a revised 2008 

VOC emission inventory of 369.4 tons/day. Thus the actual 2008 VOC 

emissions inventory for the SJVAPCD is too high by about 98.4 tons/day to meet 

the 51 percent reduction over the 1990-2008 time period. 

7.4.2.2 NOx Emissions Reductions 

The FCAA allows Districts to substitute reductions in NOx emissions when they 

are unable to achieve the necessary reductions with VOC emissions alone [Title 

1, Part D, Section 182 (c)]. 

Section 182 (c) and 182 (d) of the FCAA state that NOx emissions reductions 

that occurred after 1990 can be used to meet post-1996 emission reduction 

requirements, provided that they meet the criteria outlined in the EPA’s NOx 

Substitution Guidance (EPA 1993). The 1993 Guidance establishes two criteria 

for use of these emission reductions. First, the sum of all creditable VOC and 

NOx emission reductions must equal three percent per year averaged over each 

applicable milestone period. The percent VOC reduction is determined from the 

VOC rate of progress inventory and the percent NOx reduction is determined 

from the NOx rate of progress inventory. Second, the overall VOC and NOx 

reductions must be consistent with the area’s modeled attainment demonstration. 

In other words, NOx emission reductions creditable toward rate of progress plans 

cannot be greater than the cumulative reductions dictated by the modeled 

attainment demonstration (because the ROP plans must be consistent with the 

strategy selected by the District as its attainment strategy). The guidance also 

notes a third condition of “the periodic emission reductions must be consistent 

with the modeled attainment demonstration.” 

With regards to the second requirement, as noted in Chapter 1, the District 

cannot identify enough emission reductions from existing and new control 

measures that will allow the SJVAB to attain the one-hour ozone standard by 

20081

. Thus a modeled attainment demonstration for 2008 for the SJVAB does 

not exist, so the comparison with a cumulative attainment total for this year is not 

relevant. Consequently the District may use NOx substitution for 2008 in 

accordance with the FCAA. 

The NOx base year emissions inventory is 805.1 tons/day (Table 7-1); the 

FMCVP correction for NOx is zero for 2008 (and 2010), so the adjusted base 

year NOx inventory is also 805.1 tons/day. Computing the necessary NOx 

emissions reductions involves multiplying the VOC shortfall by 1.27 to reflect the 

 

1

 The state measures that are critical for demonstrating attainment do not go into effect in time to 

help demonstrate attainment for 2008. As noted in Chapter 4, ARB developed these measures 

primarily to help the South Coast Air Basin reach attainment by 2010, so the measures are 

geared towards a 2010 attainment deadline (for the South Coast as well as the SJVAB). 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-6

NOx/VOC ratio in the base year, which produces a total of 125.1 tons/day of NOx 

reductions needed to help the VOC emission reductions meet the overall 2008 

ROP requirement of a 51 percent reduction in precursor emissions. 

The actual 2008 NOx inventory is 429.1 (Table 3-1), emission reductions from 

post-2002 control measures reduce this total by an additional 12.4 tons/day 

(Table 7-3), and expansion of the enhanced I/M program contributes another 5.7 

tons/day of reductions, which results in a revised 2008 NOx emission inventory of 

411.0 tons/day; actual NOx emissions reductions achieved [the difference 

between 2008 and the 1990 base year] are therefore 394.1 tons/day. NOx 

reductions used previously for substitution (2002 and 2005) account for 102.4 

tons/day2

, leaving 291.7 tons/day of NOx reductions available for substitution in 

2008. Since the total is greater than the 125.1 tons/day needed to meet the 51 

percent requirement, sufficient rate of progress in reducing ozone precursor 

emissions has been demonstrated. 

7.4.2.3 Summary 

Table 7-4 summarizes the emission calculations performed to demonstrate 

achievement of a 51 percent reduction in ozone precursor emissions from 1990 

through 2008 for the SJVAB. Figure 7-1 provides a graphical illustration of the 

emission trends and reductions. 

7.5 1990-2010 MILESTONE (57 PERCENT) DEMONSTRATION 

7.5.1 Required 57 Percent Reduction for 2010 

As specified in the FCAA [Title I, Part D, Section 182 (c)(2)], the total ozone 

precursor emissions reductions required for 2010 must equal 57 percent3

 of the 

adjusted base year inventory. As shown in Table 7-2, the adjusted 1990 Base 

Year VOC inventory for the SJVAB is 548.5 tons/day. The 57 percent reduction 

for the 1990 adjusted base year emissions inventory (Table 7-2) is therefore 

calculated to be 312.6 tons/day (57 percent of 548.5 tons/day). Subtracting the 

57 percent emission reduction of 312.6 tons/day from the adjusted base year 

inventory of 548.5 tons/day gives a target 2010 VOC emissions inventory of 

 

2

 Reflects the sum of recalculated NOx substitution emission reductions for 2002 (40.9 tpd) and 

2005 (61.5 tpd) using the same EMFAC model runs as employed elsewhere in this Extreme 

OADP. Nothing in this recalculation affects conformity budgets for 2002 and 2005 as established 

in the Amended 2002 and 2005 Rate of Progress Plan for San Joaquin Valley Ozone, and as 

found adequate by EPA in 2003. 

3

 Because 2008 is an ROP milestone year and 2010 is the attainment year for extreme 

nonattainment areas, the final ROP post-1996 interval is actually two years rather than the usual 

three, so reductions of six percent (3 percent/year for two years) are added to the reductions 

required by the 2008 milestone year (51 percent) to arrive at a total of 57 percent [EPA 1994a]. 
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SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-7

TABLE 7-4 

2008 Rate of Progress Demonstration Summary

Line # Emission Calculation 

Emissions 

(tons/day) 

1 Adjusted 1990 Base Year VOC Inventory1

 553.0 

2 VOC Reduction Required (51% of Line 1) 282.0 

3 Target 2008 VOC Emissions Inventory (Line 1 minus Line 2) 271.0 

4 Actual 2008 VOC Emissions Inventory2

 369.4 

5 VOC Reductions Achieved (Line 1 minus Line 4) 183.6 

6 VOC Reduction Shortfall (Line 2 minus Line 5)3

 98.4 

7 Adjusted 1990 Base Year NOx Inventory4

 805.1 

8 NOx Reductions Required5

 125.1 

9 Actual 2008 NOx Emissions Inventory6 411.0 

10 NOx Reductions Achieved (Line 7 minus Line 9) 394.1 

11 NOx Reductions Used Previously for Substitution7

 102.4 

12 Available NOx Reductions for Substitution in 2008 291.7 

13 Sufficient NOx Reductions Available for Substitution? Yes 

14 Rate of Progress Achieved?8 Yes 

1

Computed by subtracting the Federal Motor Vehicle Control Program (FMVCP) and Reid Vapor Pressure (RVP) emission 

reductions (Table 7-2) from the 1990 base year inventory: 633.2 tons/day-80.2 tons/day=553 tons/day. 

2

The actual 2008 VOC inventory was calculated by subtracting 3.1 tons/day (from expansion of Enhanced I/M program) 

and 2.3 tons/day (reductions from adopted rules—see Table 7-3) from 374.9 tons/day (2008 planning inventory—see 

Table 3-1). 

3

The VOC emission reduction shortfall can be computed by subtracting line 4 (2008 actual emissions) from line 3 (2008 

target emissions).

4

The FMVCP and RVP program emission reductions are zero for NOx, so the adjusted 1990 base year emissions 

inventory is the same as shown in Table 7-1 (805.1 tons/day). 

5

Computed by multiplying the VOC shortfall by 1.27 to reflect the NOx/VOC ratio in the base year. 

6

The actual 2008 NOx inventory was calculated by subtracting 5.7 tons/day (from expansion of Enhanced I/M program) 

and 12.4 tons/day (reductions from adopted rules—see Table 7-3) from 429.1 tons/day (2008 planning inventory—see 

Table 3-1). 

7

Reflects new FMVCP/RVP values of 53.6 tpd of VOC emissions reductions for 2002 and 70.1 tpd for 2005 (and therefore 

does not match the values given in the Amended 2002 and 2005 Rate of Progress Plan for San Joaquin Valley Ozone). 

Recalculated NOx reductions needed for substitution are 40.9 tpd for 2002 and 61.5 tpd for 2005, for a total of 102.4 tpd 

used previously. Nothing in this recalculation affects conformity budgets for 2002 and 2005 as established in the 

Amended 2002 and 2005 Rate of Progress Plan for San Joaquin Valley Ozone, and as found adequate by EPA in 2003. 

8

Because the 2008 Rate of Progress demonstration needs 125.1 tons/day of NOx reductions and 291.7 tons/day of NOx 

reductions are available, the Rate of Progress is achieved. 
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SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-8

2008 ROP DEMONSTRATION

271.0

369.4

553.0

100

200

300

400

500

600

1990

Year

2008

Precursor Emissions (tons/day)

Required VOC emissions

Actual VOC emissions

Constant adjusted 1990 VOC

emissions

183.6 tons/day of VOC 

Reductions Achieved

Additional 98.4 

tons/day of VOC 

emissions reductions 

needed to meet 51% goal; 

translated to 125.1

tons/day of NOx.

Figure 7-1. 

Graphical Summary of 2008 ROP Demonstration 

For San Joaquin Valley Ozone 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-9

235.9 tons/day. In other words, achieving the 57 percent reduction from the 

adjusted base year emissions inventory would produce a 2010 VOC emissions 

inventory of 235.9 tons/day. If the actual 2010 VOC emissions inventory is 

greater than this, then VOC emission reductions alone are insufficient to meet 

regulatory requirements, and reductions in NOx emissions must be sought in 

order to meet the 57 percent requirement. 

7.5.2 2010 Rate of Progress 

7.5.2.1 VOC Emission Reductions 

As noted in Section 7.3 and presented in Table 3-1, the 2010 actual VOC 

emissions inventory is estimated to be 367.6 tons/day. Emission reductions from 

post-2002 District control measures reduce this total by an additional 2.4 

tons/day (Table 7-3) and expansion of the Enhanced I/M program contributes 

another 2.5 tons/day of reductions, which reduces the total 2010 VOC emissions 

to 362.7 tons/day. Since the target 2010 VOC emissions inventory is estimated 

at 235.9 tons/day, the actual inventory is too high by about 126.8 tons/day to 

meet the required 57 percent reduction over the 1990—2010 time frame. 

7.5.2.2 NOx Emissions Reductions 

The FCAA allows Districts to substitute reductions in NOx emissions when they 

are unable to achieve the necessary reductions with VOC emissions alone [Title 

1, Part D, Decision 182(c)], provided the conditions spelled out by the FCAA are 

met. More information on these terms and conditions is given in Section 7.4.2.2. 

The NOx base year emissions inventory is 805.1 tons/day (Table 7-1). No 

corrections for FMCVP or RVP are needed. Computing the required NOx 

emissions reductions thus involves multiplying the VOC shortfall by 1.27 to reflect 

the NOx/VOC ratio in the base year, which produces a total of 161.2 tons/day of 

NOx emissions that are needed to help the VOC emission reductions meet the 

final ROP requirement of 57 percent reduction. 

The actual 2010 NOx emissions inventory is 401.7 tons/day (Table 3-1); control 

measure emission reductions not reflected in this total will reduce emissions by 

an additional 12.2 tons/day (Table 7-3) and expansion of the Enhanced I/M 

program contributes another 5.0 tons/day of reduction to reduce the actual NOx 

inventory to 384.5 tons/day. Actual emissions reductions achieved [the 

difference between the 2010 actual and 1990 base year (805.1 tons/day) 

emissions inventories] are therefore 420.6 tons/day. NOx reductions used 

previously for substitution account for 227.5 tons/day4

, leaving 193.1 tons/day of 

 

4

 Reflects the sum of the recalculated 2002 and 2005 NOx substitution (102.4 tpd) and the 2008 

NOx substitution (125.1 tpd). See Footnote #2. 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-10

NOx reductions available for substitution in 2010. Since the 2010 ROP milestone 

requires NOx reductions of 161.2 tons/day, and 193.1 tons/day are available, 

adequate NOx emissions reductions have been achieved to help the VOC 

emissions reductions meet the overall 2010 ROP requirement of a 57 percent 

reduction in precursor emissions. 

As discussed in Chapter 5, the NOx carrying capacity for attainment is about 344 

tons/day in 20105

. The 1990 base year NOx inventory is about 805 tons/day. 

Thus attainment of the federal 1-hour ozone standard in the SJVAB requires a 

cumulative reduction in NOx emissions of about 461 tons/day over the period 

1990—2010. NOx reductions needed to meet ROP reductions over the time 

frame 1990—2010 total 388.7 tons/day6

. Thus, the cumulative NOx reductions 

needed to meet the final ROP milestone are less than the NOx reductions 

needed for attainment, and thus are consistent with EPA guidance (EPA 1993 

and EPA 1994b). 

Finally, it should be mentioned that a number of peer-reviewed studies [e.g., Pun 

et al. (1998) and SJVAQSA (1996)] have determined that attainment of the 

federal 1-hour ozone standard in the SJVAB requires NOx emissions controls7

, 

so the use of NOx reductions in SJVAB ROP calculations over the 1990—2010 

time frame is consistent with the overall attainment demonstration strategy for the 

SJVAB as determined by gridded photochemical modeling. EPA’s guidelines on 

ROP plans and NOx substitution identify consistency with overall attainment 

strategy as a key factor affecting the appropriateness and extent of NOx 

substitution for ROP calculations (EPA 1994). 

7.5.2.3 Summary 

Table 7-5 summarizes the emission calculations performed to demonstrate 

achievement of a 57 percent reduction in precursor emissions from 1990 through 

2010. Figure 7-2 provides a graphical illustration of the emission trends and 

reductions. 

 

5

 Based on gridded photochemical modeling and a reduction in NOx emissions of about 15% of 

the 2010 inventory and a reduction of about 15% of the 2010 VOC inventory. As shown in 

Figure 5-5, other combinations of NOx and VOC emissions reductions within this general range 

can also demonstrate attainment. 

6

 Reflects the sum of NOx substitution reductions for 2002 (40.9 tpd), 2005 (61.5 tpd), 2008 

(125.1 tpd) and 2010 (161.2 tpd). 

7

 Analyses done for this Extreme OADP, as presented in Chapter 5, also identify the need for 

NOx emissions controls to attain the federal 1-hour ozone standard in the SJVAB. 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-11

TABLE 7-5 

2010 Rate of Progress Demonstration Summary 

Line # Emission Calculation 

Emissions 

(tons/day) 

1 Adjusted 1990 Base Year VOC Inventory1

 548.5 

2 VOC Reduction Required (57% of Line 1) 312.6 

3 Target 2010 VOC Emissions Inventory (Line 1 minus Line 2) 235.9 

4 Actual 2010 VOC Emissions Inventory2

 362.7 

5 VOC Reductions Achieved (Line 1 minus Line 4) 185.8 

6 VOC Reduction Shortfall (Line 2 minus Line 5)3

 126.8 

7 Adjusted 1990 Base Year NOx Inventory4

 805.1 

8 NOx Reductions Required5

 161.2 

9 Actual 2010 NOx Emissions Inventory6 384.5 

10 NOx Reductions Achieved (Line 7 minus Line 9) 420.6 

11 NOx Reductions Used Previously for Substitution7

 227.5 

12 Available NOx Reductions for Substitution in 2010 193.1 

13 Sufficient NOx Reductions Available for Substitution? Yes 

14 Rate of Progress Achieved?8 Yes 

1

Computed by subtracting the Federal Motor Vehicle Control Program (FMVCP) and Reid Vapor Pressure 

(RVP) emission reductions (Table 7-2) from the 1990 base year inventory (Table 3-1): 633.2 tons/day-84.7 

tons/day=548.5 tons/day. 

2

The actual 2010 VOC inventory was calculated by subtracting 2.5 tpd from expansion of Enhanced I/M 

program and 2.4 tons/day [reductions from adopted rules—see Table 7-3] from 367.6 tons/day (2010 

planning inventory—see Table 3-1). 

3

The VOC emission reduction shortfall can be computed by subtracting line 4 (2010 actual emissions) from 

line 3 (2010 target emissions).

4

The FMVCP and RVP program emission reductions are zero for NOx, so the adjusted 1990 base year 

emissions inventory is the same as shown in Table 7-1 (805.1 tons/day). 

5

Computed by multiplying the VOC shortfall by 1.27 to reflect the NOx/VOC ratio in the base year. 

6

The actual 2010 NOx inventory was calculated by subtracting 5.0 tpd from expansion of Enhanced I/M 

program and 12.2 tons/day (reductions from adopted rules—see Table 7-3) from 401.7 tons/day (2010 

planning inventory—see Table 3-1). 

7

Reflects the sum of line 8 and line 11 from Table 7-4. 

8

Because the 2010 Rate of Progress demonstration needs 161.2 tons/day of NOx reductions and 193.1 

tons/day of NOx reductions are available, the Rate of Progress is achieved.
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SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-12

Figure 7-2 

Graphical Summary of 2010 ROP Demonstration 

for San Joaquin Valley Ozone

2010 ROP DEMONSTRATION

100.0

200.0

300.0

400.0

500.0

600.0

700.0

19902010

Year

Precursor Emissions (tons/day)

Required VOC emissions

Actual VOC emissions

Constant adjusted 1990 VOC

emissions

548.5

362.7

235.9

185.8 tons of VOC 

emission reduction 

achieved

Additional 126.8 

tons/day of VOC 

needed to meet 57% 

goal; translated to 

161.2 tons/day of 

NOx.
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SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-13

7.6 PRIOR ROP AND MILESTONE COMPLIANCE 

DEMONSTRATION 

7.6.1 Prior ROP 

The Amended 2002 and 2005 Rate of Progress Plan for San Joaquin Valley 

Ozone adopted in December 2002 and submitted to EPA in 2003 is based upon 

an emissions inventory dated December 5, 2001 (except for the on-road mobile 

source emissions inventory, which is dated November 4, 2002). Emissions 

calculations in this Extreme OADP are based upon Version 2.11_RF932PEI of 

the CCOS Inventory, accessed in January 2004. Given the over two-year 

difference in these inventories, and the rapidly changing state of knowledge of 

ozone precursor emissions in the SJVAB, the District chose to reexamine the 

rate of progress calculations in the Amended 2002 and 2005 Rate of Progress

Plan for San Joaquin Valley Ozone to see if the rate of progress calculations still 

show that the SJVAB met its emissions reductions requirements for 2002 and 

2005. This section revisits the demonstration of rate of progress with the more 

recent inventory used in this Extreme OADP. This reexamination is not required 

by the federal Clean Air Act or associated regulations, but is done to provide the 

public with a full accounting of emissions as related to regulatory requirements. 

Furthermore, this reexamination in no way affects SJVAB conformity budgets 

established for 2002 and 2005 in the Amended 2002 and 2005 Rate of Progress 

Plan for San Joaquin Valley Ozone; EPA found these budgets to be adequate on 

July 10, 2003 (Broadbent 2003). 

In general, emissions inventories improve over time through incorporation of 

more accurate activity data, new emissions factors, new control factors, and 

better coverage and allocation of emissions to sources. The District and ARB 

prepare SIP submittals with the best available emissions data at the time of plan 

development. The emissions inventory used in this Extreme OADP (CCOS 

Version 2.11_RF932PEI) is generally thought to be a more accurate reflection of 

emissions than the inventory used in the Amended 2002 and 2005 Rate of 

Progress Plan for San Joaquin Valley Ozone (December 2002).8

 Table 7-6 

compares the two inventories for the two ozone precursors of interest and the 

three years relevant to the Amended 2002 and 2005 Rate of Progress Plan. 

As noted previously in this chapter and in the Amended 2002 and 2005 Rate of 

Progress for San Joaquin Valley Ozone, the federal Clean Air Act specifies ROP 

milestones as minimum percentages by which 1990 VOC emissions must be 

reduced at a future date. The emissions reduction for 1990—2002 must be 33%, 

 

8

 The more recent inventory does not reflect any changes to the 2002 or 2005 emissions for the 

emission inventory category of on-road motor vehicles. Most of the inventory changes pertain to 

the stationary and area source categories. 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Chapter 7 – Rate of Progress Demonstration 

 7-14

Table 7-6 

Comparison of Unadjusteda

 Emissions Inventories Used 

 in Amended 2002/2005 ROP Plan and Extreme OADP

(Summer, tons/day) 

Amended ROP Plan b Extreme OADP c Ozone 

Precursor 1990 2002 2005 1990 2002 2005 

VOC 670.4 464.3 439.1 633.2 422.9 388.4 

NOx 787.0 533.4 492.2 805.1 519.3 477.3 

Total 1457.4 997.7 931.3 1438.3 942.2 815.7 

a

 Emission reductions from federal, state and District rules for year of inventory not reflected 

b

 Inventory dated December 5, 2001 except for mobile [dated November 4, 2002] 

c

 CCOS Version 2.11_RF932PEI accessed January 2004 

and the reduction for 1990—2005 must be 42% [Title I, Part D, Section 182 

[c](2)].9

 Alternatively, the 2002 VOC emissions inventory must be no greater 

than 67% of the 1990 inventory, and the 2005 VOC inventory must be no greater 

than 58% of the 1990 inventory. Therefore, for the purposes of this section, the 

relationship between future milestone year emissions and the base year 

emissions can be compared from inventory to inventory as a screening tool to 

see if the change in emissions from one inventory to another warrant a full ROP 

calculation for the new inventory. Since the SJVAB met the federal Clean Air Act 

ROP requirements with the “old” inventory, all we need to show is that the ratio of 

future year to base year emissions for the new inventory is equal to or less than 

the same ratios for the old inventory to know that ROP milestones will be met for 

the new inventory as well. 

Analysis of the data in Table 7-6 shows the following for the future year/1990 

ratios of unadjusted10 VOC emissions for the two different inventories: 

Amended ROP Plan Extreme OADP 

2002/1990 2005/1990 2002/1990 2005/1990 

0.6911 0.668 0.67 0.61 

As can be seen, the inventory used in the Extreme OADP has lower future 

year/1990 ratios of VOC emissions, so rate of progress calculations for this 

updated inventory would show better progress than those done using the older 

inventory. Consequently, no additional ROP calculations need to be done to 

determine if the newer emissions inventory adversely affected rate of progress 

calculations for the most recent ROP milestone years (2002 and 2005). 

 

9

 These are minimum percentages; gridded photochemical modeling showing that reductions in 

excess of these levels are needed supersedes the 3%/year requirement (EPA 1994). 

10 Emissions have not been reduced to account for federal, state and local control programs. 11 The Amended ROP Plan demonstrated ROP for these years (even though the ratios shown 

would suggest otherwise) because state and District control measures reduced future year VOC 

emissions and because NOx substitution allowed the ROP requirements to be met. 
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7.6.2 Milestone Compliance Demonstration 

Section 182 (g) of the federal Clean Air Act requires nonattainment areas to 

determine if they have achieved the emissions reductions identified during 

previous three-year reasonable further progress (RFP)/rate of progress (ROP) 

intervals (see Section 7.4) as being needed to meet the RFP/ROP milestones for 

the intervals in question. In other words, nonattainment areas must look back 

following the completion of an RFP/ROP interval (e.g., 2000 to 2002) to see if 

control measures achieved the reductions necessary for that milestone (e.g., 

2002). 

The District prepared this Extreme OADP in 2004 using the CCOS emissions 

inventory version 2.11 that reflects state and District control measures adopted 

through September 2002. For the purposes of this section, this inventory is 

assumed to be the best available actual 2002 emissions inventory. Since the 

most recent ROP three-year interval that has been completed is 2000—2002, it 

is of interest to examine the SJVAB’s 2002 inventory from CCOS version 2.11 to 

see if the year 2002 ROP milestone of a 33% reduction in emissions (from the 

1990 base year specified in the federal Clean Air Act) occurred in the SJVAB. 

The adjusted 1990 SJVAB base year VOC emissions (for the 2002 ROP 

milestone) from the CCOS version 2.11 emissions inventory total 579.6 tons per 

day (Table 7-2). The 2002 VOC emissions from the same CCOS inventory total 

422.9 tons per day (Table 7-6). The 1990—2002 improvement, according to 

data in version 2.11 of the CCOS inventory, is therefore 156.7 tons per day, or 

about 27% of the adjusted base year inventory. This is about 6% short of the 

33% reduction required for the 2002 milestone. As discussed in the previous 

sections, the District is allowed to use NOx substitution for ROP in the SJVAB. 

The adjusted 1990 SJVAB base year NOx emissions from the CCOS version 

2.11 inventory total 805.1 tons per day, and the 2002 NOx emissions from the 

same inventory total 519.3 tons per day (Table 7-6). Transferring this 6% 

shortfall to the CCOS version 2.11 1990 NOx emissions shows that about 48.3 

tons per day of NOx reductions (6% of 805.1 tons per day) are needed over the 

time frame 1990—2002 to meet the 2002 ROP milestone. The NOx reductions 

achieved in this time, as given in CCOS version 2.11, are 285.8 tons per day 

(805.1 tons per day minus 519.3 tons per day), which greatly exceeds the 

amount required. Therefore, the SJVAB met the 2002 ROP milestone. 

The above information clearly shows that the SJVAB’s 2002 ozone precursor 

emissions, as accessed in 2004 from the CCOS version 2.11 inventory, meet the 

federal Clean Air Act requirements for ozone precursor emissions reductions for 

the 2002 ROP milestone year. Consequently, the SJVAB meets Section 182(g) 

requirements at this point in time. 
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7.6 REFERENCES 

Broadbent 2003 Jack Broadbent, Director, Air Division, U.S. Environmental 

Protection Agency, Region IX, 75 Hawthorne Street, San 

Francisco, California. Letter to Catherine Witherspoon, 

Executive Officer, California Air Resources Board, 

Sacramento, California, July 10, 2003. 

EPA 1993 U.S. Environmental Protection Agency. NOx Substitution 

Guidance, Office of Air Quality Planning and Standards, 

Research Triangle Park, NC, December 1993 

EPA 1994a United States Environmental Protection Agency. Guidance on the 

 Post-1996 Rate-of-Progress Plan and the Attainment 

Demonstration. EPA-452/R-93/015 (corrected version, 

February 18, 1994). 

EPA 1994b U.S. Environmental Protection Agency. Clarification of Policy 

for Nitrogen Oxides (NOx) Substitution, Memorandum from 

John S. Seitz to EPA Directors, Office of Air Quality Planning 

and Standards, Research Triangle Park, North Carolina, 

August 5, 1994. 

Pun, B.K., 1998 A Conceptual Model for Ozone Formation in the San 

Joaquin Valley, Prepared for Pacific Gas and Electric 

Company, December 15, 1998 (with J-F Louis and C. 

Seigneur) 

SJVAQSA 1996 San Joaquin Valley Air Quality Study Agency, San Joaquin 

Valley Air Quality Study, Policy Relevant Findings, 

November 1996. 

SJVUAPCD 2000 2000 Ozone Rate of Progress Report, San Joaquin Valley 

Unified Air Pollution Control District, Fresno, California, April 

20, 2000 (revised April 27, 2000). 

SJVUAPCD 1994 Revised 1993 Rate of Progress Plan. San Joaquin Valley 

Unified Air Pollution Control District, Fresno, California, 

November 4, 1994. 

SJVUAPCD 1995 Revised Post 1996 Rate of Progress Plan. San Joaquin 

Valley Unified Air Pollution Control District, Fresno, 

California, September 20, 1995. 

SJVUAPCD 2002 Amended 2002 and 2005 Rate of Progress Plan for San 

Joaquin Valley Ozone. San Joaquin Valley Unified Air 

Pollution Control District, Fresno, California, December 31, 

2002. 
Chapter 8 – CALIFORNIA CLEAN AIR ACT

 TRIENNIAL PROGRESS REPORT

 AND PLAN REVISION 
❖
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8 CALIFORNIA CLEAN AIR ACT TRIENNIAL PROGRESS 

REPORT AND PLAN REVISION 

8.1 INTRODUCTION

Section 40910 of the California Health and Safety Code (CH&SC) requires air 

pollution control districts in the state to achieve and maintain state ambient air 

quality standards for ozone, carbon monoxide, sulfur dioxide and nitrogen dioxide 

at the earliest practicable date. Section 40911 of the CH&SC requires all districts 

designated as nonattainment for the state standards for ozone, carbon 

monoxide, sulfur dioxide, or nitrogen dioxide to prepare and submit a plan for 

attaining and maintaining the standards to the California Air Resources Board 

(ARB). Section 40924 (b) of the CH&SC requires districts to prepare a report 

every three years summarizing progress in meeting the schedules for 

developing, adopting, and implementing the air pollution control measures 

contained in each district’s plan for attaining the California air quality standards. 

Section 40925(a) of the CH&SC requires districts to review and revise their 

original 1991 Air Quality Attainment Plan (AQAP) to correct for deficiencies in 

meeting the interim measures of progress incorporated into the plan pursuant 

Section 40914 [emission reductions], and to incorporate new data or projections 

into the Plan. This requirement, termed a Triennial AQAP Revision, is on the 

same reporting schedule as the Triennial Progress Report, and is usually 

combined with the progress report. 

In January 1992, the District prepared and adopted the 1991 Air Quality 

Attainment Plan (AQAP) [SJVUAPCD 1992]. ARB approved this plan in 

December 1992. The 1991 AQAP covers ozone and carbon monoxide, since the 

District was classified as nonattainment for these two state standards at that 

time.1

 In accordance with the CH&SC, the District subsequently prepared 

Triennial Progress Reports and Plan Revisions as updates to this initial 1991 

AQAP in 1998 and in 2001 (SJVUAPCD 1998; SJVUAPCD 2001). 

This Chapter of the Extreme OADP represents the third Triennial Progress 

Report and Plan Revision for the District; as such, it covers the period 2000-

2002, and its original due date was December 31, 2003. However, for Districts 

preparing State Implementation Plan (SIP) submittals in 2004, ARB revised the 

due date to be the time of the 2004 SIP submittal. 

Because the District has attained the California ambient air quality standard for 

carbon monoxide, ARB no longer requires the District to address carbon 

 

1

 The District was also designated as nonattainment for the state particulate matter standard; 

however, as noted above, Section 40911 does not require the development of plans for districts 

that are designated nonattainment for California particulate matter standards. 
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monoxide in progress reports and plan revisions. This chapter of the Extreme 

OADP thus focuses on the state ambient air quality standard for ozone (as 

opposed to the other chapters of the Extreme OADP that address compliance 

with federal ozone standards). 

In 1998, the District adopted the California Clean Air Act Triennial Progress 

Report and Plan Revision 1995-1997 (1997 Triennial Update); ARB approved 

this report in October 1999. No change in the District’s ozone attainment 

strategy was set forth in the Update. In 2001, the District adopted the California 

Clean Air Act Triennial Progress Report and Plan Revision 1997-1999 (2000 

Triennial Update). No change in the District’s ozone attainment strategy was set 

forth in the Update. The District’s adopted strategy is based on the latter 

alternative. For the 2000-2002 period, this chapter of the OADP represents the 

triennial plan (2003 Triennial Update). 

8.1.1 Attainment Designation 

California’s ambient air quality standard for ozone is 0.09 ppm. For an area to 

attain the state 1-hour ozone standard, representative and complete ambient air 

quality monitoring data must show that measured 1-hour average ozone levels 

did not exceed 0.09 ppm (CH&SC 70303, 70304). Unlike the federal standard, 

the state ozone standard is strictly a level not to be exceeded. Thus, occurrence 

of even a single one-hour period with measured ozone levels in excess of 0.09 

ppm is enough to designate an area as nonattainment for the state standard 

(unlike the federal 1-hour ozone standard, in which four exceedances in three 

years are needed for designation as nonattainment). Also unlike the federal 

standard, State law does not establish attainment dates for ambient standards, 

but instead requires evaluation of trends and continued progress in reducing 

emissions that lead to unhealthy pollutant levels. 

Based on the designation criteria established by Section 40921.5 of the 

California Health and Safety Code, ARB has classified the SJVAB as severe 

nonattainment for the California 1-hour ozone standard. Because of this 

classification, the District is subject to stringent requirements in the CCAA and 

must apply all feasible measures to reduce emissions. 

8.1.2 Air Basin Description 

The San Joaquin Valley (Valley) is a major geographic, population, and 

agricultural region of California. The District, and the corresponding air basin, 

includes the counties of San Joaquin, Stanislaus, Merced, Madera, Fresno, 

Kings, Tulare and the Valley portion of Kern County. Comprising about 24,840 

square miles, it represents approximately 16% of the geographic area of 

California and is the second largest air basin in California. The California 

Department of Finance estimates that the District’s population will grow to 3.6 
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million by 2005. Major urban centers include Bakersfield, Fresno, Modesto and 

Stockton. 

The Valley consists of a continuous inter-mountain valley that is approximately 

250 miles long and averages 80 miles wide. It is defined by the Sierra Nevada 

mountains in the east (8,000 to 14,000 feet in elevation), the Coast Range in the 

west (reaching 5,020 feet in elevation), and the Tehachapi mountains in the 

south (6,000 to 8,000 feet in elevation). The Valley opens to the Carquinez 

Straits in the north where the San Joaquin-Sacramento Delta empties into San 

Francisco Bay. Except for its foothill and mountain areas, the SJVAB is 

essentially flat with a slight downward gradient to the northwest. 

Approximately 31 percent of the total land area within the SJVAB is under public 

ownership. The federal government is the largest public landholder, with 

approximately 94 percent of the total public-owned land under its jurisdiction. For 

the most part, the holdings consist of National Forest lands, National Parks, 

wildlife refuge areas, plus a major military air base located on the Valley floor. 

The Valley is predominately agriculturally oriented, including foothill and 

mountain areas devoted to grazing and timber sales. Currently, the majority 

of industry remains directly or indirectly related to providing services, 

products and support to agriculture. In addition, industries related to the 

production of natural resources are scattered throughout the District. 

Various lumbering operations that process timber harvested from the nearby 

National Forests and private forestlands are located along the east side of 

the District. The District also has substantial petroleum production fields in 

the southern counties, while oil refineries are located in Kern County. See 

Chapter 2 for more detailed information on the SJVAB. 

8.2. OZONE AIR QUALITY INDICATORS

8.2.1 Air Quality Indicators 

A number of ways exist to characterize ozone air quality trends. ARB has 

identified three air quality indicators for districts to use in the preparing 

triennial updates to ozone attainment plans. These are the Expected Peak 

Day Concentration (EPDC), the Population Weighted Exposure (PWE) and 

the Area Weighted Exposure (AWE). The following sections provide 

background information on each, along with an overview of the calculation 

procedure. 

8.2.2 Expected Peak Day Concentration (EPDC) 

The EPDC represents the maximum ozone concentration expected to 

occur once per year, on average. The EPDC is based on a statistical 

calculation of ambient ozone data collected at each monitoring site in the 
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district. The EPDC is useful for tracking air quality progress at individual 

monitoring locations. Because it is based on a robust statistical 

calculation, it is relatively stable, thereby providing a trend indicator that is 

not highly influenced by year-to-year changes in meteorology. 

The EPDC is calculated using ozone data for a three-year period (the 

summary year and two years immediately before the summary year). The 

data included in the calculation are daily maximum 1-hour ozone 

observations. However, when three years of data are not available, an 

EPDC can be calculated using only one or two years of data. The EPDC 

is computed using a statistical procedure that fits an exponential-tail model 

to the upper tail of the distribution of concentrations. The fitted distribution 

then is used to determine analytically the concentration that is expected to 

recur at a one-in-one year rate. 

8.2.3 Exposure Indicators 

8.2.3.1 Description 

The exposure indicators provided are the population-weighted (PWE) and areaweighted exposure (AWE) indictors. These are intended to provide an indication 

of the potential for chronic adverse health impacts. Unlike the EPDC, which 

tracks progress at individual locations, the population-weighted and areaweighted exposure indicators consolidate hourly ozone monitoring data from all 

sites within the district into a single exposure value. The result is a value 

representing the average potential exposure in an area, which in this case, is a 

district. The term “potential” is used, because daily activity affects an individual’s 

exposure. For example, being indoors during peak ozone concentrations will 

decrease a person’s exposure to outdoor ozone concentrations. 

The purpose of the population-weighted indicator is to characterize the potential 

average outdoor exposure per person to concentrations above the level of the 

state ozone standard. The population-weighted exposure indicator represents a 

composite of exposures at individual locations that have been weighted to 

emphasize equally the potential exposure for each individual in an area. In 

contrast, the purpose of the area-weighted exposure indicator is to characterize 

the potential average annual outdoor exposure per unit area. The area-weighted 

exposure indicator represents a composite of exposures at individual locations 

that have been weighted to emphasize equally the potential exposure in all 

portions of the district. 

The exposure analysis is based solely on ambient (outdoor) ozone data. The 

calculation methodology assumes that an “exposure” occurs when a person 

experiences a 1-hour ozone concentration outdoors that is higher than 0.09 ppm, 

the level of the State standard. The PWE and AWE consider both the level and 

duration of ozone concentrations above the State standard. 
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The annual exposure is the sum of all the hourly exposures during the year and 

presents the results as an average per exposed person or average per exposed 

unit land area. 

8.2.3.2 Calculation 

The Time Period: The population-weighted and area-weighted exposure 

indicators are computed as an annual value for each year. 

Air Quality Data: The air quality data used for computing the exposure 

indicators are hourly ozone data. All available data for sites in the district are 

used, regardless of whether the data meet designation criterion for complete and 

representative data. Because the individual exposure values are interpolated 

from data for several monitoring sites, the data for all the sites do not need to be 

complete for all hours. 

Census Data: The exposure computations are based on census data collected 

by the federal government. For the years from 1985 to 1999, the population 

statistics are based on the 1990 census. For the years 2000, 2001, 2002, 

population data from the 2000 census was used. 

The federal government has divided the nation into census tracts for the 

purpose of counting population and obtaining demographic information. Each 

of these census tracts has associated with it: a (1) centroid of the census 

tract, (2) the population residing within the census tract, and (3) the land area 

of the census tract. The population within each census tract is used in 

computing the annual population-weighted exposure, whereas, the land area 

of the census tract is used in computing the annual area-weighted exposure. 

The centroid of the census tract is used in computing both exposure 

indicators. 

Calculation Procedure for Population-Weighted Exposure: Hourly ozone 

concentrations are interpolated to each census tract centroid. Hourly ozone 

exposures are computed for each centroid by subtracting the value of the 

State ozone standard (0.09 ppm) from each interpolated hourly concentration. 

If negative, the result is set equal to zero. The hourly exposures for each 

census tract are multiplied by the number of people residing in the census 

tract. These hourly exposures are then added together and divided by the 

total population of all of the census tracts for which interpolated exposure 

values are available. 

The result represents an hourly population-weighted exposure for the district. 

The hourly exposures are aggregated into a daily population-weighted 

exposure. 
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The daily exposures are then aggregated into an annual population-weighted 

exposure. This is done for each year from 1985 through 2002, for which data 

are available. 

Calculation Procedure for Area-Weighted Exposure: The procedure for 

computing the area-weighted exposure is similar. In this case, the hourly 

exposures for each census tract are multiplied by the square kilometer land 

area of the census tract. These hourly exposures are then added together 

and divided by the total land area of all of the census tracts for which 

interpolated exposure values are available. The result represents an hourly 

area-weighted exposure for the district. The hourly exposures are 

aggregated into a daily area-weighted exposure. The daily exposures are 

then aggregated into an annual area-weighted exposure. This is done for 

each year from 1985 through 2002, for which data are available. 

8.3 PROGRESS TOWARD AIR QUALITY STANDARD 

ATTAINMENT 

Pursuant to California Health and Safety Code (H&SC) section 40924, on 

or before December 31, 2003, the District is required to assess the extent 

of air quality improvement achieved during the preceding three years 

(2000-2002)1. The assessment of improvement should be based on: 1) 

ambient pollutant measurements; 2) best available modeling techniques; 

and 3) air quality indicators identified by the State Board for that purpose. 

Based on the ARB guidance document, Guidance for Using Air QualityRelated Indicators in Reporting Progress in Attaining the State Ambient Air 

Quality Standards, the District's assessment of improvement is based on 

air quality indicators and confirmed by ambient measurements and 

modeling. 

Ambient pollutant measurements are collected from monitoring stations 

within the SJVAB and are incorporated into the ARB's annually published 

Air Quality Data. Data used to prepare the annual statistics shown in Air 

Quality Data are reflected in the air quality indicators discussed below. 

Table 8-1 provides trend data for the SJVAB with respect to the state 

ozone standard.2

 As shown in Table 8-1, the number of days per year 

with 1-hour ozone levels above the state standard in the SJVAB has 

decreased slightly from 1990 through 2002. The remainder of this section 

emphasizes the indicators required by ARB for inclusion in this report. 

 

1

 For triennial Reports due in 2003, ARB modified the due date for air basins also preparing SIP 

submittals, and stated that the triennial Reports could be submitted with, and at the same times 

as, SIP submittals in the 2003-2004 time frame. 

2

 Chapter 2 presents SJVAB monitoring data with respect to the federal 1-hour ozone standard. 
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ARB staff has prepared data showing EPDC trends, population-weighted 

ozone exposure and area-weighted ozone exposure for many of the 

monitoring sites in the District that have been in operation long enough to 

have the necessary data (six years). The EPDC trends for the SJVAB for 

the period 2000—2002 show a wide degree of variability in that some are 

relatively steady, others decreasing, and a few showed increases (Figures 

8-1 through 8-8). Of the three-year period of interest for this Triennial 

Progress Report and Plan Revision (2000—2002), the year 2002 seemed 

to be when most sites experienced an increase in EPDC values. 

Comparison of Figures 8-1 through 8-8 with the SJVAB trends for the 

federal standard (Chapter 2) indicates that 2002 also showed deteriorating 

ozone air quality, reflecting the same emissions levels and meteorological 

conditions that shaped the trends in EPDC levels in this time frame. 

TABLE 8-1 

SJVAB Ozone Exceedances 

1990-2002 

 

Year No. of 

Hours 

Above 

State 

Standard 

No. of 

Days 

Above 

State 

Standard 

1990 711 131 

1991 788 133 

1992 735 127 

1993 743 125 

1994 808 118 

1995 807 124 

1996 936 120 

1997 586 110 

1998 801 90 

1999 775 123 

2000 691 114 

2001 221 123 

2002 850 127 

Source: ARB 2004b 

The area-weighted exposure chart (Figure 8-9) shows a general improvement in 

air quality since 1996. For the most recent reporting period (2000-2002), the 

trend in this metric is generally downward, thereby showing continued 

improvement. However, AWE does show an increase from 2001 to 2002, again 

reflecting the same conditions affecting the EPDC trends and federal ozone 

standard tracking given in Chapter 2. 

The population-weighted exposure chart (Figure 8-10) prepared by the ARB 

shows that exposure to ozone (adjusted to reflect population distribution 
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and to give more "weight" to higher ozone values) has declined 

approximately 100 hours per person per year within the District between 

1986 and 1993. Since 1993, the metric has shown year-to-year fluctuation 

near the value of 1.60 ppm-hrs per person. For the most recent reporting 

period (2000-2002), the metric showed a downward trend, with again a 

slight increase from 2001 to 2002. 

In summary, the data prepared pursuant to H&SC section 40924 shows 

that expected "peak day" concentration, per-capita annual exposure, and 

per-unit-area annual exposure for ozone have slightly declined within the 

SJVAB since reporting of these statistics began. The nature of the trends 

varies with monitoring site, and each site’s trend reflects emissions and 

meteorological conditions, as well as the influence of other parameters (for 

example, the population weighted average is also affected by trends in 

population in the SJVAB. As shown in the following sections, the District 

has been aggressively developing and implementing ozone precursor 

emission control measures to improve ozone air quality in the SJVAB. 

Though these emissions reductions have been driven by compliance with 

federal requirements, they will help the SJVAB demonstrate continued 

progress toward meeting state ambient air quality standards as well. 

Figure 8-1

 Expected Peak Day Concentration (EPDC) at the Arvin-Bear 

Site 

0.090

0.100

0.110

0.120

0.130

0.140

0.150

0.160

0.170

0.180

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002

Year (End Year of Three)

Ozone (ppm)

EPDC

Baseline

State Standard: 0.09 ppm 

Source: ARB and SJVUAPCD 
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Figure 8-2

 Expected Peak Day Concentration (EPDC) at the Bakersfield 

Golden State Site. 

0.090

0.100

0.110

0.120

0.130

0.140

0.150

0.160

0.170

0.180

1994 1995 1996 1997 1998 1999 2000 2001 2002

Year (End Year of Three) 

Ozone ppm

EPDC

Baseline

Figure 8-3 

Expected Peak Day Concentration (EPDC) at the Bakersfield 

California Ave. Site

0.090

0.100

0.110

0.120

0.130

0.140

0.150

0.160

0.170

0.180

1996 1997 1998 1999 2000 2001 2002

Year (End Year of Three)

Ozone (ppm) 

EPDC

Baseline

State Standard: 0.09 ppm 

Source: ARB and SJVUAPCD 
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Figure 8-4

 Expected Peak Day Concentration (EPDC) at the 

Clovis N. Villa Ave. Site 

0.090

0.100

0.110

0.120

0.130

0.140

0.150

0.160

0.170

0.180

1993 1994 1995 1996 1997 1998 1999 2000 2001 2002

 Year (End Year of Three)

Ozone (ppm)

EPDC

Baseline

Figure 8-5

Expected Peak Day Concentration (EPDC) at the 

Fresno 1st Street Site

0.090

0.100

0.110

0.120

0.130

0.140

0.150

0.160

0.170

1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002

Year (End Year of Three)

Ozone (ppm)

EPDC

Baseline

State Standard: 0.09 ppm 

Source: ARB and SJVUAPCD 
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Figure 8-6

Expected Peak Day Concentration (EPDC) at the

Hanford-Irwin Street Site

0.090

0.100

0.110

0.120

0.130

0.140

0.150

0.160

0.170

0.180

1996 1997 1998 1999 2000 2001 2002

Year (End Year of Three)

Ozone (ppm)

EPDC

Baseline

Figure 8-7

Expected Peak Day Concentration (EPDC) at the

Maricopa-Stanislaus Street Site

0.090

0.100

0.110

0.120

0.130

0.140

0.150

0.160

0.170

0.180

1996 1997 1998 1999 2000 2001 2002

Year (End Year of Three)

Ozone (ppm)

EPDC

Baseline

State Standard: 0.09 ppm 

Source: ARB and SJVUAPCD 
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Figure 8-8

Expected Peak Day Concentration (EPDC) at the 

Merced-South Coffee Ave. Site

0.090

0.100

0.110

0.120

0.130

0.140

0.150

0.160

0.170

0.180

1994 1995 1996 1997 1998 1999 2000 2001 2002

Year (End Year of Three)

Ozone(ppm)

EPDC

Baseline

Figure 8-9

Area Weighted Exposure per Square Kilometer

0.10

0.60

1.10

1.60

2.10

2.60

3.10

3.60

4.10

1985 1987 1989 1991 1993 1995 1997 1999 2001 2003

Year (End Year of Three)

Ozone (ppm-hours per square kilomenter

Three Year Moving Average Area-Weighted Exposure Baseline
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Figure 8-10

Population Weighted Exposure per Person

0.10

0.60

1.10

1.60

2.10

2.60

3.10

3.60

4.10

1985 1987 1989 1991 1993 1995 1997 1999 2001 2003

Year (End of Year Three)

Ozone (ppm-hours per person)

Three Year Moving Average Population-Weighted Exposure Baseline

8.4 TRANSPORT MITIGATION 

The movement of air pollutants across jurisdictional boundaries is called longrange transport, or simply transport. ARB, in cooperation with local air districts, 

is required by the CCAA to evaluate intrastate transport and to suggest mitigation 

for such transport. 

Most violations of ozone ambient air quality standards occur under stagnant 

weather conditions, when pollutant concentrations build up because emitted 

pollutants do not disperse either horizontally or vertically. For ozone, these 

conditions occur on hot, summer days with low wind speed limiting horizontal 

dispersion, and temperature inversions in the atmosphere limiting vertical 

dispersion. Prevailing winds carry air pollutants and precursors from emission 

points to downwind locations, mixing with cleaner air or other emissions along 

the way. Pollutant and precursor concentrations are much lower on windy days 

because emissions are dispersed through larger volumes of ambient air. 

The air quality management community in California generally agrees that 

pollutant transport does occur among the various air districts and air basins in 

California. The wind direction and resulting transport direction may change 

significantly from day to day, depending on specific weather conditions. The 

ARB has identified transport couples (source and receptor areas) throughout 
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California. The San Joaquin Valley Air Basin is identified as both a source and a 

receptor of transported pollutants. 

ARB issued its most recent assessment of ozone transport in California in April 

2001 (ARB 2001), and concluded that transport from the San Francisco Bay Area 

Air Basin and the Broader Sacramento Area contributes to some exceedances of 

the state 1-hour ozone standard in the SJVAB, and that the degree of 

contribution ranges from overwhelming to inconsequential3. ARB also found that 

the SJVAB contributes overwhelmingly to ozone exceedances in the Mojave 

Desert, Mountain Counties, and Great Basin Valley Air Basins, significantly to the 

North Central Coast, and significantly to inconsequentially to the Broader 

Sacramento Area and the South Central Coast (ARB 2001). 

ARB is in the process of analyzing CCOS 2000 data to develop improved 

technical capabilities to better quantify transport. Future triennial progress 

reports and plan revisions will include the results from this body of work. 

In 2003, ARB amended state regulations on ozone transport mitigation. ARB 

retained, with minor revisions to eliminate outdated provisions, the requirement 

for upwind transport districts such as the San Joaquin Valley to apply best 

available retrofit control technology (BARCT). To ensure that upwind districts 

minimize their impact on downwind districts, ARB also added two new 

requirements related to the adoption of all feasible measures and no net increase 

thresholds for new source review permitting programs. The San Joaquin Valley 

was already required to comply with these provisions due to other existing 

CH&SC requirements. The District already had the most stringent new source 

review thresholds and had implemented all feasible measures in lieu of meeting 

the annual five percent ozone precursors emissions reductions requirements. 

Table 8-2 identifies BARCT rules adopted by the District since 1991. The District 

adopted the majority of these rules before 1994 and continues to update them as 

new technology is demonstrated. To ensure that the District continues to include 

all feasible measures applicable to sources under its authority, the District 

reviewed adopted rules of other California Air Districts to determine if other 

measures should be incorporated. The California Air Pollution Control Officers 

Association (CAPCOA) has taken a proactive step to assist in this process by 

developing a list of the most stringent rules adopted by California Air Districts. 

The District participated in the process of developing the list and has reviewed its 

own adopted rules and proposed control measures in the Extreme OADP to 

ensure it meets the “all feasible measure” requirement. 

 

3

 ARB uses three classifications to describe transport: inconsequential, significant, and 

overwhelming (ARB 1990). 
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1 BARCT rules adopted or amended in 1995-1998. 

2 BARCT for larger units was adopted in 1993. BARCT for smaller units was adopted in 1996. 

3

 Last updated in the 2001 to 2003 time frame 

4

 Scheduled for update in this Extreme OADP (see Tables 4-1 and 4-2) 

Table 8-2

BARCT Rules

VOC BARCT 

Rule Rule Name 

44014 Steam-Enhanced Crude Oil Production Well Vents 

44024 Crude Oil Production Sumps 

44034 Components Serving Light Crude Oil or Gases at Light Crude Oil 

and Gas Production Facilities & Components at Natural Gas 

Processing Facilities 

4404 Heavy Oil Test Station - Kern County 

4407 In-situ Combustion Well Vents 

44514 Valves, Pressure Relief Valves, Flanges, Threaded Connections 

and Process Drains at Petroleum Refineries and Chemical Plants 

44524 Pump/Compressor Seals at Petrol. Refineries and Chemical Plants 

4453 Refinery Vacuum Producing Devices or Systems 

4454 Refinery Process Unit Turnaround 

46013 Architectural Coatings 

46023,4 Motor Vehicle and Mobile Equipment Coating Operations 

46033,4 Surface Coating of Metal Parts and Products 

46043 Can and Coil Coating Operations 

46053,4 Aerospace Assembly and Component Manufacturing Operations 

46063,4 Wood Products Coating Operations 

46071,3,4 Graphic Arts 

46211,4 Gasoline Transfer into Stationary Storage Containers, Delivery 

Vessels, and Bulk Plants 

46221 Gasoline Transfer into Vehicle Fuel Tanks 

46244 Organic Liquid Loading 

4625 Wastewater Separators 

46414 Cutback, Slow Cure, and Emulsified Asphalt Paving and 

Maintenance Operations 

46421 Solid Waste Disposal Sites 

46514 Volatile Organic Compound Emissions from Soil Decontamination 

4652 Coatings and Ink Manufacturing 

46534 Adhesives 

4672 Petroleum Solvent Dry Cleaning Operations 

4681 Rubber Tire Manufacturing 

46824 Polystyrene Foam, Polyethylene, and Polypropylene Manufacturing 

46844 Polyester Resin Operations 

4691 Vegetable Oil Processing Operations 

NOx BARCT

43052,3 Boilers, Steam Generators, and Process Heaters 

43524 Solid Fuel Fired Boilers, Steam Generators and Process Heaters 

43541,3 Glass Melting Furnaces 

47011,3 Internal Combustion Engines 

47033 Stationary Gas Turbines 
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8.5 CONTROL MEASURE IMPLEMENTATION

8.5.1 Stationary Source Control Measures 

Table 8-3 presents the District’s rulemaking schedule and adoption activity for 

2001-2003 as developed in the 2000 Triennial Plan Update and Plan Revision 

(SJVUAPCD 2001). 

 Table 8-3*

 2001-2003 Rulemaking Schedule 

RULE CONTROL MEASURE 2000 TRIENNIAL 

PLAN SCHEDULE 

ACTIVITY COMMITMENT

4103 Open Burning 2Q/01 Amendment 1997 Triennial 

Plan & EPA 

Requirement 

4106 Prescribed Burning and 

Hazard Reduction Burning 

2Q/01 New Rule 1997 Triennial 

Plan & EPA 

Requirement 

4623 Organic Liquid Storage 2Q/01 Amendment 1997 Triennial 

Plan & EPA 

Requirement

4662 Organic Solvent 

Degreasing 

2Q/01 Amendment 1997 Triennial 

Plan & EPA 

Requirement 

4663 Organic Solvent Cleaning, 

Storage and Disposal 

2Q/01 New Rule 1997 Triennial 

Plan & EPA 

requirement 

Regulation 

8 

Fugitive Dust 2Q/01 Amendment PM10 ADP & 

EPA SIP 

Deficiency 

4411 Oil Production Well Cellars 3Q/01 New Rule 1997 Triennial 

Plan & EPA 

Requirement

4601 Architectural Coatings 3Q/01 Amendment 1997 Triennial 

Plan & EPA 

Requirement

4692 Commercial Charbroiling 3Q/01 New Rule 1997 Triennial 

Plan & EPA 

Requirement 
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Table 8-3 

2001-2003 Rulemaking Schedule (cont.) 

RULE CONTROL MEASURE 2000 TRIENNIAL 

PLAN SCHEDULE 

ACTIVITY COMMITMENT

4354 Glass Melting Furnaces 2Q/02 Amendment EPA SIP 

Deficiency 

4305** Boilers, Process Heaters, 

and Steam Generators 

3Q/02 Amendment EPA SIP 

Deficiency 

4307 Dryers & Ovens 3Q/02 New Rule EPA RACT 

Requirement 

4311 Flares 3Q/02 New Rule EPA RACT 

Requirement 

4312 Nitric Acid Plants 3Q/02 New Rule EPA RACT 

Requirement 

4313 Foundries 3Q/02 New Rule EPA RACT 

Requirement 

4351** Boilers, Steam Generators 

and Process Heaters – 

Reasonably Available 

Control Technology 

3Q/02 Amendment EPA SIP 

Deficiency 

4610 Mirror Coating Operations 3Q/02 New Rule EPA RACT 

Requirement 

4693 Bakeries 3Q/02 New Rule EPA RACT 

Requirement 

4696 Food Products Cooking 3Q/02 New Rule EPA RACT 

Requirement 

4104 Reduction of Animal Matter 3Q/02 Amendment EPA RACT 

Requirement 

4701** Internal Combustion 

Engines 

3Q/02 Amendment EPA SIP 

Deficiency 

4703** Stationary Gas Turbines 3Q/02 Amendment EPA SIP 

Deficiency 
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Table 8-3 

2001-2003 Rulemaking Schedule (cont.) 

RULE CONTROL MEASURE 2000 TRIENNIAL 

PLAN SCHEDULE 

ACTIVITY COMMITMENT

4403 Components Serving Light 

Crude Oil or Gases at Light 

Crude Oil and Gas 

Production Facilities and 

Components at Natural 

Gas Processing Facilities 

3Q/03 Amendment Feasible 

Control 

Measure

4451 Valves, Pressure Relief 

Valves, Flanges, Threaded 

Connections and Process 

Drains at Petroleum 

Refineries and Chemical 

Plants 

3Q/03 New Rule Feasible 

Control 

Measure 

4452 Pump and Compressor 

Seals at Light Crude oil and 

Gases Production Facilities 

& Components at Natural 

Gas Processing Facilities 

3Q/03 Amendment Feasible 

Control 

Measure 

4701 Internal Combustion 

Engines 

3Q/03 Amendment Feasible 

Control 

Measure 

4703 Stationary Gas Turbines 3Q/03 Amendment Feasible 

Control 

Measure 

Projected emissions reductions associated with the control measures are not included on this 

table. District staff is still in the process of developing this information. Projected emission 

reductions and a revised rulemaking schedule are included in Section 4 of this Extreme OADP. 

Some measures listed above were included in the Amended 2002 and 2005 Rate of Progress 

Plan for San Joaquin Valley Ozone adopted December 19, 2002. Source: SJVUAPCD 2001.

Section 40924(b)(2) of the CH&SC, as well as ARB’s guidance for triennial 

progress reports and plan revisions, directs districts to report actual emissions 

reductions achieved for each measure scheduled for adoption in the three year 

period addressed by each progress report and plan revision. Table 8-4 presents 

this information for the SJVAB, in the 2000—2002 time frame that is the focus of 

this Triennial Progress Report and Plan Revision. 
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8.5.2 Mobile Source Control Measures 

8.5.2.1 Introduction 

Under the CCAA’s severe nonattainment classification for the state ozone 

standard, the District is required to include “reasonably available transportation 

control measures sufficient to substantially reduce the rate of increase in 

passenger vehicle trips and miles traveled per trip...” in its state air quality plans. 

The 2000 Triennial Progress Report and Plan Revision addressed a number of 

TCMs, and this 2003 report updates those discussions and addresses new 

measures identified after the 2000 Triennial Progress Report and Plan Revision. 

Table 8-4 

Actual Emission Reductions 

for District Rules Affecting Ozone Precursor Emissions1

 (2000-2002) 

Rule Date Title Pollutant 

Baseline 

(tons/day) 

Actual 

Reductions 

(tons/day) 

4408 12/19/2002 

Glycol 

Dehydration 

Systems 

VOC 1.7 1.5 

4601 10/31/01 Architectural 

Coatings VOC 9.3 1.3 

4610 12/19/02 Glass Coating 

Operations VOC 0.2 0.2 

4623 12/20/01 Storage of 

Organic Liquids VOC 2.8 0.2 

4662 4/19/01 

Organic Solvent 

Degreasing 

Operations 

VOC 14.0 11.3 

4692 3/21/02 Commercial 

Charbroiling VOC 0.04 0.03 

4693 5/16/02 Bakery Ovens VOC 0.2 0.2 

4703 4/25/02 Stationary Gas 

Turbines NOx 9.6 5.4 

1 Rules may also reduce emissions of other pollutants (e.g., PM), but only ozone precursors 

are shown. 

Reductions from mobile source measures differ from stationary source 

reductions in that they are limited to a specific time period rather than being 

permanent, and they are calculated over the projects’ lifetimes (in large part 

because they are tied to state and federal funding cycles for transportation 

projects).4 Stationary source reductions are referenced on a tons/day basis 

 

4

 This statement primarily reflects mobile source measures for which the District has authority to 

implement or assist in implementation. Mobile source measures for which ARB is responsible 
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because they are cumulative in that they continue to occur day after day, year 

after year, from the same source. The control measures continue to generate 

reductions as long as the controlled source is operating. Due to the nature of 

mobile source emissions control measures, quantifying the actual years in which 

reductions will occur is not possible. For some projects, reductions may be 

limited or tied to a set number of years. For others, emission reductions may 

occur over a set number of years. 

8.5.2.2 District Committed Measures 

The District is continuing to work with the Transportation Planning Agencies 

(TPAs) in implementing previously-committed TCMs and in developing new 

TCMs for SIP submittals. The Memorandum of Understanding (MOU) among the 

District and the eight county TPAs is still in effect. The 2000 Triennial Progress 

Report and Plan Revision mentioned several 9000-series rules that were no 

longer being pursued due to state action; these rules are still inactive. 

District and TPA staffs are working on specific actions and programs to reduce 

vehicle miles traveled (VMT) or to reduce emissions through other activities. 

Local governments in the SJVAB have committed to hundreds of Reasonably 

Available Control Measures in the period 2000—2002. The reader is referred to 

the Amended 2002 and 2005 Rate of Progress Plan for San Joaquin Valley 

Ozone for more information. The document is available on the District’s website 

at www.valleyair.org. Descriptions of specific control measures are available in 

hardcopy at the District office in Fresno, at ARB’s office in Sacramento, or at 

EPA Region 9’s office in San Francisco. 

In addition, The District is working on a number of rules involving mobile sources. 

As shown in Chapter 4 of this Extreme OADP, the rule making schedule includes 

a school Bus Fleet Rule and Indirect Source Rules. Each of these rules is 

directed at reducing emissions from mobile sources. 

The Indirect Source Rules represent a major rule development activity. Indirect 

Source Mitigation is aimed at controlling secondary emissions from development 

that attracts or generates motor vehicle trips. The District is currently evaluating 

rules to implement the Indirect Source Mitigation measure that would require 

mitigation measures and/or emission based fees to fund projects that reduce 

emissions. Developers would have the option for mitigating emissions on-site 

through project design and location, credit for the installation of infrastructure and 

equipment at the project site that would reduce vehicle trips or emissions, and/or 

the payment of a fee. During the 2000—2002 period, the District began the 

 

address motor vehicle technology changes and are quantifiable in amount of reductions and time 

period in which reductions occur. 
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process of revisiting prior rule development activities in this area (that did not 

result in development of indirect source rules). The 2003 PM10 Plan and state 

legislation signed into law in 2003 (SB 700 series) are driving the District to adopt 

indirect source rules in the late 2004/early 2005 time frame. 

8.5.2.3 Voluntary Programs 

The District continued to implement several successful voluntary mobile source 

emission reduction programs in the 2000-2002 time frame. These programs are 

described below. 

During the 2000—2002 time frame covered by this report, the REduce Motor 

Vehicle Emissions (REMOVE) Program utilized a portion of a $4 motor vehicle 

registration surcharge fee allowed by State legislation for nonattainment areas for 

District-operated planning, monitoring, enforcement, technical studies, and 

emission reduction projects necessary to implement the California Clean Air Act 

(CCAA). The REMOVE Program funded projects that reduce motor vehicle 

emissions within the Valley through a competitive request for proposal (RFP) 

process. During the 2000-2001 funding cycle (2 years were treated as one 

cycle) and 2001-2002 funding cycles, the District continued to implement the 

REMOVE Program; projects funded at a cost of almost $3,633,389 resulted in an 

estimated 460 tons of emissions reduction over the lifetime of the projects. The 

REMOVE Program is no longer in existence as of July 2004, but the District 

plans to replace it later in 2004 with a similar program. 

During 2000, 2001 and 2002, the District received 5,997 calls or report slips 

regarding smoking vehicles, with about a 17 percent response rate from 

individuals receiving a “Smoking Vehicle” letter. This voluntary program reduces 

motor vehicle emissions by encouraging owners of smoking vehicles to have 

repairs made to correct problems of high emissions. 

The Heavy Duty Vehicle Emission Reduction Program provides financial 

incentives to municipalities, companies, fleet operators and individuals who 

purchase new heavy-duty, low-emission on-road vehicles from original 

equipment manufacturers (OEM); new OEM heavy-duty, low-emission engines 

for replacements; or retrofit technologies for heavy-duty on-road and non-road 

vehicles meeting criteria guidelines. 

The District is funding its Heavy Duty Vehicle Emission Reduction Program with 

Carl Moyer funds, provided through state legislative action. Since 1999, The 

District has received $18,308,227 on Carl Moyer Program funding. The District 

has provided additional match funding in the amount of $7,658,671. To date, the 

District has obligated all Moyer Program funds for years one, two and three (CMI, 

CMII and CMIII) and approximately 30% of funds for year four (CMIV). 
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Implementation has been successful, particularly with the agricultural community. 

The District has provided Moyer Program incentive funds for projects including 

agricultural pump engines, refuse haulers, street sweepers, tractors, grape 

harvesters, delivery trucks, and almond sweepers. Approximately $25,000,000 

in Moyer Program funds and matching funds has been awarded to fund over 

1,300 cleaner burning engines. Approximately 9,500 tons of NOx reductions 

have resulted from Moyer Program projects. 

Additionally, in 1996, the District began a Spare the Air Program. This voluntary 

program is designed to encourage ridesharing and discourage use of equipment 

and products that emit ozone precursors during the ozone season. The program 

is directed both to employers and the general public. In 1996, 75 employers 

were enrolled in the employer component. By September 1997, the employer 

component had increased to nearly 500 participants, while in 1998 and 1999, the 

employer component ran about 730. The focus of the program in 1999 was 

increasing the active participation of employers already enrolled in the program 

rather than increasing the number of employers in the program. Between 2000-

2002, the employer component grew from 710 to 749. 

8.5.3 Land Use Programs 

Land use programs contain three basic elements: District CEQA review of 

projects in the SJVAB, District Guidelines for Assessing and Mitigation Air Quality 

Impacts, and District Air Quality Guidelines for General Plans. 

In the CEQA Program, the District reviews projects each year from nearly all 

local planning agencies in the San Joaquin Valley. Local jurisdictions routinely 

include air quality mitigation measures recommended by the District in 

development projects. For the period 2000-2002, the District reviewed almost 

4000 projects of varying complexity throughout the 8-county region. In addition, 

the District is increasingly functioning as lead on CEQA documents due to its 

discretionary action of permit issuance. For the period 2000-2002, the District 

reviewed and updated the Guide for Assessing and Mitigating Air Quality Impacts

(SJVUAPCD 2002) to further assist local jurisdictions in analyzing and mitigating 

impacts, and issued a revised version on January 10, 2002. The District is 

preparing another update in 2004. 

In the District’s program to encourage air quality elements in city and county 

general plans, District staff provides assistance to cities and counties via its Air 

Quality Guidelines for General Plans (AQGGP) [SJVUAPCD 1994] and by 

reviewing general plans as they are updated. The AQGGP has been very well 

accepted. Nearly all cities and counties in the District that have prepared general 

plan updates have used the AQGGP since its approval in 1994. In 2002 the 
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District began updating the AQGGP, and expects to issue a revised version in 

2004. 

Also in 2002, the District began developing a manual entitled Internal CEQA 

Guidelines for District Staff. When completed, this manual will guide District staff 

on how to comply with CEQA for the range of District activities, which include 

serving as lead agency on development projects. Other activities related to land 

use include Indirect Source Rules discussed above under Mobile Sources. 

8.6 PLAN REVISION 

8.6.1 Introduction 

The California Clean Air Act requires the District to establish a strategy that will 

achieve an annual average five percent reduction in ozone precursor emissions, 

or alternatively, to commit to taking all feasible measures to reduce emissions 

within its boundaries in an expeditious time frame. The District’s adopted 

strategy is based on the latter alternative. During the 2000-2002 period, the 

District continued to implement its original control strategy of adopting rules to 

fulfill the District’s SIP commitment and then to address additional measures 

needed for attainment of the California ozone standard. The District met all of its 

federally required emission reduction rates (three percent per year for every 

three year period post 1996 until attainment) for 1-hr ozone precursors for the 

2000—2002 period addressed by this report. 

During the 2003-2005 planning cycle, the District will continue its efforts to 

improve its emissions inventory. This will consist of both in-house efforts, joint 

efforts with ARB, and contracting with consultants for updating or developing 

inventories for specific sources. The District will also continue to participate with 

ARB and other districts on analyzing CCOS data and developing modeling tools 

to improve ozone standard attainment planning. In particular, work in 2003-2005 

will focus on developing modeling tools for 8-hour ozone. 

8.6.2 Control Strategy 

The District’s control strategy to reduce ozone pollution is largely driven at 

present by emissions reductions needed to attain the federal 1-hour ozone 

standards and needed to attain the federal PM10 standards. The District is 

implementing an intense rule development schedule to meet commitments in the 

Amended 2002 and 2005 Rate of Progress plan for San Joaquin Valley Ozone

(which includes control measures though 2005) and in the 2003 PM10 Plan

(which contains control measures for PM10 and its precursors, including the 

VOC and NOx out to the year 2010). For ozone rate of progress, the District has 

demonstrated a 33% reduction in ozone precursor emissions over the period 
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1990-2002 by a large margin, thus exceeding federal requirements for ozone 

precursor emissions reductions. The 2003 PM10 Plan calls for a total annual 

NOx reduction of 45.3 tons/day and a total annual VOC reduction of 20.8 

tons/day by 2010. 

Table 8-5 presents the District’s 2003-2005 rulemaking schedule. Beyond 2005, 

the District’s rulemaking schedule becomes even more intense. The PM10 Plan

identifies NOx, VOC and PM10 direct emissions controls through 2010. This 

plan will be revised and resubmitted to EPA in March 2006, so a significant 

evaluation of the control measure commitments will occur in 2005. This Extreme 

OADP identifies control measure commitments through 2010 for VOC and NOx. 

In 2007, the District must develop and submit to EPA an OADP for the 8-hour 

ozone standard, which is expected to call for even more emissions reductions 

than have been identified to date for PM10 and the 1-hour ozone standard. By 

early 2008, the District must develop and submit to EPA plans for attaining the 

PM2.5 standard and the regional haze standard. These plans will also include 

control measure commitments for ozone precursor emissions. The District will 

continue to pursue emissions reductions for VOC and NOx unless and until 

gridded photochemical modeling results indicate air quality benefits from 

controlling emissions of one precursor more than the other. The District also 

intends to continue its strategy of regional control measures and rules; no new 

rules, nor exemptions to existing rules, are being considered for specific subregions within the SJVAB. All of these future federal planning activities will be 

addressed in future Triennial Progress Reports and Plan Revisions. The reader 

is referred to the Amended 2002 and 2005 Rate of Progress Plan for San 

Joaquin Valley Ozone, to the 2003 PM10 Plan; both documents are available on 

the District’s website at www.valleyair.org. Table 4-1 of this Extreme OADP 

includes measures for the 2005 to 2007 time frame. 

The previous Triennial Progress Report and Plan Revision (SJVUAPCD 2001) 

referred to a number of requirements related to classification of the SJVAB as 

severe nonattainment for the federal 1-hour ozone standard. EPA eliminated 

these requirements upon the effective date of the reclassification to extreme 

nonattainment (69 FR 20550). 
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Table 8-5 

Rule Making Schedule for 2003-2005 

Rule Control Measure Adopt/ 

Amend 

Date 

Reason 

4313 (New) Lime Kilns 2Q/03 

1Q-2003 

RACT/RACM 

4305, 4351, & 

4306 

Boilers, Steam Generators 

and Process Heaters 

3Q – 2003 Sanction 

Clock/Fixup/RACM 

4701 & 4702 Stationary IC Engines 3Q – 2003 Sanction 

Clock/Fixup/RACM 

4604 Can and Coil Coating 1Q – 2004 RACM 

4409 New Oil and Gas Fugitives 2Q – 2005 EOADP (Ch. 4) 

4455 New Refinery & Chemical 

Fugitives 

2Q – 2005 EOADP (Ch. 4) 

9510 New 

3180 New 

Indirect Source Mitigation 4Q – 2005 EOADP (Ch. 4) 

4307 New Small Boilers, Process 

Heaters, Steam Generators, 

2.0 – 5.0 MMBtu/hr 

4Q – 2005 EOADP (Ch. 4) 

4694 New Wineries – Fermentation and 

Storage 

4Q – 2005 EOADP (Ch. 4) 

4702 Stationary IC Engines 2Q – 2005 EOADP (Ch. 4) 

4309 New Commercial Dryers 4Q – 2005 EOADP (Ch. 4) 

Source : SJVAPCD 2002; EOADP Ch.4, Table 4-1 

*Control measures shown as deleted were moved into the post-2005 time frame and thus are beyond the scope of this 

Triennial Progress Report and Plan Revision, they will be addressed in the next Triennial Progress Report and Plan 

Revision 

Note: Bold Text indicates that the control measure has been adopted.

8.6.3 Updated Strategy & Expected Reductions 

As requested by ARB in the 2003 “Triennial Assessment and Plan Revisions” 

guidance, the District has included projections of the planning inventory out to the 

year 2020. Table 8-6 presents the requested years of 2010, 2015 and 2020 by 

primary source sector of stationary, area, and mobile sources to provide a longterm view of how emissions are expected to change in the future in the SJVAB. 

Table 8-6 shows that ARB projects the SJVAB emissions to decline over the long 

term. Trends for all three pollutants show a downward trend, with the exception 
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of VOC, which slightly increases from 2010 to 2020, primarily due to area 

sources (but also stationary sources). This increase is most likely due to 

population growth outstripping the ability of area source emission controls in the 

out years. Also of note is a significant downward trend in NOx emissions for onroad and off-road mobile sources, reflecting state and federal emissions controls 

on engines. 

Table 8-6 

Planning Emissions Inventories (summer, tons/day)* 

Source 

Category 

2010 

VOC 

2015 

VOC 

2020 

VOC 

2010 

CO 

2015 

CO 

2020 

CO 

2010 

NOx 

2015 

NOx 

2020 

NOx 

Stationary 93.6 97.4 101.2 53.5 54.5 58.0 136.6 138.3 139.1

Area 171.1 180.7 190.7 419.1 413.8 405.7 5.9 5.9 5.9 

On-Road 

Mobile 

58.5 43.3 34.3 592.0 406.2 291.7 137.4 92.3 64.7 

Other 

Mobile 

41.5 35.4 32.0 380.2 371.5 376.3 118.5 96.0 81.8 

Total 364.7 356.8 358.2 1444.8 1246.0 1131.6 398.3 332.5 291.4

* Represents direct inventory output, CCOS Version 2.11_RF932PEI; no local or state line 

item adjustments made. Also may not match Table 3-1 due to changes in Version 2.11 over 

time. 

8.6.4 Further Study Measures 

Further study measures are measures that need to be researched in order to 

determine its feasibility as a control measure in the future. The District identified 

several emission source categories that appear to have the potential for emission 

reductions, but they have highly uncertain emission inventories or estimates of 

control measure effectiveness. For those sources, the District proposes further 

study to enable an informed decision on whether to pursue a control measure and to 

determine a realistic emission reduction estimate. The District’s “Further Study 

Measures” are presented in Section 4.2 of this Extreme OADP. Note that Chapters 

4, 5, and 7 of this Extreme OADP identify and evaluate state and District ozone 

precursor emission control measures that would be adopted outside the time frame 

of the California Clean Air Act Plan Revision, and are therefore not mentioned in this 

Chapter. 
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8.7 REFERENCES 

ARB 1990 California Air Resources Board, Assessment and Mitigation 

of the Impacts of Transported Pollutants on Ozone 

Concentrations within California, June 1990, CARB, 

Sacramento, California. 

ARB 2001 California Air Resources Board, Ozone Transport: 2001 

Review, California Air Resources Board, Sacramento, 

California, April 2001. 

ARB 2004a California Air Resources Board, EPCD Data Sacramento, 

California. 

ARB 2004b The 2004 California Almanac of Emissions and Air Quality, 

California Air Resources Board, Sacramento, California. 

SJVAPCD 1992 San Joaquin Valley Air Pollution Control District, 1991 Air 

Quality Attainment Plan, January 1992, SJVUAPCD, Fresno, 

California. 

SJVAPCD 1994 San Joaquin Valley Air Pollution Control District, Air Quality 

Guidelines for General Plans, SJVUAPCD, Fresno, 

California, October 20, 1994. 

SJVAPCD 1998 San Joaquin Valley Air Pollution Control District, California 

Clean Air Act Triennial Progress Report and Plan Revision 

1995-1997 (1997 Triennial Update), 1998, SJVUAPCD, 

Fresno, California. Approved by ARB October 1999. 

SJVAPCD 2001 San Joaquin Valley Air Pollution Control District, California 

Clean Air Act Triennial Progress Report and Plan Revision 

1997-1999 (2000 Triennial Update), SJVUAPCD, Fresno, 

California, 2001. 

SJVAPCD 2002a San Joaquin Valley Air Pollution Control District, Guide for 

Assessing and Mitigating Air Quality Impacts, SJVUAPCD, 

Fresno, California, January 10, 2002 revision (originally 

adopted August 20, 1998). 

SJVAPCD 2002b San Joaquin Valley Air Pollution Control District, Amended 

2002 and 2005 Rate of Progress Plan for San Joaquin 

Valley Ozone, SJVUAPCD, Fresno, California, December 

19, 2002 revision.
❖
Chapter 9 – ACRONYMS AND GLOSSARY
❖
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SJVUAPCD Chapter 9- Acronyms and Glossary 

9-1 

9.1 ACRONYMS 

APCD Air Pollution Control District 

AQAP Air Quality Attainment Plan 

AQMD Air Quality Management District 

AQMP Air Quality Management Plan 

APS Achievable Performance Standard (CARB) 

AWE Area Weighted Exposure 

BACM Best Available Control Measure 

BACT Best Available Control Technology 

BARCT Best Available Retrofit Control Technology 

CAC Citizen’s Advisory Committee 

CAPCOA California Air Pollution Control Officers’ Association 

CARB California Air Resources Board 

CCAA California Clean Air Act 

CCAP California Clean Air Plan 

CCOS Central California Ozone Study 

CDPF Catalytic Diesel Particulate Filter 

CE-CERT Center for Environmental Research & Technology 

CEIDARS California Emission Inventory Development and Reporting 

Air System 

CEFS California Emission Forecasting System 

CEQA California Environmental Quality Act 

CH&SC California Health and Safety Code 

CMAQ Congestion Mitigation and Air Quality 

CO Carbon Monoxide 

CO2 Carbon Dioxide 

District San Joaquin Valley Unified Air Pollution Control 

District 

DMV Department of Motor Vehicles 
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EF Emission Factor 

EI Emission Inventory 

EMFAC EMissions FACtor (motor vehicle emissions model) 

EPA U.S. Environmental Protection Agency 

ERC Emission Reduction Credit 

FCAA Federal Clean Air Act, as amended 

FGR Flue Gas Recirculation 

FHWA Federal Highway Administration 

FIP Federal Implementation Plan 

FR- Federal Register 

FMVCP Federal Motor Vehicle Control Program 

FTA Federal Transit Administration 

g/l grams per liter 

I/M Inspection and Maintenance 

IC Internal Combustion 

MACT Maximum Achievable Control Technology 

MPOs Metropolitan Planning Organizations 

MW Megawatt 

N/A Not available 

NAAQS National Ambient Air Quality Standards 

ND Not Determined at This Time 

NOx Oxides of Nitrogen 

NSR New Source Review 

OADP Ozone Attainment Demonstration Plan 

PM10 Particulate Matter of 10 microns and smaller 

PM10 ADP PM10 Attainment Demonstration Plan 

ppb parts per billion 

pphm parts per hundred million 

ppm parts per million 

PWE Population Weighted Exposure 
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RACT Reasonably Available Control Technology 

RACM Reasonably Available Control Measure 

REMOVE Reduce Motor Vehicle Emissions Program 

RFP Reasonable Further Progress 

ROG Reactive Organic Gas 

ROP Rate of Progress 

RTP Regional Transportation Plan 

RTPA Regional Transportation Planning Agencies (Valley 

Transportation Planning Agencies) 

RTPACID Regional Transportation Planning Agency 

Commitments for Implementation Documentation 

RVP Reid Vapor Pressure 

SCAQMD South Coast Air Quality Management District 

SCR Selective Catalytic Reduction 

SEDAB Southeast Desert Air Basin 

SIP State Implementation Plan 

SNCR Selective Non-Catalytic Reduction 

SJVAB San Joaquin Valley Air Basin 

SOx Oxides of Sulfur 

TAC Toxic Air Contaminants 

TCM Transportation Control Measure 

TOG Total Organic Gases 

TPAs Valley Transportation Planning Agencies [see 

Regional Transportation Planning Agencies (RTPAs)] 

TIP Transportation Improvement Programs 

tpd tons per day 

UTM Universal Transverse Mercator 

Valley San Joaquin Valley 

VMT Vehicle Miles Traveled 

VOC Volatile Organic Compounds
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9.2 GLOSSARY

Air Basin: An area of the state designated by the CARB pursuant to Subdivision 

(a) of Section 39606 of the CH&SC that has similar meteorological and 

geographic conditions. 

Air Monitoring: The periodic or continuous sampling and analysis of air 

pollutants in ambient air or from individual pollutant sources. 

Air Pollutants: Substances which are foreign to the atmosphere or are present 

in the natural atmosphere to the extent that they may result in adverse 

effects on humans, animals, vegetation, and/or materials. 

Air Pollution Control District (APCD): A county agency with authority to 

regulate sources of air pollution, other than emissions from mobile 

sources, such as refineries, manufacturing facilities, and power plants 

within a given county, and governed by a District Air Pollution Control 

Board composed of elected county supervisors. (Compare AQMD and 

Unified District) 

Air Pollution Control Officer (APCO): A person appointed by the APCB given 

the authority to appoint district personnel for the purpose of observing and 

enforcing the provisions of Part 4, Division 26 of the CH&SC. 

Air Quality Attainment Plan (AQAP): An air quality plan prepared in 

approximately 1991 by each air pollution control district in the California 

that at that time was classified as nonattainment for specific state ambient 

air quality standards. 

Air Quality Management District (AQMD): A group of counties or portions of 

counties with authority to regulate sources of air pollution within the region 

and governed by a regional air pollution control board comprised mostly of 

elected officials from within the region. An AQMD is established by state 

legislation. (Compare APCD and Unified District). 

Ambient Air: Air occurring at a particular time and place outside of structures. 

Often used interchangeably with outdoor air. 

Anthropogenic: Of, relating to, or influenced by the impact of man on nature; 

man-made. 

Area-wide Sources: Also known as "area" sources, are those sources which are 

not large enough to be tracked individually, but when added together can 

represent a large quantity of pollution. Examples of these sources include 
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multiple stationary emission sources such as water heaters, gas furnaces, 

fireplaces, gas stations, dry cleaners and woodstoves. Area sources of 

pollution are identified by Category of Emission Source (CES) codes. 

Attainment: Achieving and maintaining the air quality standards for a given 

 standard. This is generally accomplished by demonstrating that there was 

no more than one day in a year where the ambient air exceeded the 

appropriate given standard. 

Attainment Area: A geographic area that is in compliance with the National 

and/or California Ambient Air Quality Standards (NAAQS or CAAQS). 

Best Available Control Technology (BACT): The most up to date methods, 

systems, techniques, and production processes available to achieve the 

greatest feasible emission reductions for given regulated air pollutants and 

processes. BACT is a requirement of NSR (New Source Review) and 

PSD (Prevention of Significant Deterioration). 

Best Available Control Measure (BACM): A term used to describe the “best” 

measures (according to EPA guidance) for controlling small or dispersed 

sources of particulate matter and other emissions from sources such as 

roadway dust, woodstoves, and open burning. 

Best Available Retrofit Control Technology (BARCT): An emission limitation 

that is based on the maximum degree of reduction achievable, taking into 

account environmental, energy, and economic impacts by each class or 

category of source (Section 40406 CH&SC). 

Biogenic: Produced by living organisms. Biogenic emissions are of extreme 

interest because of the predominance of agriculture in the San Joaquin 

Valley; however, the District has no authority to regulate biogenic 

emissions. Preliminary studies indicate that biogenic emissions may be at 

least two times the total hydrocarbon emissions already quantified in the 

emissions inventory (in the AQAP). 

Bureau of Automotive Repair (BAR): An agency of the California Department 

of Consumer Affairs responsible for the implementation of the motor 

vehicle inspection and maintenance program (smog check). 

California Air Resources Board (CARB): The State's lead air quality agency 

consisting of an eleven-member Governor appointed board and 

supporting staff fully responsible for motor vehicle pollution control, and 

having oversight authority over California's air pollution management 

program. 
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California Clean Air Plan (CCAP): A plan being developed by the California Air 

Resources Board to help meet state and federal ozone standards 

throughout California. Originally scheduled for release in 2001 and 2002, 

it is still in development pending resolution of issues related to mobile 

source emission controls. 

California Environmental Quality Act (CEQA): A California law that sets forth a 

process for public agencies to make informed decisions on discretionary 

project approvals. The process aids decision makers to determine 

whether any environmental impacts are associated with a proposed 

project. It requires the elimination or reduction of environmental impacts 

associated with a proposed project and the implementation of mitigation 

measures to reduce or remove those impacts. 

Carbon Monoxide (CO): A colorless, odorless gas resulting from the incomplete 

combustion of fossil fuels. Over 80 percent of the CO emitted in urban 

areas is contributed by motor vehicles. CO interferes with the blood's 

ability to carry oxygen to the body's tissues and results in numerous 

adverse health effects. CO is a criteria pollutant. 

Central California Ozone Study (CCOS): A research effort undertaken in 2001 

to collect observations related to formation of ozone at the surface and 

aloft for a large area of central California, with supporting collection of 

activity and emissions data, to be followed by analysis and modeling. 

Conformity: A demonstration of whether a federally-supported activity is 

consistent with the State Implementation Plan (SIP) – per section 176(c) 

of the FCAA. Transportation conformity refers to plans, programs, and 

projects approved or funded by the Federal Highway Administration or the 

Federal Transit Administration. General conformity refers to projects 

approved or funded by other federal agencies. 

Consumer Products: Products such as detergents, cleaning compounds, 

polishes, personal care products, and automotive specialty products which 

are part of our everyday lives and, through consumer use, may produce 

air emissions which contribute to air pollution. 

Criteria Air Pollutant: An air pollutant for which acceptable levels of exposure 

can be determined and for which an federal or state ambient air quality 

standard has been set. Examples include: Ozone, Carbon Monoxide, 

Lead, Nitrogen Dioxide, Sulfur Dioxide, and PM10. 

Department of Motor Vehicles (DMV): The agency responsible for registering 

drivers and vehicles as well as collecting state and local motor vehicle 

fees. 
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Design Value: The pollutant concentration used by air quality managers as the 

basis for determining attainment of an air quality standard, generally by 

using an air quality model. The design value may or may not be the same 

as the designation value. 

Emission Factor: For stationary sources, the relationship between the amount 

of pollution produced and the amount of raw material processed or 

burned. For mobile sources, the relationship between the amount of 

pollution produced and the number of vehicle miles traveled. By using the 

emission factor of a pollutant and specific data regarding quantities of 

material used by a given source, it is possible to compute emissions for 

the source. 

Emission Inventory: An estimate of the amount of pollutants emitted into the 

atmosphere from major mobile, stationary, area-wide, and natural source 

categories over a specific period of time such as a day or a year. 

Emission Offset: Actual enforceable emission reductions from existing sources 

sufficient to offset anticipated emission increases associated with new or 

modified stationary sources. A rule-making concept whereby approval of a 

new stationary source of air pollution or increase of emissions from an 

existing source of air pollution is conditional on the equal or greater 

reduction of emissions from other existing stationary sources of air 

pollution. This concept is utilized in addition to reduction in emissions by 

employing BACT. 

Emission Projecting: Utilizing information and growth and control estimates to 

approximate future emissions. 

Emission Reduction Credit (ERC): Credits given for actual emission reductions 

that are real, enforceable, permanent, quantifiable, and surplus (beyond 

the required reduction). An actual credit is certified via a District-issued 

document that specifies the date of issuance, expiration date of credit, 

type of pollutant, and legal owner of emission reduction credits. In some 

cases, ERCs can be transferred to another owner or banked for future 

use. 

Emission Standard: The maximum amount or rate of a pollutant permitted to be 

discharged from a polluting source such as an automobile or smoke stack. 

Emissions Inventory: An estimate of the quantity of pollutants emitted into the 

atmosphere over a specific period such as a day or a year. 

Considerations that go into the inventory include type and location of 

sources, the processes involved, and the level of activity. 
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Environmental Protection Agency (EPA): The United States Environmental 

Protection Agency is a federal agency charged with protecting human 

health and safeguarding the natural environment—air, water, and land-- 

upon which life depends. EPA promulgates national ambient air quality 

standards and implements other federal programs designed to improve air 

quality. 

Exceedance: An air pollutant that is monitored to be above the state and/or 

federal ambient air quality standard for that pollutant. 

Federal Clean Air Act (FCAA): A federal law passed in 1970 and significantly 

amended in 1977 and 1990 that forms the basis for the national air 

pollution control efforts. Basic elements of the Act include national 

ambient air quality standards for major air pollutants, air toxics standards, 

acid rain control measures, and enforcement provisions. 

Federal Clean Air Act Amendments of 1990: The 1990 amended version of 

the FCAA that mandates attainment of the National Ambient Air Quality 

Standards (NAAQS) by specified dates for nonattainment areas. For 

ozone nonattainment, urban areas are now sorted into categories 

(marginal, moderate, serious, severe, and extreme) with deadlines 

established ranging from three years for marginal areas to twenty years 

for extreme areas. 

Federal Implementation Plan (FIP): In the absence of an approved State 

Implementation Plan (SIP), a plan prepared by the EPA which provides 

measures that nonattainment areas must take to meet the requirements of 

the FCAA. 

Federal Motor Vehicle Control Program (FMVCP): This program establishes 

the tailpipe emissions standards that are implemented by the Federal 

Government. 

Hydrocarbon (HC): any of a large number of compounds containing various 

combinations of hydrogen and carbon atoms. They may be emitted into 

the air as a result of fossil fuel combustion and fuel volatilization, and are a 

major contributor to smog. 

Indirect Source: Any facility, building, structure, or installation, or combination 

thereof, which generates or attracts mobile source activity that results in 

emissions of any pollutant (or precursor) for which there is a state or 

federal ambient air quality standard. Examples of indirect sources include 

employment sites, shopping centers, sports facilities, housing 
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SJVUAPCD Chapter 9- Acronyms and Glossary 

9-9 

developments, airports, educational institutions, commercial and industrial 

developments, and parking lots and garages.

Indirect Source Review (ISR): A rule or regulation that governs entities such as 

stationary facilities, buildings, structures, properties, and/or roads which, 

through their construction to operation indirectly contributes to air 

pollution. This includes projects and facilities that attract or generate 

mobile sources activity (autos and trucks) such as employment sites, 

shopping centers, sports facilities, housing developments, airports, 

educational institutions, commercial and industrial developments, and 

parking lots and garages, that results in the emissions of any regulated 

pollutant. 

Inspection and Maintenance Program (I & M): A motor vehicle inspection 

program implemented by the Bureau of Automotive Repair. It is designed 

to identify vehicles in need of maintenance and to assure the effectiveness 

of their emission control systems on a biennial basis. The program was 

enacted in 1979 and strengthened in 1990. The standard program is 

called Basic I & M. Enhanced I & M has more stringent testing 

requirements and is to be implemented in urbanized areas that are 

classified as "serious" and above nonattainment for ozone or "high 

moderate" and above for carbon monoxide and which had a population of 

200,000 or more in 1980. Also known as a "smog check". 

Internal Combustion Engine (IC): A heat engine in which the combustion 

generates the heat inside the engine proper instead of in a furnace. An 

example of an IC engine is an automobile engine.

Inversion: A layer of warm air in the atmosphere that lies over a layer of cooler 

air, trapping pollutants. 

Memorandum of Understanding (MOU): n agreement made among agencies 

for the purposes of jointly accomplishing a goal, program, etc. The 

governing boards of the involved agencies must ratify this agreement. 

Mobile Sources: Sources of air pollution that are not stationary by nature such 

as automobiles, motorcycles, trucks, off-road vehicles, boats, and 

airplanes. 

National Ambient Air Quality Standards (NAAQS): Standards set by the 

Federal EPA for the maximum levels of air pollutants that can exist in the 

ambient air without unacceptable effects on human health or the public 

welfare. 
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New Source Review (NSR): The mechanism to assure that new and modified 

stationary sources will not interfere with the attainment or maintenance of 

any ambient air quality standard, or prevent reasonable further progress 

towards the attainment or maintenance of any ambient air quality 

standard. A program used in a non-attainment area to permit or site new 

industrial facilities or modifications to existing industrial facilities that emit 

non-attainment criteria air pollutants. The two major requirements of NSR 

are Best Available Control Technology and Offsets. 

Nonattainment Area: An area identified by the EPA and/or CARB as not 

meeting either NAAQS or CAAQS standards for a given pollutant. 

Oxides of Nitrogen (NOx): A general term pertaining to compounds of nitric 

oxide (NO), nitrogen dioxide (NO2), and other oxides of nitrogen. Nitrogen 

oxides are typically created during combustion processes, and are major 

contributors to smog formation and acid deposition. NO2 is a criteria 

pollutant, and may result in numerous adverse health effects. 

Ozone (O3): A reactive gas consisting of three oxygen atoms. In the 

troposphere, it is a product of the photochemical process involving the 

sun's energy. It is a secondary pollutant that is formed when nitrogen 

oxides (NOx) and reactive organic gases (ROG) react in the presence of 

sunlight. Ozone at the earth's surface causes numerous adverse health 

effects and is a criteria pollutant. It is a major component of smog. In the 

stratosphere, ozone exists naturally and shields life on earth from harmful 

incoming ultraviolet radiation. 

Ozone Attainment Demonstration Plan (OADP): A plan prepared by air 

pollution control districts and air quality management districts that 

proposes and evaluates, through modeling, emission controls deemed 

necessary to attain ambient air quality standards for ozone. 

Ozone Precursors: Chemicals such as volatile organic compounds and nitrogen 

oxides, occurring either naturally or as a result of human activities, which 

contribute to the formation of ozone, a major component of smog. They 

are emitted directly from sources into the atmosphere. 

Particulate Matter (PM10): A major air pollutant consisting of tiny solid or liquid 

particles of soot, dust, smoke, fumes, and mists. The size of the particles 

(10 microns or smaller, about 0.0004 inches or less) allows them to easily 

enter the air sacs deep in the lungs where they may be deposited to result 

in adverse health effects. PM10 also causes visibility reduction and is a 

criteria air pollutant. 
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9-11 

parts per hundred million (pphm): Standard of measurement of concentration 

by which ozone or other atmospheric gases may be measured. One 

pphm is equal to ten ppb. 

parts per million (ppm): Standard of measurement of concentration by which 

ozone or other atmospheric gases may be measured. One ppm is equal 

to 100 pphm or 1000 ppb. 

Photochemical Reaction: A term referring to chemical reactions brought about 

by the light energy of the sun. Photochemical reactions create harmful air 

pollutants such as ozone. 

Public Workshop: A workshop held by an air district for the purpose of 

informing the public and obtaining its input on the development of a 

regulatory action or control measure by that agency. 

Rate of Progress (ROP): The Federal Clean Air Act Amendments [Section 

182(c)(2)] require ozone nonattainment areas designated as “serious” or 

above to demonstrate post-1996 volatile organic compound emission 

reductions of three percent per year, averaged over a 3-year period. The 

U.S. Environmental Protection Agency refers to these reductions as the 

rate-of-progress requirement. 

Reactive Organic Gas (ROG): A reactive chemical gas, composed of 

hydrocarbon compounds that may contribute to the formation of smog by 

their involvement in atmospheric chemical reactions. Also sometimes 

referred to as Non-Methane Organic Compounds (NMOCs). VOC 

emissions are a subset of ROG emissions. 

Regional Transportation Planning Agencies (RTPAs) The eight governmental 

bodies in the San Joaquin Valley primarily responsible for transportation 

planning in compliance with federal and state requirements. Also referred 

to as Valley Transportation Planning Agencies (TPAs). 

Reasonably Available Control Technology (RACT): Devices, systems, 

process modifications, or other apparatus or techniques that are 

reasonably available taking into account the necessity of imposing such 

controls in order to attain and maintain a national ambient air quality 

standard; the social, environmental, and economic impact of such 

controls; and alternative means of providing for attainment and 

maintenance of such standard. 

Reid Vapor Pressure (RVP): The absolute vapor pressure of volatile crude oil 

and volatile nonviscous petroleum liquids, except liquefied petroleum 

gases. 
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San Joaquin Valley Air Basin (SJVAB): An air basin established by CARB that 

has similar meteorological and geographical conditions that consist of all 

of San Joaquin, Stanislaus, Merced, Madera, Fresno, Kings, and Tulare 

Counties, and the Valley portion of Kern County. 

San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD or 

District): Also known as the "Valley Air District". The eight member 

counties include Fresno, Kings, Madera, Merced, San Joaquin, 

Stanislaus, and Tulare Counties, and the Valley portions of Kern County. 

Smog: A combination of smoke, ozone, hydrocarbons, nitrogen oxides, and 

other chemically reactive compounds, which, under various conditions of 

weather and sunlight, may result in a murky brown haze that causes 

adverse health effects. A primary source of smog is automobiles. 

Smog Check Program: A motor vehicle inspection program implemented by the 

Bureau of Automotive Repair. It is designed to identify vehicles in need of 

maintenance and to assure the effectiveness of their emission control 

systems on a biennial basis. The program was enacted in 1979 and 

strengthened in 1990. Also known as the Inspection and Maintenance 

Program (I & M). 

State Implementation Plan (SIP): A document prepared by each state 

describing existing air quality conditions and measures which will be taken 

to attain and maintain national ambient air quality standards. 

Stationary Sources: Non-mobile sources such as power plants, refineries, and 

manufacturing facilities that emit air pollutants. 

Transportation Control Measure (TCM): Any control measure to reduce vehicle 

trips, vehicle use, vehicle miles traveled, vehicle idling, or traffic 

congestion for the purpose of reducing motor vehicle emissions. TCMs 

can include encouraging the use of carpools and mass transit. 

Transportation Planning Agency (TPA): See Regional Transportation Planning 

Agency. 

Unified Air Pollution Control District: A specialized APCD in which two or 

more contiguous counties merge their county districts into one. A unified 

district is formed by action of the member counties. The San Joaquin 

Valley Unified Air Pollution Control District is a Unified District pursuant to 

Division 26, Part 3, Chapter 11 of the CH&SC. (Compare APCD and 

AQMD) 
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9-13 

United States Environmental Protection Agency (EPA): The United States 

agency charged with setting policy and guidelines, and carrying out legal 

mandates for the protection of national interests in environmental 

resources. 

Valley: All references to the "Valley" in this plan refer to the San Joaquin Valley. 

Valley Transportation Planning Agencies (TPAs): The eight governmental 

bodies in the San Joaquin Valley primarily responsible for transportation 

planning in compliance with federal and state requirements. Also referred 

to as Regional Transportation Planning Agencies (RTPAs). 

Vehicle Miles Traveled (VMT): A measure of both the volume and extent of 

motor vehicle operation; the total number of vehicle miles traveled within a 

specified geographical area over a given period of time. 

Volatile Organic Compounds (VOC): Hydrocarbon compounds that exist in the 

ambient air. VOCs contribute to the formation of smog and/or may 

themselves be toxic. VOC emissions are a major precursor to the 

formation of ozone. VOCs often have an odor, and some examples 

include gasoline, alcohol, and the solvents used in paints. 
❖
APPENDIX A County Emission Inventories 

for On-Road Motor Vehicles
❖
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SJVUAPCD Appendix A – County Emission Inventories 

 for On-Road Motor Vehicles

A-1 

PREFACE 

This Appendix presents the county by county planning emissions inventories for 

2008 and 2010 for the emission inventory category of on-road motor vehicles. 

Data for the pollutants Reactive Organic Gases (ROG, the same as VOC used 

elsewhere in this document), Carbon Monoxide (CO), and Nitrogen Oxides 

(NOx). ARB compiled the emissions data in this Appendix on July 23, 2004 

using EMFAC2002, Version 2.2 (April 2003), San Joaquin Valley by subarea, 

summer, WIS enabled with updated vehicle populations and vehicle miles 

traveled data. The data in this appendix serve as further detail to Table 3-1 and 

Table 3-4, and are intended to support the derivation of conformity emissions 

budgets for counties in the SJVAB. Table 3-4 sets the conformity budgets; any 

discrepancy between totals in this Appendix and Table 3-4 are due to rounding 

conventions, and no totals in this Appendix represent conformity budgets. 

The District used the following protocol to round emissions data to the nearest 

0.1 tons per day: 

• If the digit to be discarded is less than five, the last digit retained is 

unchanged; 

• If the digit to be discarded is five or greater, the last digit retained is 

increased by one unit. 

This rounding convention is consistent with practices given under the American 

Society for Testing and Materials (ASTM) “Standard for Metric Practice E 380”. 

The original data was expressed to the nearest 0.01 tons per day; the District 

computed totals using the original data expressed to the nearest 0.01 tons per 

day and then rounded the total to tenths; consequently, the sums of columns 

may be slightly off due to rounding. 

The emissions inventories are presented in the following order: 2008 ROG, 2008 

CO, 2008 NOx, 2010 ROG, 2010 CO, and 2010 NOx. 

The “I/M Adjustment” row in selected tables refers to the motor vehicle Inspection 

and Maintenance Program (I & M), which is implemented by the Bureau of 

Automotive Repair. The standard program is called Basic I & M. Enhanced I & 

M has more stringent testing requirements and is to be implemented in urbanized 

areas that are classified as "serious" and above nonattainment for ozone or "high 

moderate" and above for carbon monoxide and which had a population of 

200,000 or more in 1980. The program is also known as a "smog check". The 

“ISR/Incentive” adjustment refers to an emission reduction from the District’s 

Indirect Source Rules and Incentive Program that reduces emissions (NOx only 

for 2008 and 2010) from mobile sources. Adjustments for state measures reflect 

the state emission control measures given in Table 4-3 that affect mobile source 

emissions (2010 ROG and NOx only). 
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SJVUAPCD Appendix A - County Emission Inventories for On-Road M

A-2

Table A-1. SJVAB On-Road Motor Vehicle ROG Emissions, 2008 by County (sum

Vehicle Class Grand Total Fresno Kern (SJV) Kings Madera Merced San Joaquin St

LDA 23.0 5.7 3.3 0.8 1.2 1.8 4.1 

LDT1 14.5 3.4 2.5 0.6 1.0 1.3 1.8 LDT2 10.4 2.5 1.8 0.4 0.5 0.9 1.5 

MDV 4.5 1.0 0.8 0.2 0.3 0.4 0.7 

LHDT1-Gas 1.5 0.4 0.3 0.0 0.1 0.1 0.2 

LHDT1-Dsl 0.2 0.0 0.0 0.0 0.0 0.0 0.0 

LHDT2-Gas 0.5 0.2 0.2 0.0 0.0 0.0 0.1 

LHDT2-Dsl 0.2 0.0 0.1 0.0 0.0 0.0 0.0 MHDT-Gas 2.7 0.6 0.5 0.1 0.2 0.2 0.4 

MHDT-Dsl 0.6 0.1 0.1 0.0 0.0 0.0 0.1 

HHDT-Gas 1.6 0.4 0.3 0.1 0.2 0.1 0.2 

HHDT-Dsl 3.7 0.8 0.9 0.2 0.2 0.3 0.5 

SBUS 0.3 0.1 0.1 0.0 0.0 0.0 0.0 

UB-Gas 1.1 0.2 0.3 0.1 0.2 0.1 0.1 

UB-Dsl 0.2 0.0 0.0 0.0 0.0 0.0 0.0 

MH 0.8 0.1 0.1 0.0 0.1 0.1 0.1 

MCY 2.0 0.5 0.4 0.1 0.1 0.1 0.3 

Totals 67.8 16.1 11.8 2.6 4.1 5.3 10.2 

I/M Adjustment 3.1 0.4 0.3 0.1 0.2 0.3 1.0 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix A - County Emission Inventories for On-Road M

A-3

Table A-2. SJVAB On-Road Motor Vehicle CO Emissions, 2008 by County (sum

Vehicle Class Grand Total Fresno Kern (SJV) Kings Madera Merced San Joaquin St

LDA 240.3 57.2 36.5 9.6 12.8 20.5 44.5 

LDT1 163.7 36.0 29.6 7.6 12.5 17.3 19.9 LDT2 117.4 27.6 22.0 4.9 6.2 11.1 17.0 

MDV 51.0 11.4 9.3 1.9 3.4 4.9 8.0 

LHDT1-Gas 8.4 2.0 1.8 0.3 0.8 0.4 1.1 

LHDT1-Dsl 0.7 0.1 0.2 0.0 0.1 0.1 0.1 

LHDT2-Gas 2.9 0.8 0.9 0.1 0.1 0.1 0.4 

LHDT2-Dsl 0.5 0.1 0.2 0.0 0.0 0.0 0.1 MHDT-Gas 19.9 4.6 3.9 0.6 1.2 1.4 2.9 

MHDT-Dsl 4.1 1.0 1.0 0.2 0.2 0.3 0.6 

HHDT-Gas 21.1 4.5 3.3 1.2 2.5 2.0 2.3 

HHDT-Dsl 15.3 3.5 3.6 0.7 0.9 1.2 2.0 

SBUS 3.3 0.6 0.8 0.2 0.1 0.2 0.3 

UB-Gas 9.9 1.8 2.4 0.4 1.2 0.5 1.3 

UB-Dsl 0.7 0.2 0.2 0.0 0.0 0.0 0.1 

MH 18.3 3.3 3.3 0.7 1.6 1.6 3.0 

MCY 18.3 4.3 4.5 0.9 0.7 0.8 2.8 

Totals 695.7 158.9 123.2 29.1 44.3 62.3 106.2 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix A - County Emission Inventories for On-Road M

A-4

Table A-3. SJVAB On-Road Motor Vehicle NOx Emissions, 2008 by County (sum

Vehicle Class Grand Total Fresno Kern (SJV) Kings Madera Merced San Joaquin St

LDA 19.4 4.3 3.1 0.9 1.1 1.7 3.6 

LDT1 13.1 2.6 2.4 0.7 1.0 1.4 1.6 LDT2 12.6 2.7 2.4 0.6 0.7 1.2 1.9 

MDV 6.4 1.3 1.2 0.3 0.4 0.6 1.1 

LHDT1-Gas 2.3 0.5 0.5 0.1 0.2 0.1 0.3 

LHDT1-Dsl 2.4 0.5 0.5 0.1 0.2 0.2 0.3 

LHDT2-Gas 0.7 0.2 0.2 0.0 0.0 0.0 0.1 

LHDT2-Dsl 1.8 0.4 0.5 0.1 0.1 0.1 0.2 MHDT-Gas 2.1 0.5 0.5 0.1 0.1 0.1 0.3 

MHDT-Dsl 15.9 3.8 3.8 0.5 0.7 0.9 2.4 

HHDT-Gas 2.8 0.6 0.5 0.2 0.2 0.2 0.3 

HHDT-Dsl 69.6 15.5 15.9 2.7 3.5 4.8 10.5 

SBUS 2.6 0.6 0.6 0.1 0.1 0.3 0.4 

UB-Gas 1.0 0.2 0.2 0.0 0.1 0.1 0.1 

UB-Dsl 3.6 0.7 1.0 0.1 0.1 0.2 0.7 

MH 1.8 0.3 0.3 0.1 0.2 0.2 0.3 

MCY 0.5 0.1 0.1 0.0 0.0 0.0 0.1 

Totals 158.4 34.8 33.8 6.5 8.7 12.1 24.4 

I/M Adjustment 5.7 0.7 0.6 0.2 0.3 0.6 1.7 

ISR/Incentive 0.5 0.5 0.1 0.1 0.1 0.3 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix A - County Emission Inventories for On-Road M

A-5

Table A-4. SJVAB On-Road Motor Vehicle ROG Emissions, 2010 by County (sum

Vehicle Class Grand Total Fresno Kern (SJV) Kings Madera Merced San Joaquin St

LDA 19.2 4.8 2.8 0.7 0.9 1.5 3.5 

LDT1 12.5 2.9 2.1 0.5 0.9 1.1 1.6 LDT2 9.4 2.3 1.7 0.4 0.5 0.8 1.4 

MDV 4.1 1.0 0.7 0.1 0.3 0.3 0.7 

LHDT1-Gas 1.4 0.3 0.3 0.0 0.1 0.1 0.2 

LHDT1-Dsl 0.2 0.0 0.0 0.0 0.0 0.0 0.0 

LHDT2-Gas 0.5 0.1 0.2 0.0 0.0 0.0 0.1 

LHDT2-Dsl 0.2 0.0 0.0 0.0 0.0 0.0 0.0 MHDT-Gas 2.4 0.5 0.5 0.1 0.1 0.2 0.3 

MHDT-Dsl 0.6 0.1 0.1 0.0 0.0 0.0 0.1 

HHDT-Gas 1.4 0.3 0.2 0.1 0.2 0.1 0.1 

HHDT-Dsl 3.4 0.8 0.8 0.2 0.2 0.3 0.4 

SBUS 0.3 0.1 0.1 0.0 0.0 0.0 0.0 

UB-Gas 1.1 0.2 0.3 0.1 0.2 0.1 0.1 

UB-Dsl 0.2 0.0 0.0 0.0 0.0 0.0 0.0 

MH 0.7 0.1 0.1 0.0 0.1 0.1 0.1 

MCY 1.9 0.5 0.4 0.1 0.1 0.1 0.3 

Totals 59.3 14.1 10.5 2.3 3.6 4.5 8.9 

I/M Adjustment 2.6 0.3 0.2 0.1 0.1 0.3 0.8 

State Measures 0.9 0.7 0.1 0.2 0.3 0.5 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix A - County Emission Inventories for On-Road M

A-6

Table A-5. SJVAB On-Road Motor Vehicle CO Emissions, 2010 by County (sum

Vehicle Class Grand Total Fresno Kern (SJV) Kings Madera Merced San Joaquin St

LDA 202.1 48.0 31.1 8.2 10.4 17.1 37.8 

LDT1 138.6 30.2 25.2 6.6 10.8 14.7 17.0 LDT2 103.5 24.3 19.6 4.4 5.4 9.7 15.0 

MDV 45.7 10.2 8.4 1.7 3.0 4.4 7.2 

LHDT1-Gas 7.0 1.7 1.6 0.2 0.7 0.3 0.9 

LHDT1-Dsl 0.7 0.1 0.2 0.0 0.1 0.0 0.1 

LHDT2-Gas 2.5 0.7 0.7 0.1 0.1 0.1 0.3 

LHDT2-Dsl 0.5 0.1 0.2 0.0 0.0 0.0 0.1 MHDT-Gas 16.7 3.8 3.4 0.5 1.0 1.1 2.4 

MHDT-Dsl 4.0 1.0 1.0 0.2 0.2 0.2 0.6 

HHDT-Gas 17.8 3.9 2.8 1.2 2.3 1.5 1.8 

HHDT-Dsl 14.2 3.2 3.3 0.7 0.8 1.1 1.8 

SBUS 3.2 0.6 0.7 0.2 0.1 0.2 0.3 

UB-Gas 9.6 1.7 2.4 0.4 1.2 0.5 1.3 

UB-Dsl 0.7 0.2 0.2 0.0 0.0 0.0 0.1 

MH 15.7 2.8 2.7 0.6 1.5 1.4 2.7 

MCY 16.4 3.9 4.1 0.8 0.6 0.6 2.4 

Totals 598.6 136.2 107.5 25.6 38.3 53.2 91.7 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix A - County Emission Inventories for On-Road M

A-7

Table A-6. SJVAB On-Road Motor Vehicle NOx Emissions, 2010 by County (sum

Vehicle Class Grand Total Fresno Kern (SJV) Kings Madera Merced San Joaquin St

LDA 16.1 3.6 2.6 0.7 0.9 1.4 3.0 

LDT1 11.0 2.2 2.1 0.6 0.9 1.2 1.4 LDT2 11.0 2.4 2.1 0.5 0.6 1.1 1.7 

MDV 5.6 1.1 1.1 0.2 0.4 0.6 0.9 

LHDT1-Gas 2.4 0.5 0.6 0.1 0.2 0.1 0.3 

LHDT1-Dsl 2.1 0.4 0.5 0.1 0.2 0.1 0.3 

LHDT2-Gas 0.7 0.2 0.2 0.0 0.0 0.0 0.1 

LHDT2-Dsl 1.6 0.4 0.5 0.1 0.1 0.1 0.2 MHDT-Gas 1.9 0.4 0.5 0.1 0.1 0.1 0.3 

MHDT-Dsl 14.1 3.4 3.4 0.5 0.7 0.7 2.1 

HHDT-Gas 2.4 0.5 0.4 0.2 0.2 0.2 0.2 

HHDT-Dsl 60.9 13.8 14.1 2.5 3.3 4.0 8.8 

SBUS 2.6 0.6 0.6 0.1 0.1 0.3 0.4 

UB-Gas 1.0 0.2 0.2 0.0 0.1 0.1 0.1 

UB-Dsl 3.5 0.7 1.0 0.1 0.1 0.2 0.7 

MH 1.7 0.3 0.3 0.1 0.2 0.2 0.3 

MCY 0.5 0.1 0.1 0.0 0.0 0.0 0.1 

Totals 138.9 30.6 30.1 5.9 8.0 10.3 20.9 

I/M Adjustment 5.0 0.6 0.5 0.2 0.3 0.5 1.5 

ISR/Incentive 0.6 0.6 0.1 0.1 0.1 0.3 

State Measures 1.8 1.8 0.3 0.5 0.6 1.2 
❖
CURRENT LIST OF EMISSION

REDUCTION CREDITS (ERCS)

APPENDIX B 
❖
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-1 

List of NOx and VOC Emissions Reduction Credits 

July 2004 

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st 

QTR

2nd 

QTR 

3rd 

QTR 

4th 

QTR

AERA ENERGY LLC C 39 2 NOx 33123 33123 33123 33123

AERA ENERGY LLC C 219 2 NOx 1738 1923 2100 1931

ANDERSON CLAYTON 

CORP/CORCORAN C 81 2 NOx 0 0 0 264 

ANDERSON CLAYTON 

CORP/DAIRYLAN C 332 2 NOx 0 0 0 203 

ANDERSON CLAYTON 

CORP/DAIRYLND C 472 2 NOx 0 0 0 353 

ANDERSON CLAYTON CORP/EL 

DORAD C 427 2 NOx 18 0 0 408 

ANDERSON CLAYTON CORP/FIVE 

PTS C 78 2 NOx 0 0 0 223 

ANDERSON CLAYTON 

CORP/HANFORD C 74 2 NOx 0 0 0 73 

ANDERSON CLAYTON CORP/IDRIA 

#2 C 250 2 NOx 0 0 0 263 

ANDERSON CLAYTON 

CORP/KEARNY C 75 2 NOx 0 0 0 196 

ANDERSON CLAYTON 

CORP/KERMAN C 428 2 NOx 0 0 0 298 

ANDERSON CLAYTON 

CORP/KINGSRIV C 460 2 NOx 34 0 0 550 

ANDERSON CLAYTON CORP/MURIT 

#1 C 334 2 NOx 0 0 0 200 

ANDERSON CLAYTON CORP/MURIT 

#2 C 336 2 NOx 0 0 0 203 

ANDERSON CLAYTON 

CORP/MURRAY C 234 2 NOx 0 0 0 343 

ANDERSON CLAYTON CORP/NAPA 

GIN C 335 2 NOx 0 0 0 140 

ANDERSON CLAYTON CORP/PLSNT 

VA C 326 2 NOx 0 0 0 514 

ANDERSON CLAYTON CORP/SAN 

JOAQ C 79 2 NOx 0 0 0 155 

ANDERSON CLAYTON 

CORP/SETTER C 76 2 NOx 0 0 0 198 

ANDERSON CLAYTON 

CORP/STRATFOR C 56 2 NOx 0 0 0 68 

ANDERSON CLAYTON 

CORP/SUNSET C 333 2 NOx 0 0 0 154 

ANDERSON CLAYTON 

CORP/TRANQLTY C 80 2 NOx 0 0 0 201 

BRITZ AG FINANCE CO., INC. C 557 2 NOx 0 0 0 232 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-2 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

BRITZ INCORPORATED C 586 2 NOx 0 0 0 381 

CALAVERAS MATERIALS INC C 89 2 NOx 284 257 294 236 

CALAVERAS MATERIALS INC. C 233 2 NOx 1265 3371 3913 2469

CALIFORNIA DAIRIES, INC. C 454 2 NOx 30 30 30 30 

CALIFORNIA DAIRIES, INC. C 583 2 NOx 0 1782 2914 2940

CALMAT CO. C 50 2 NOx 104 111 154 159 

CALMAT OF FRESNO C 40 2 NOx 74 355 163 547 

CALPINE CORPORATION C 375 2 NOx 12500 12500 12500 12500

CALPINE CORPORATION C 376 2 NOx 54301 54301 54301 54301

CALPINE CORPORATION C 447 2 NOx 0 0 0 212 

CANDLEWICK YARNS C 507 2 NOx 90 77 63 58 

CHEVRON USA INC C 221 2 NOx 2311 2557 2792 2567

CHEVRON USA INC C 331 2 NOx 23739 23739 23740 23740

CHEVRON USA INC C 364 2 NOx 30130 29673 29217 29217

CLARK BROTHERS-DERRICK GIN C 511 2 NOx 0 0 0 43 

COALINGA FARMERS CO-OP GIN C 537 2 NOx 0 0 0 257 

COIT RANCH C 532 2 NOx 0 0 0 132 

CORCORAN IRRIGATION DISTRICT C 560 2 NOx 352 356 321 209 

CRAYCROFT BRICK COMPANY C 71 2 NOx 417 336 328 332 

DE FRANCESCO & SONS INC. C 603 2 NOx 1188 1163 1138 1137

DUKE ENERGY NORTH AMERICA C 400 2 NOx 2243 2243 2243 2243

DUNCAN ENTERPRISES C 33 2 NOx 450 446 472 315 

E & J GALLO WINERY C 37 2 NOx 238 2086 8184 5402

HANSEN BROTHERS C 249 2 NOx 0 0 0 256 

J.G. BOSWELL CO. (EL RICO) C 135 2 NOx 14 4 0 40 

KRAFT FOODS INC C 149 2 NOx 284 284 284 284 

KRAFT FOODS INC C 150 2 NOx 1632 1632 1632 1632

KRAFT FOODS INC C 386 2 NOx 9774 9883 9992 9992

KRAFT FOODS INC C 387 2 NOx 5 5 4 4 

LA PALOMA GENERATING CO, LLC C 344 2 NOx 4702 6728 3983 1831

LEPRINO FOODS COMPANY C 60 2 NOx 7878 7985 7810 7898

LONE STAR GAS C 437 2 NOx 1024 1024 1023 1023

MODESTO IRRIGATION DISTRICT C 562 2 NOx 1054 2162 2162 2164

MODESTO IRRIGATION DISTRICT C 564 2 NOx 2578 4267 7351 10262

MODESTO IRRIGATION DISTRICT C 566 2 NOx 3582 1647 4608 843 

NAS LEMOORE C 330 2 NOx 221 221 221 221 

NRG POWER MARKETING INC C 589 2 NOx 753 0 0 310 

NUEVO ENERGY COMPANY C 242 2 NOx 2357 2654 2937 2661
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-3 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

NUEVO ENERGY COMPANY C 322 2 NOx 3336 3689 4029 3704

NUEVO ENERGY COMPANY C 323 2 NOx 2977 2977 2977 2977

NUEVO ENERGY COMPANY C 452 2 NOx 2236 0 5755 6063

PARAMOUNT FARMS, INC. C 343 2 NOx 0 4611 4573 1214

PARAMOUNT FARMS, INC. C 497 2 NOx 1000 2000 4000 3000

PASTORIA ENERGY LLC C 481 2 NOx 16404 7142 1086 10577

PIRELLI TIRE CORP. C 27 2 NOx 12628 7460 6641 3662

PIRELLI TIRE CORP. C 505 2 NOx 129 137 122 117 

PRODUCERS COTTON OIL 

(MADERA) C 48 2 NOx 0 0 0 74 

R F MACDONALD C 579 2 NOx 0 8 0 0 

R M WADE & COMPANY C 152 2 NOx 326 373 379 370 

SEQUOIA FOREST INDUSTRIES C 67 2 NOx 16 70 0 44 

SEQUOIA FOREST INDUSTRIES C 72 2 NOx 154 0 20 24 

TURLOCK IRRIGATION DISTRICT C 482 2 NOx 24685 34404 40916 31425

VALLEY AIR CONDITIONING & 

REPAIR INC C 584 2 NOx 0 0 409 0 

WELLHEAD POWER PANOCHE, LLC. C 529 2 NOx 0 255 255 0 

WESTSIDE FARMERS COOP. GIN C 164 2 NOx 0 0 0 846 

ANDERSON CLAYTON CORP. N 181 2 NOx 0 0 1 111 

ANDERSON CLAYTON 

CORPORATION N 135 2 NOx 0 0 0 97 

BROWN SAND INC N 46 2 NOx 90 98 46 83 

CALPINE CORPORATION N 195 2 NOx 41829 41829 41829 41828

CALPINE CORPORATION N 272 2 NOx 308 36838 15649 308 

CAMPBELL SOUP COMPANY N 127 2 NOx 1515 454 409 924 

CASTLE AIRPORT AVIATION & 

DEVELOP CENTER N 109 2 NOx 38954 39386 39819 39819

CITY OF VISALIA N 317 2 NOx 0 0 7160 0 

CONAGRA CONSUMER FROZEN 

FOODS N 37 2 NOx 718 526 606 663 

CONAGRA CONSUMER FROZEN 

FOODS N 318 2 NOx 0 0 3380 0 

CONOPCO DBA UNILEVER BEST 

FOODS N AMER N 91 2 NOx 0 0 9120 180 

DEL MONTE CORPORATION N 316 2 NOx 321 274 790 147 

DEL MONTE CORPORATION/PLANT 

#1 N 58 2 NOx 0 0 27616 0 

DUKE ENERGY NORTH AMERICA N 229 2 NOx 0 1166 88317 1422

DUKE ENERGY NORTH AMERICA N 231 2 NOx 0 9 1255 437 

DUKE ENERGY NORTH AMERICA N 232 2 NOx 0 0 4728 0 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-4 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

E & J GALLO WINERY N 2 2 NOx 2587 2434 7175 7642

E & J GALLO WINERY N 260 2 NOx 0 172 515 71 

ECKERT FROZEN FOODS N 133 2 NOx 146 545 2047 395 

ENRON CAPITAL & TRADE 

RESOURCE N 183 2 NOx 574 565 475 445 

FIBREBOARD CORP. N 209 2 NOx 535 447 204 583 

FOSTER FOOD PRODUCTS N 254 2 NOx 1825 1824 1822 1823

GALLO GLASS COMPANY N 54 2 NOx 21897 20995 21313 21532

GALLO GLASS COMPANY N 276 2 NOx 69524 70655 72080 67173

GALLO GLASS COMPANY N 278 2 NOx 83525 66849 77176 81929

GALLO GLASS COMPANY N 280 2 NOx 89634 87268 90814 85504

GENERAL MILLS OPERATIONS, INC N 139 2 NOx 288 245 243 337 

GRAHAM ROYALTY, LTD N 6 2 NOx 18467 18467 18467 18467

H. J. HEINZ COMPANY N 39 2 NOx 0 1509 8208 148 

H. J. HEINZ COMPANY, L.P. N 21 2 NOx 0 1026 3112 1060

HERSHEY CHOCOLATE & CONF. 

CORP N 42 2 NOx 24 19 32 24 

HERSHEY CHOCOLATE & CONF. 

CORP N 373 2 NOx 156 188 224 202 

HILMAR CHEESE COMPANY N 424 2 NOx 729 0 3540 0 

HOLLY SUGAR CORPORATION N 257 2 NOx 3505 9788 11695 9157

INTERLAKE MATERIAL HANDLING N 414 2 NOx 1131 1183 1027 1132

LA PALOMA GENERATING 

COMPANY N 365 2 NOx 0 9612 23105 0 

LEPRINO FOODS N 108 2 NOx 2335 2529 2412 2143

LIDESTRI FOODS, INC N 391 2 NOx 0 0 1527 0 

LOS BANOS GRAVEL GROUP, 

ASPHLT N 125 2 NOx 23 113 359 120 

MODESTO ENERGY LIMITED 

PARTNER N 89 2 NOx 9480 9480 9480 9480

MODESTO ENERGY LIMITED 

PARTNER N 425 2 NOx 18860 11467 22662 22553

MODESTO IRRIGATION DISTRICT N 371 2 NOx 3971 10226 0 17390

MODESTO IRRIGATION DISTRICT N 372 2 NOx 0 9439 51165 922 

MODESTO IRRIGATION DISTRICT N 407 2 NOx 8000 8000 8000 8000

MORNING STAR PACKING 

COMPANY N 138 2 NOx 4882 8207 4833 3163

MORNING STAR PACKING 

COMPANY N 332 2 NOx 0 0 8139 0 

PACIFIC COAST PRODUCERS N 12 2 NOx 0 0 10015 0 

PACIFIC COAST PRODUCERS N 293 2 NOx 195 1396 3923 312 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-5 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

PACIFIC GAS & ELECTRIC CO. N 126 2 NOx 1840 4712 4259 1636

PARAMOUNT FARMS, INC N 284 2 NOx 3670 3580 3488 3488

PILKINGTON NORTH AMERICA, INC N 410 2 NOx 272 4 43 275 

POSDEF POWER COMPANY, L.P. N 14 2 NOx 1085 1097 1109 1109

POSDEF POWER COMPANY, L.P. N 15 2 NOx 7792 7878 7965 7965

SAN JOAQUIN COGEN N 90 2 NOx 4686 4738 4790 4790

SIGNATURE FRUIT COMPANY, LLC -

PLANT 4 N 399 2 NOx 177 172 1273 128 

SIGNATURE FRUIT COMPANY, LLC -

PLANT R N 387 2 NOx 10542 3731 2487 5171

SIGNATURE FRUIT COMPANY, LLC -

PLANT T N 388 2 NOx 0 0 5529 581 

SOUTHERN CALIFORNIA GAS 

CORORATION N 299 2 NOx 0 1311 1415 0 

STOCKDALE OIL & GAS N 384 2 NOx 173 0 3 0 

SUN GARDEN-GANGI CANNING CO 

LL N 222 2 NOx 0 0 12886 540 

THE BEVERAGE SOURCE N 92 2 NOx 220 800 520 900 

THE NESTLE COMPANY INC N 93 2 NOx 2975 2650 2476 3352

TRIANGLE PACIFIC CORPORATION N 18 2 NOx 187 54 54 161 

VINTAGE PETROLEUM N 346 2 NOx 0 165 1432 14 

WESTERN STONE PRODUCTS, INC. N 17 2 NOx 543 543 619 619 

AERA ENERGY LLC S 133 2 NOx 3203 0 0 0 

AERA ENERGY LLC S 135 2 NOx 5032 1152 0 0 

AERA ENERGY LLC S 137 2 NOx 5115 6792 5437 9206

AERA ENERGY LLC S 139 2 NOx 11686 11816 11946 11946

AERA ENERGY LLC S 140 2 NOx 36695 46397 47292 36806

AERA ENERGY LLC S 158 2 NOx 38057 29690 32405 43791

AERA ENERGY LLC S 162 2 NOx 1E+05 2E+05 1E+05 1E+05

AERA ENERGY LLC S 163 2 NOx 96698 1E+05 1E+05 78678

AERA ENERGY LLC S 257 2 NOx 1508 1272 2 2 

AERA ENERGY LLC S 259 2 NOx 5519 6499 0 2156

AERA ENERGY LLC S 470 2 NOx 3478 4930 5390 5212

AERA ENERGY LLC S 662 2 NOx 9433 18919 3766 817 

AERA ENERGY LLC S 784 2 NOx 7140 3993 228 0 

AERA ENERGY LLC S 796 2 NOx 16403 14218 15065 18484

AERA ENERGY LLC S 838 2 NOx 442 218 338 338 

AERA ENERGY LLC S 865 2 NOx 6713 6788 6863 6863

AERA ENERGY LLC S 883 2 NOx 632 160 2073 2061

AERA ENERGY LLC S 1030 2 NOx 93295 83665 32600 77083
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-6 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

AERA ENERGY LLC S 1061 2 NOx 8071 8777 10695 9555

AERA ENERGY LLC S 1062 2 NOx 8530 9784 10046 9903

AERA ENERGY LLC S 1063 2 NOx 9423 10057 12159 9776

AERA ENERGY LLC S 1064 2 NOx 5126 5705 5881 6709

AERA ENERGY LLC S 1065 2 NOx 10366 10483 11017 8841

AERA ENERGY LLC S 1066 2 NOx 5542 7367 5038 6117

AERA ENERGY LLC S 1067 2 NOx 1255 893 2650 4592

AERA ENERGY LLC S 1068 2 NOx 7648 9620 6968 8415

AERA ENERGY LLC S 1069 2 NOx 4713 5029 4352 2082

AERA ENERGY LLC S 1070 2 NOx 495 4228 2744 99 

AERA ENERGY LLC S 1092 2 NOx 348 242 246 236 

AERA ENERGY LLC S 1136 2 NOx 2522 4568 1346 162 

AERA ENERGY LLC S 1151 2 NOx 96355 1E+05 1E+05 1E+05

AERA ENERGY LLC S 1270 2 NOx 4586 4637 4688 4688

AERA ENERGY LLC S 1437 2 NOx 42372 49588 46800 43954

AERA ENERGY LLC S 1476 2 NOx 1242 0 0 350 

AERA ENERGY LLC S 1477 2 NOx 2153 0 0 607 

AERA ENERGY LLC S 1821 2 NOx 5974 7291 7466 4158

AERA ENERGY LLC S 1851 2 NOx 914 455 0 1154

AERA ENERGY LLC S 1935 2 NOx 474 508 543 543 

AERA ENERGY LLC S 2023 2 NOx 1108 636 737 993 

AERA ENERGY LLC S 40130321 2 NOx 9180 6501 2218 3514

ANDERSON CLAYTON CORP S 314 2 NOx 0 0 23 330 

ANDERSON CLAYTON CORP S 471 2 NOx 0 0 0 416 

ANDERSON CLAYTON CORP S 1045 2 NOx 0 0 3 174 

ANDERSON CLAYTON CORP S 1171 2 NOx 23 0 0 188 

ANDERSON CLAYTON CORP S 1262 2 NOx 2 0 7 148 

ANDERSON CLAYTON CORP S 1263 2 NOx 76 0 0 211 

ANDERSON CLAYTON-MARICOPA 

GIN S 697 2 NOx 0 0 0 348 

BERRY PETROLEUM COMPANY S 567 2 NOx 8752 106 0 1833

BERRY PETROLEUM COMPANY S 884 2 NOx 326 446 179 392 

BERRY PETROLEUM COMPANY S 2066 2 NOx 1211 339 275 1247

CALPINE CORPORATION S 1280 2 NOx 20238 17410 19037 19604

CALPINE CORPORATION S 1666 2 NOx 0 0 0 256 

CHEVRON U S A INC S 519 2 NOx 990 1001 1012 1012

CHEVRON U S A INC S 629 2 NOx 2316 2041 2088 1975

CHEVRON U S A INC S 1325 2 NOx 260 118 276 211 

CHEVRON U S A INC S 1428 2 NOx 1968 1990 2011 2011
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-7 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

CHEVRON USA INC S 1100 2 NOx 62167 62857 63548 63548

CHEVRON USA INC S 1102 2 NOx 57160 57795 58430 58430

CHEVRON USA INC S 1106 2 NOx 11814 11942 12075 12075

CHEVRON USA INC S 1254 2 NOx 13332 13480 13627 13627

CHEVRON USA INC S 1256 2 NOx 45238 45741 46244 46244

CHEVRON USA INC S 1419 2 NOx 4875 4928 4983 4983

CHEVRON USA INC S 1445 2 NOx 17602 20114 20328 15867

CHEVRON USA INC S 1730 2 NOx 7823 15506 22039 12182

CHEVRON USA INC S 77 2 NOx 2038 1840 1733 2274

CHEVRON USA INC S 496 2 NOx 5160 233 1734 4212

CHEVRON USA INC S 909 2 NOx 3990 3412 3474 3072

CHEVRON USA INC S 1487 2 NOx 11663 11793 11923 11923

CHEVRON USA INC S 1584 2 NOx 78972 79850 80728 80728

CHEVRON USA INC S 1589 2 NOx 48737 49278 49820 49820

CHEVRON USA INC S 1605 2 NOx 5672 7143 7028 6447

CHEVRON USA INC S 1967 2 NOx 973 955 855 984 

CHEVRON USA INC S 2031 2 NOx 5694 4723 4406 0 

CHEVRON USA INC S 20410241 2 NOx 2E+05 1E+05 1E+05 2E+05

CHEVRON USA INC S 20410281 2 NOx 3806 3765 3765 3848

CHEVRON USA INC S 40088101 2 NOx 41166 42720 41536 41222

CHEVRON USA INC S 40410441 2 NOx 20385 20612 20838 20838

CHEVRON USA INC (REFINERY) S 20050011 2 NOx 52919 53507 54095 54095

CHEVRON USA INC LOST HILLS GP S 704 2 NOx 5564 5626 5687 5687

CHEVRON USA INC LOST HILLS GP S 1470 2 NOx 780 789 797 797 

CHEVRON USA PRODUCTION INC S 674 2 NOx 507 781 226 485 

COTTON ASSOCIATES, INC S 25 2 NOx 0 0 0 157 

ELK HILLS POWER LLC S 1622 2 NOx 1373 1389 1404 1404

ELK HILLS POWER LLC S 1994 2 NOx 12485 12624 12762 12762

ENRON NORTH AMERICA CORP S 1702 2 NOx 1E+05 1E+05 1E+05 1E+05

ENRON NORTH AMERICA CORP S 1788 2 NOx 2395 2395 2395 2395

ENRON NORTH AMERICA CORP S 1794 2 NOx 11605 11605 11605 11605

EQUILON ENTERPRISES LLC S 1014 2 NOx 4645 5658 5190 4325

EQUILON ENTERPRISES LLC S 1650 2 NOx 1425 1689 1612 1776

EQUILON ENTERPRISES LLC S 1652 2 NOx 2E+05 2E+05 2E+05 2E+05

EXXON MOBIL CORPORATION S 84 2 NOx 1648 1666 1685 1685

EXXON MOBIL CORPORATION S 188 2 NOx 5175 5197 5494 4871

EXXON MOBIL CORPORATION S 301 2 NOx 3010 2818 2052 3565

GAF DBA BUILDING MATERIALS 

MFG. CORP. S 1662 2 NOx 5832 5840 5848 5848
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-8 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

GOTLAND OIL (GAS PLANT) S 2011 2 NOx 417 345 508 572 

GROWERS COOP S 88 2 NOx 0 0 22 406 

GWF ENERGY LLC S 1910 2 NOx 0 0 3 0 

HILMAR CHEESE COMPANY S 2057 2 NOx 3921 2784 2976 5720

KRAFT FOODS, INC S 116 2 NOx 0 3296 538 2660

KRAFT FOODS, INC S 117 2 NOx 0 2971 2714 2156

KRAFT FOODS, INC S 118 2 NOx 0 3374 5552 6708

KRAFT FOODS, INC S 119 2 NOx 0 0 3425 1107

KRAFT FOODS, INC S 120 2 NOx 0 0 1229 0 

KRAFT FOODS, INC S 129 2 NOx 7208 0 0 0 

KRAFT FOODS, INC S 130 2 NOx 3887 3670 0 733 

KRAFT FOODS, INC S 131 2 NOx 2070 0 0 94 

LA PALOMA GENERATING CO LLC S 1357 2 NOx 22379 22627 22876 22876

LA PALOMA GENERATING CO LLC S 1386 2 NOx 1457 0 1145 2959

LA PALOMA GENERATING CO LLC S 1389 2 NOx 11282 16892 9045 13640

LA PALOMA GENERATING CO LLC S 1390 2 NOx 0 9294 4654 14613

LA PALOMA GENERATING CO LLC S 1399 2 NOx 5123 5415 2148 3593

LA PALOMA GENERATING CO LLC S 1400 2 NOx 2682 3241 938 687 

LA PALOMA GENERATING CO LLC S 1401 2 NOx 23349 23151 24224 24469

LA PALOMA GENERATING CO LLC S 1402 2 NOx 1019 2105 1303 264 

LA PALOMA GENERATING CO LLC S 1403 2 NOx 2296 16202 9353 954 

LA PALOMA GENERATING CO LLC S 1920 2 NOx 0 1437 0 0 

LAND O' LAKES, INC. S 1816 2 NOx 27269 18630 20700 20796

LIVE OAK LIMITED S 3 2 NOx 1585 1603 1620 1620

MID-VALLEY COTTON GROWERS 

INC S 317 2 NOx 0 0 0 296 

MONTEREY RESOURCES, INC. S 432 2 NOx 2053 2081 1707 1898

NRG POWER MARKETING, INC S 2041 2 NOx 1837 0 0 598 

NUEVO ENERGY COMPANY S 1580 2 NOx 13229 10050 6765 15163

NUEVO ENERGY COMPANY S 1581 2 NOx 10010 10691 10155 6716

NUEVO ENERGY COMPANY S 1582 2 NOx 8908 7571 8947 9569

OCCIDENTAL OF ELK HILLS, INC. S 826 2 NOx 6684 6259 5625 6369

OCCIDENTAL OF ELK HILLS, INC. S 829 2 NOx 2393 2504 2988 2422

OCCIDENTAL OF ELK HILLS, INC. S 1617 2 NOx 49124 49669 50215 50215

OCCIDENTAL OF ELK HILLS, INC. S 1619 2 NOx 66550 67290 68029 68029

OCCIDENTAL OF ELK HILLS, INC. S 1891 2 NOx 156 275 140 224 

PACIFIC PIPELINE SYSTEM, LLC S 575 2 NOx 0 4693 10418 3569

PACIFIC PIPELINE SYSTEM, LLC S 577 2 NOx 4090 5007 5251 5251

PACIFIC PIPELINE SYSTEM, LLC S 1099 2 NOx 0 13703 12649 0 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-9 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

PASTORIA ENERGY FACILITY, LLC S 1340 2 NOx 45681 47927 46196 44813

PASTORIA ENERGY FACILITY, LLC S 1341 2 NOx 4319 5348 5007 4447

PASTORIA ENERGY FACILITY, LLC S 1342 2 NOx 3233 0 3511 5000

PASTORIA ENERGY FACILITY, LLC S 1343 2 NOx 1847 2417 1590 2044

PASTORIA ENERGY FACILITY, LLC S 1543 2 NOx 10354 8381 11018 11467

PASTORIA ENERGY FACILITY, LLC S 1544 2 NOx 3384 2194 2118 3141

PASTORIA ENERGY FACILITY, LLC S 1545 2 NOx 1696 3526 1536 1221

PASTORIA ENERGY FACILITY, LLC S 1547 2 NOx 3986 9681 19140 9076

PASTORIA ENERGY FACILITY, LLC S 1550 2 NOx 1160 7055 4075 3491

PASTORIA ENERGY FACILITY, LLC S 1554 2 NOx 3E+05 3E+05 3E+05 3E+05

RECOT INC S 1862 2 NOx 13752 13939 14110 14110

SAN JOAQUIN FACILITIES MGMT S 89 2 NOx 1855 1489 1875 1907

SAN JOAQUIN FACILITIES MGMT S 200 2 NOx 597 493 600 649 

SAN JOAQUIN FACILITIES MGMT S 1253 2 NOx 459 509 544 481 

SAN JOAQUIN FACILITIES MGMT S 1509 2 NOx 34 45 45 45 

SAN JOAQUIN FACILITIES MGMT S 1735 2 NOx 9 8 6 4 

SEMI TROPIC COOP GIN S 426 2 NOx 50 0 24 1282

SENECA RESOURCES S 1427 2 NOx 88 57 76 98 

SIERRA POWER CORPORATION S 2910001 2 NOx 2115 2138 2162 2162

SOUTHERN CALIF GAS CO S 1016 2 NOx 283 288 289 289 

STOCKDALE OIL & GAS INC S 1948 2 NOx 22 0 0 0 

TAFT PRODUCTION COMPANY S 1960 2 NOx 5840 5905 5970 5970

TAFT PRODUCTION COMPANY S 1961 2 NOx 130 131 132 132 

TEXACO EXPLOR & PROD INC S 436 2 NOx 12891 9861 9530 10101

TEXACO EXPLOR & PROD INC S 20250361 2 NOx 7037 7356 6314 6778

TURLOCK IRRIGATION DISTRICT S 1834 2 NOx 27815 18096 11584 21075

WATERMAN INDUSTRIES INC S 2003 2 NOx 1347 1294 804 875 

WESTERN COTTON SERVICES S 98 2 NOx 0 0 0 184 

AERA ENERGY LLC C 183 1 VOC 11307 11761 11802 11504

AERA ENERGY LLC C 219 1 VOC 268 297 324 298 

AMERICAN YEAST CORPORATION C 247 1 VOC 6939 7016 7094 7094

ANDERSON CLAYTON 

CORP/CORCORAN C 81 1 VOC 0 0 0 15 

ANDERSON CLAYTON 

CORP/DAIRYLAN C 332 1 VOC 0 0 0 7 

ANDERSON CLAYTON 

CORP/DAIRYLND C 472 1 VOC 0 0 0 13 

ANDERSON CLAYTON CORP/EL 

DORAD C 427 1 VOC 1 0 0 17 

ANDERSON CLAYTON CORP/FIVE C 78 1 VOC 0 0 0 8 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-10 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

PTS 

ANDERSON CLAYTON 

CORP/HANFORD C 74 1 VOC 0 0 0 5 

ANDERSON CLAYTON CORP/IDRIA 

#2 C 250 1 VOC 0 0 0 9 

ANDERSON CLAYTON 

CORP/KEARNY C 75 1 VOC 0 0 0 7 

ANDERSON CLAYTON 

CORP/KERMAN C 428 1 VOC 0 0 0 11 

ANDERSON CLAYTON 

CORP/KINGSRIV C 460 1 VOC 2 0 0 31 

ANDERSON CLAYTON CORP/MURIT 

#1 C 334 1 VOC 0 0 0 7 

ANDERSON CLAYTON CORP/MURIT 

#2 C 336 1 VOC 0 0 0 7 

ANDERSON CLAYTON 

CORP/MURRAY C 234 1 VOC 0 0 0 12 

ANDERSON CLAYTON CORP/NAPA 

GIN C 335 1 VOC 0 0 0 5 

ANDERSON CLAYTON CORP/PLSNT 

VA C 326 1 VOC 0 0 0 18 

ANDERSON CLAYTON CORP/SAN 

JOAQ C 79 1 VOC 0 0 0 5 

ANDERSON CLAYTON 

CORP/SETTER C 76 1 VOC 0 0 0 7 

ANDERSON CLAYTON 

CORP/STRATFOR C 56 1 VOC 0 0 0 4 

ANDERSON CLAYTON 

CORP/SUNSET C 333 1 VOC 0 0 0 5 

ANDERSON CLAYTON 

CORP/TRANQLTY C 80 1 VOC 0 0 0 12 

ARCO PIPELINE FACILITY C 271 1 VOC 419 417 417 417 

BERRY PETROLEUM COMPANY C 542 1 VOC 6442 4348 3828 4584

BERRY PETROLEUM COMPANY C 543 1 VOC 41 42 38 37 

BERRY PETROLEUM COMPANY C 568 1 VOC 1249 1248 944 1068

BRITZ AG FINANCE CO., INC. C 557 1 VOC 0 0 0 8 

BRITZ INCORPORATED C 586 1 VOC 0 0 0 21 

BUILDERS CONCRETE, INC. C 41 1 VOC 35 35 35 35 

CALAVERAS MATERIALS INC C 89 1 VOC 92 83 95 76 

CALAVERAS MATERIALS INC. C 233 1 VOC 148 410 483 300 

CALMAT CO. C 50 1 VOC 2 2 3 3 

CALMAT OF FRESNO C 40 1 VOC 2 11 5 17 

CALPINE CORPORATION C 348 1 VOC 30485 30519 30470 30501
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-11 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

CALPINE CORPORATION C 447 1 VOC 0 0 0 7 

CANDLEWICK YARNS C 507 1 VOC 23 20 16 14 

CHEVRON USA INC C 221 1 VOC 357 395 431 396 

CHEVRON USA INC C 277 1 VOC 2209 2209 2209 2209

CHEVRON USA INC C 331 1 VOC 1220 1220 1221 1221

CLARK BROTHERS-DERRICK GIN C 511 1 VOC 0 0 0 2 

COALINGA FARMERS CO-OP GIN C 537 1 VOC 0 0 0 8 

COIT RANCH C 532 1 VOC 0 0 0 8 

CORCORAN IRRIGATION DISTRICT C 560 1 VOC 154 163 159 90 

CRAYCROFT BRICK COMPANY C 71 1 VOC 24 20 19 19 

DART CONTAINER CORPORATION C 555 1 VOC 30481 26626 14213 50680

DUKE ENERGY AVENAL, LLC C 464 1 VOC 5480 6496 4696 6616

DUKE ENERGY NORTH AMERICA C 400 1 VOC 45 45 45 45 

DUNCAN ENTERPRISES C 33 1 VOC 26 26 27 18 

HANSEN BROTHERS C 249 1 VOC 0 0 0 13 

J.G. BOSWELL CO. (EL RICO) C 135 1 VOC 1 0 0 1 

LEPRINO FOODS COMPANY C 60 1 VOC 137 139 136 138 

MODESTO IRRIGATION DISTRICT C 539 1 VOC 513 616 819 689 

MODESTO IRRIGATION DISTRICT C 552 1 VOC 669 1765 1586 659 

MODESTO IRRIGATION DISTRICT C 553 1 VOC 266 686 1005 1062

MODESTO IRRIGATION DISTRICT C 554 1 VOC 216 684 1077 949 

NAS LEMOORE C 330 1 VOC 12 12 12 12 

NAS LEMOORE C 346 1 VOC 1765 610 1223 215 

NATIONAL CEMENT COMPANY C 283 1 VOC 10311 10311 10311 10313

NUEVO ENERGY COMPANY C 324 1 VOC 10126 10123 10121 10121

NUEVO ENERGY COMPANY C 452 1 VOC 1729 27 3599 3523

NUEVO ENERGY COMPANY C 509 1 VOC 192 207 253 270 

PACIFIC GAS & ELECTRIC CO. C 280 1 VOC 21981 68020 71348 53244

PACTIV CORPORATION C 162 1 VOC 14172 14172 14172 14172

PACTIV CORPORATION C 397 1 VOC 3189 3189 3189 2201

PACTIV CORPORATION C 522 1 VOC 6449 6035 6686 6301

PACTIV CORPORATION C 551 1 VOC 68102 23673 20343 38447

PACTIV CORPORATION C 561 1 VOC 64098 0 0 0 

PACTIV CORPORATION C 593 1 VOC 9986 9206 9494 9041

PAR III INC C 506 1 VOC 0 7125 7589 0 

PARAMOUNT FARMS, INC. C 291 1 VOC 0 0 63 12 

PELCO C 29 1 VOC 374 374 349 349 

PELCO C 167 1 VOC 1842 2601 2219 1756
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-12 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

PRODUCERS COTTON OIL 

(MADERA) C 48 1 VOC 0 0 0 4 

SEALED AIR CORPORATION C 409 1 VOC 29500 29500 29500 29500

SEQUOIA FOREST INDUSTRIES C 67 1 VOC 2 9 0 6 

SEQUOIA FOREST INDUSTRIES C 72 1 VOC 7 0 1 1 

SHELL CALIFORNIA PIPELINE 

COMPANY LLC C 467 1 VOC 185 0 0 0 

SILGAN CONTAINER CORP. C 359 1 VOC 4501 4813 4481 5201

SILGAN CONTAINER CORP. C 360 1 VOC 3414 3423 3418 3425

TRI-TECH GRAPHICS C 215 1 VOC 753 546 783 564 

TURLOCK IRRIGATION DISTRICT C 484 1 VOC 13350 13350 13350 13350

UNOCAL CALIF PIPELINE CO C 590 1 VOC 3155 2048 3304 1323

UNOCAL CALIF PIPELINE CO C 591 1 VOC 4064 4908 4834 4505

VENDO COMPANY C 165 1 VOC 2509 3099 1865 1338

WESTSIDE FARMERS COOP. GIN C 164 1 VOC 0 0 0 31 

ANDERSON CLAYTON CORP. N 181 1 VOC 0 0 0 6 

ANDERSON CLAYTON 

CORPORATION N 135 1 VOC 0 0 0 5 

APTCO LLC N 390 1 VOC 1370 1266 1618 948 

APTCO LLC N 397 1 VOC 12104 11748 9416 0 

APTCO LLC N 398 1 VOC 3141 4397 3194 0 

BARBOSA CABINETS, INC. N 420 1 VOC 11000 2000 2000 0 

BERRY PETROLEUM COMPANY N 427 1 VOC 2988 4184 4658 3379

BROWN SAND INC N 46 1 VOC 2 2 1 2 

CALIFORNIA DAIRIES N 412 1 VOC 792 792 792 792 

CALIFORNIA DAIRIES N 415 1 VOC 1006 1006 1006 1006

CALIFORNIA-WASHINGTON CAN 

CO. N 77 1 VOC 2664 0 0 1583

CALIFORNIA-WASHINGTON CAN 

CO. N 187 1 VOC 3081 1485 2118 1547

CALPINE CORPORATION N 208 1 VOC 26 1107 904 26 

CALPINE CORPORATION N 303 1 VOC 53352 43607 47208 38670

CAMPBELL SOUP COMPANY N 127 1 VOC 84 58 52 61 

CASTLE AIRPORT AVIATION & 

DEVELOP CENTER N 109 1 VOC 33690 34064 34438 34438

CONAGRA CONSUMER FROZEN 

FOODS N 37 1 VOC 55 40 46 50 

CONOCOPHILLIPS COMPANY N 428 1 VOC 2695 2843 966 1851

CONOPCO DBA UNILEVER BEST 

FOODS N AMER N 52 1 VOC 0 0 278 0 

CONOPCO DBA UNILEVER BEST N 91 1 VOC 0 0 180 0 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-13 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

FOODS N AMER 

DEL MONTE CORPORATION N 316 1 VOC 82 71 116 28 

DOPACO INC. N 249 1 VOC 34162 18446 18900 32156

DUKE ENERGY NORTH AMERICA N 232 1 VOC 0 0 709 0 

DUKE ENERGY NORTH AMERICA N 233 1 VOC 0 0 241 0 

E & J GALLO WINERY N 2 1 VOC 9 9 26 28 

ECKERT FROZEN FOODS N 133 1 VOC 3 11 41 8 

ENRON CAPITAL & TRADE 

RESOURCE N 183 1 VOC 30 30 25 24 

FABRICATED EXTRUSION 

COMPANY N 286 1 VOC 2087 2185 2284 2284

FIBREBOARD CORP. N 209 1 VOC 41 34 16 45 

GENERAL MILLS OPERATIONS, INC N 139 1 VOC 16 13 13 19 

H. J. HEINZ COMPANY N 60 1 VOC 0 23 129 0 

H. J. HEINZ COMPANY, L.P. N 21 1 VOC 0 60 180 60 

HANFORD, L.P. N 101 1 VOC 40 184 131 98 

HERSHEY CHOCOLATE & CONF. 

CORP N 42 1 VOC 1 1 1 1 

HERSHEY CHOCOLATE & CONF. 

CORP N 373 1 VOC 9 11 13 11 

HOLLY SUGAR CORPORATION N 257 1 VOC 841 506 897 1831

INTERLAKE MATERIAL HANDLING N 414 1 VOC 6309 7827 6255 5476

J.R. WOOD, INC. N 132 1 VOC 3 11 41 8 

KINGS RIVER CONSERVATION 

DISTRICT N 416 1 VOC 1196 0 0 0 

KINGS RIVER CONSERVATION 

DISTRICT N 418 1 VOC 684 3120 4980 0 

LIDESTRI FOODS, INC N 391 1 VOC 0 0 389 0 

LOS BANOS GRAVEL GROUP, 

ASPHLT N 125 1 VOC 16 81 258 86 

MODESTO ENERGY LIMITED 

PARTNER N 224 1 VOC 255 174 267 249 

MODESTO IRRIGATION DISTRICT N 285 1 VOC 2050 2050 2050 2050

MODESTO IRRIGATION DISTRICT N 389 1 VOC 858 1303 694 560 

MODESTO IRRIGATION DISTRICT N 406 1 VOC 31 31 31 31 

MORNING STAR PACKING 

COMPANY N 138 1 VOC 157 264 156 102 

NATIONAL CEMENT COMPANY OF 

CAL N 174 1 VOC 36077 39363 40649 33826

NATIONAL CEMENT COMPANY OF 

CAL N 178 1 VOC 8260 9792 6902 0 

NATIONAL CEMENT COMPANY OF N 179 1 VOC 12338 12264 12139 12300
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-14 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

CAL 

NATIONAL CEMENT COMPANY OF 

CAL N 180 1 VOC 12608 4735 9811 7692

PACIFIC COAST PRODUCERS N 417 1 VOC 1945 4396 3184 0 

PACIFIC COAST PRODUCERS N 421 1 VOC 0 6627 2435 0 

PACIFIC GAS & ELECTRIC CO. N 126 1 VOC 3143 8046 7255 2832

PACTIV CORPORATION N 339 1 VOC 27192 27192 27192 27192

SIGNATURE FRUIT COMPANY, LLC -

PLANT 4 N 399 1 VOC 23 22 164 16 

SIGNATURE FRUIT COMPANY, LLC -

PLANT R N 387 1 VOC 457 183 143 253 

SIGNATURE FRUIT COMPANY, LLC -

PLANT T N 388 1 VOC 0 0 691 75 

SILGAN CONTAINERS MFR CORP N 191 1 VOC 1063 936 808 808 

STOCKDALE OIL & GAS N 348 1 VOC 16 16 14 14 

STOCKDALE OIL & GAS N 386 1 VOC 30 30 32 30 

THE NESTLE COMPANY INC N 93 1 VOC 997 1820 1874 1007

WESTERN STONE PRODUCTS, INC. N 17 1 VOC 6 6 7 7 

AERA ENERGY LLC S 663 1 VOC 544 495 483 454 

AERA ENERGY LLC S 728 1 VOC 67328 68076 68824 68824

AERA ENERGY LLC S 868 1 VOC 724 735 729 672 

AERA ENERGY LLC S 898 1 VOC 5312 5371 5429 5429

AERA ENERGY LLC S 1058 1 VOC 8179 8280 8354 8353

AERA ENERGY LLC S 1082 1 VOC 1E+05 1E+05 1E+05 1E+05

AERA ENERGY LLC S 1138 1 VOC 162 233 2 25 

AERA ENERGY LLC S 1142 1 VOC 39631 39976 40411 40489

AERA ENERGY LLC S 1157 1 VOC 1522 0 2176 1998

AERA ENERGY LLC S 1162 1 VOC 713 719 730 730 

AERA ENERGY LLC S 1186 1 VOC 3811 3432 3876 3953

AERA ENERGY LLC S 1476 1 VOC 190 0 0 54 

AERA ENERGY LLC S 1477 1 VOC 329 0 0 93 

AERA ENERGY LLC S 1481 1 VOC 2270 2296 2320 2320

AERA ENERGY LLC S 1587 1 VOC 26 28 26 26 

AERA ENERGY LLC S 1681 1 VOC 10 10 10 10 

AERA ENERGY LLC S 1732 1 VOC 379 354 395 484 

AERA ENERGY LLC S 1740 1 VOC 94 88 98 119 

AERA ENERGY LLC S 1742 1 VOC 590 551 614 752 

AERA ENERGY LLC S 1744 1 VOC 458 428 476 583 

AERA ENERGY LLC S 1849 1 VOC 28243 29571 28868 28766

AERA ENERGY LLC S 1872 1 VOC 0 1018 0 0 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-15 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

AERA ENERGY LLC S 1874 1 VOC 40 10 1 22 

AERA ENERGY LLC S 1880 1 VOC 360 591 251 0 

AERA ENERGY LLC S 1899 1 VOC 62458 63160 63861 63861

AERA ENERGY LLC S 1979 1 VOC 2E+05 2E+05 2E+05 2E+05

AERA ENERGY LLC S 2021 1 VOC 21531 1489 3659 2623

AERA ENERGY LLC S 2039 1 VOC 36 6 55 161 

AERA ENERGY LLC S 2045 1 VOC 16809 18377 18805 16268

AERA ENERGY LLC S 2047 1 VOC 2167 2024 2256 2762

AERA ENERGY LLC S 2049 1 VOC 5905 5974 6050 6050

AERA ENERGY LLC S 2053 1 VOC 6537 6645 6757 6757

AERA ENERGY LLC S 2059 1 VOC 25865 26261 26659 26659

AGRI-CEL INC S 1901 1 VOC 6304 7646 8132 4838

ANDERSON CLAYTON CORP S 314 1 VOC 0 0 1 18 

ANDERSON CLAYTON CORP S 471 1 VOC 0 0 0 9 

ANDERSON CLAYTON CORP S 1045 1 VOC 0 0 0 22 

ANDERSON CLAYTON CORP S 1171 1 VOC 3 0 0 24 

ANDERSON CLAYTON CORP S 1262 1 VOC 1 0 0 19 

ANDERSON CLAYTON CORP S 1263 1 VOC 9 0 0 24 

ANDERSON CLAYTON-MARICOPA 

GIN S 697 1 VOC 0 0 0 25 

APTCO LLC S 872 1 VOC 9 8 9 9 

APTCO LLC S 1990 1 VOC 1306 1709 1829 1157

APTCO LLC S 2017 1 VOC 5 14 25 25 

CALPINE CORPORATION S 1575 1 VOC 4021 3700 6230 3026

CALPINE CORPORATION S 1665 1 VOC 8440 8546 8621 8621

CALPINE CORPORATION S 1666 1 VOC 0 0 0 9 

CHEVRON U S A INC S 357 1 VOC 28 24 24 31 

CHEVRON U S A INC S 629 1 VOC 48 42 43 41 

CHEVRON U S A INC S 1973 1 VOC 2676 2707 2737 2737

CHEVRON U S A INC S 2037 1 VOC 32 34 35 35 

CHEVRON USA INC S 474 1 VOC 651 659 666 666 

CHEVRON USA INC S 1952 1 VOC 572 498 626 626 

CHEVRON USA INC S 77 1 VOC 42 38 36 47 

CHEVRON USA INC S 165 1 VOC 2970 3003 3036 3036

CHEVRON USA INC S 246 1 VOC 218 220 223 223 

CHEVRON USA INC S 409 1 VOC 5 7 18 12 

CHEVRON USA INC S 410 1 VOC 5 7 11 15 

CHEVRON USA INC S 411 1 VOC 4 9 12 12 

CHEVRON USA INC S 412 1 VOC 230 170 188 205 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-16 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

CHEVRON USA INC S 413 1 VOC 20 20 20 16 

CHEVRON USA INC S 616 1 VOC 85663 86614 87567 87567

CHEVRON USA INC S 619 1 VOC 1E+05 1E+05 1E+05 1E+05

CHEVRON USA INC S 620 1 VOC 83316 84241 85167 85167

CHEVRON USA INC S 621 1 VOC 37551 37968 38385 38385

CHEVRON USA INC S 623 1 VOC 29047 29369 29692 29692

CHEVRON USA INC S 626 1 VOC 8668 8764 8860 8860

CHEVRON USA INC S 628 1 VOC 18193 18395 18598 18598

CHEVRON USA INC S 640 1 VOC 3230 3264 3298 3298

CHEVRON USA INC S 647 1 VOC 235 699 540 95 

CHEVRON USA INC S 703 1 VOC 2084 2107 2130 2130

CHEVRON USA INC S 755 1 VOC 8053 8143 8232 8232

CHEVRON USA INC S 1432 1 VOC 1E+05 1E+05 1E+05 1E+05

CHEVRON USA INC S 1592 1 VOC 4273 4320 4368 4368

CHEVRON USA INC S 1699 1 VOC 2591 2620 2650 2650

CHEVRON USA INC S 1793 1 VOC 1420 1443 1335 1334

CHEVRON USA INC S 1878 1 VOC 230 136 143 82 

CHEVRON USA INC S 1908 1 VOC 7677 7762 7849 5795

CHEVRON USA INC S 1912 1 VOC 225 238 250 250 

CHEVRON USA INC S 1987 1 VOC 473 479 484 484 

CHEVRON USA INC S 2004 1 VOC 3143 2826 2020 2227

CHEVRON USA INC S 2005 1 VOC 640 696 679 621 

CHEVRON USA INC S 2033 1 VOC 301 304 307 259 

CHEVRON USA INC S 2051 1 VOC 1199 1222 1247 1247

CHEVRON USA INC S 2073 1 VOC 17141 17337 17533 17533

CHEVRON USA INC (REFINERY) S 657 1 VOC 35011 35399 35788 35788

CHEVRON USA INC LOST HILLS GP S 1847 1 VOC 2764 2793 2825 2825

CHEVRON USA PRODUCTION INC S 674 1 VOC 5779 5851 5903 5902

CLEAN HARBORS BUTTONWILLOW, 

LLC S 685 1 VOC 31195 31541 31888 31888

CONOCOPHILLPS S 2067 1 VOC 1340 1170 1170 1340

COTTON ASSOCIATES, INC S 25 1 VOC 0 0 0 8 

DELTA TRADING ICO CRIMSON 

RESOURCE MGMT S 2056 1 VOC 8848 8946 9044 9044

DUKE ENERGY AVENAL, LLC S 1700 1 VOC 87500 87500 87500 87500

DUKE ENERGY AVENAL, LLC S 1797 1 VOC 31432 31424 31417 31417

DUKE ENERGY AVENAL, LLC S 1805 1 VOC 31431 31424 31417 31417

ENRON OIL & GAS COMPANY S 1044 1 VOC 5516 5576 5638 5638

EQUILON ENTERPRISES LLC S 1785 1 VOC 1E+06 1E+06 1E+06 1E+06
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-17 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

EQUILON ENTERPRISES LLC S 1885 1 VOC 59372 60236 60677 60578

EXXON MOBIL CORPORATION S 645 1 VOC 127 129 130 130 

FOSTER FOOD PRODUCTS S 1501 1 VOC 432 437 442 442 

FOSTER FOOD PRODUCTS S 1502 1 VOC 68 63 58 58 

GOTLAND OIL (GAS PLANT) S 2011 1 VOC 362 290 454 518 

GOTLAND OIL INC S 1995 1 VOC 1325 4629 6301 1518

GOTLAND OIL INC S 1996 1 VOC 838 3608 4714 954 

GOTLAND OIL INC S 1997 1 VOC 653 2997 4027 763 

GOTLAND OIL INC S 1998 1 VOC 105 1473 2033 152 

GOTLAND OIL INC S 1999 1 VOC 123 1513 2068 162 

GOTLAND OIL INC S 2000 1 VOC 540 2873 3896 660 

GOTLAND OIL INC S 2001 1 VOC 1190 4465 5981 1360

GOTLAND OIL INC S 2002 1 VOC 1178 4452 6003 1377

GROWERS COOP S 88 1 VOC 0 0 1 15 

GWF POWER SYSTEMS S 1956 1 VOC 10000 10000 10000 10000

HOLMES WESTERN OIL 

CORPORATION S 439 1 VOC 281 595 667 265 

HOLMES WESTERN OIL 

CORPORATION S 458 1 VOC 31 63 70 31 

INERGY PROPANE LLC S 2055 1 VOC 248 237 148 160 

KRAFT FOODS, INC S 138 1 VOC 383 508 489 663 

KRAFT FOODS, INC S 141 1 VOC 123 57 121 0 

KRAFT FOODS, INC S 472 1 VOC 82 82 82 82 

KRAFT FOODS, INC S 630 1 VOC 330 398 459 413 

LA PALOMA GENERATING CO LLC S 1374 1 VOC 4213 4272 4307 4307

LA PALOMA GENERATING CO LLC S 1377 1 VOC 950 1016 1152 1093

LA PALOMA GENERATING CO LLC S 1918 1 VOC 470 1408 299 358 

LAND O' LAKES, INC. S 1178 1 VOC 527 1043 813 0 

LIVE OAK LIMITED S 3 1 VOC 198 200 202 202 

LIVE OAK LIMITED S 601 1 VOC 873 882 892 892 

LONE STAR GAS LIQUIDS S 2071 1 VOC 1582 3251 3995 2661

LOS ALAMOS FARMS INC S 1869 1 VOC 0 9 345 350 

LOS ALAMOS FARMS INC S 1870 1 VOC 7 15 38 38 

MACPHERSON OIL COMPANY S 1836 1 VOC 785 794 803 803 

MCFARLAND ENERGY INC. S 624 1 VOC 227 230 232 232 

MID-VALLEY COTTON GROWERS 

INC S 317 1 VOC 0 0 0 6 

MODESTO IRRIGATION DISTRICT S 1963 1 VOC 1661 1640 1406 1058

MONTEREY RESOURCES, INC. S 1983 1 VOC 708 720 557 640 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-18 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

OCCIDENTAL OF ELK HILLS, INC. S 829 1 VOC 57 60 72 58 

OCCIDENTAL OF ELK HILLS, INC. S 1170 1 VOC 1E+05 1E+05 1E+05 1E+05

OCCIDENTAL OF ELK HILLS, INC. S 1492 1 VOC 75450 84130 86706 82019

OCCIDENTAL OF ELK HILLS, INC. S 1593 1 VOC 3128 3163 3197 3197

OCCIDENTAL OF ELK HILLS, INC. S 1668 1 VOC 4168 3886 3453 3948

OCCIDENTAL OF ELK HILLS, INC. S 1679 1 VOC 748 1855 2026 905 

OCCIDENTAL OF ELK HILLS, INC. S 1703 1 VOC 394 1333 1998 1038

OCCIDENTAL OF ELK HILLS, INC. S 1704 1 VOC 1695 3741 4523 1688

OCCIDENTAL OF ELK HILLS, INC. S 1705 1 VOC 1759 4105 4872 2140

OCCIDENTAL OF ELK HILLS, INC. S 1706 1 VOC 2314 5505 6449 2760

OCCIDENTAL OF ELK HILLS, INC. S 1707 1 VOC 1717 3992 4929 2029

OCCIDENTAL OF ELK HILLS, INC. S 1708 1 VOC 1664 3970 4474 1890

OCCIDENTAL OF ELK HILLS, INC. S 1709 1 VOC 315 1237 1357 410 

OCCIDENTAL OF ELK HILLS, INC. S 1710 1 VOC 1655 4021 5103 2114

OCCIDENTAL OF ELK HILLS, INC. S 1712 1 VOC 1663 3366 3194 1481

OCCIDENTAL OF ELK HILLS, INC. S 1713 1 VOC 1093 2620 3078 1181

OCCIDENTAL OF ELK HILLS, INC. S 1714 1 VOC 1290 3038 3527 1472

OCCIDENTAL OF ELK HILLS, INC. S 1715 1 VOC 4321 9955 12590 5444

OCCIDENTAL OF ELK HILLS, INC. S 1716 1 VOC 1136 2806 3570 1534

OCCIDENTAL OF ELK HILLS, INC. S 1717 1 VOC 1239 3804 4274 1639

OCCIDENTAL OF ELK HILLS, INC. S 1718 1 VOC 2007 4650 5387 2519

OCCIDENTAL OF ELK HILLS, INC. S 1719 1 VOC 928 1948 2037 1118

OCCIDENTAL OF ELK HILLS, INC. S 1720 1 VOC 729 1479 2150 697 

OCCIDENTAL OF ELK HILLS, INC. S 1721 1 VOC 1729 4201 5109 2056

OCCIDENTAL OF ELK HILLS, INC. S 1722 1 VOC 1132 2723 3230 1359

OCCIDENTAL OF ELK HILLS, INC. S 1723 1 VOC 1723 4185 4934 2003

OCCIDENTAL OF ELK HILLS, INC. S 1724 1 VOC 1399 3732 4724 2025

OCCIDENTAL OF ELK HILLS, INC. S 1725 1 VOC 1169 2764 3251 1348

OCCIDENTAL OF ELK HILLS, INC. S 1726 1 VOC 1603 3911 4662 1932

OCCIDENTAL OF ELK HILLS, INC. S 1727 1 VOC 1061 2580 3064 1240

OCCIDENTAL OF ELK HILLS, INC. S 1728 1 VOC 1692 4025 4596 2098

OCCIDENTAL OF ELK HILLS, INC. S 1754 1 VOC 0 653 619 0 

OCCIDENTAL OF ELK HILLS, INC. S 1773 1 VOC 379 0 0 468 

OCCIDENTAL OF ELK HILLS, INC. S 1775 1 VOC 604 591 0 577 

OCCIDENTAL OF ELK HILLS, INC. S 1776 1 VOC 594 607 467 614 

OCCIDENTAL OF ELK HILLS, INC. S 1777 1 VOC 419 454 0 0 

OCCIDENTAL OF ELK HILLS, INC. S 1778 1 VOC 0 1021 0 0 

OCCIDENTAL OF ELK HILLS, INC. S 1779 1 VOC 0 656 559 0 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-19 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

OCCIDENTAL OF ELK HILLS, INC. S 1780 1 VOC 0 1678 0 0 

OCCIDENTAL OF ELK HILLS, INC. S 1782 1 VOC 454 464 398 0 

OCCIDENTAL OF ELK HILLS, INC. S 1783 1 VOC 587 2 35 4 

OCCIDENTAL OF ELK HILLS, INC. S 1889 1 VOC 147 233 220 207 

OCCIDENTAL OF ELK HILLS, INC. S 1931 1 VOC 192 1183 1553 309 

OCCIDENTAL OF ELK HILLS, INC. S 1977 1 VOC 141 144 143 128 

OILDALE ENERGY LLC S 1096 1 VOC 100 100 100 100 

OXY USA INC S 730 1 VOC 69 97 110 67 

OXY USA INC S 732 1 VOC 2515 3279 4266 2964

OXY USA INC S 733 1 VOC 1646 2248 2602 1805

OXY USA INC S 734 1 VOC 4 8 8 4 

OXY USA INC S 735 1 VOC 7 11 13 8 

OXY USA INC S 736 1 VOC 80 157 165 81 

OXY USA INC S 737 1 VOC 310 575 603 317 

OXY USA INC S 738 1 VOC 192 375 395 198 

OXY USA INC S 1755 1 VOC 53 109 120 52 

OXY USA INC S 1756 1 VOC 360 778 883 372 

OXY USA INC S 1757 1 VOC 2 7 9 4 

OXY USA INC S 1758 1 VOC 88 193 195 93 

OXY USA INC S 1759 1 VOC 137 267 382 193 

PACIFIC PIPELINE SYSTEM, LLC S 776 1 VOC 28 67 77 34 

PACTIV CORPORATION S 1839 1 VOC 9504 9955 9794 9744

PACTIV CORPORATION S 1840 1 VOC 21 23 22 22 

PACTIV CORPORATION S 1863 1 VOC 24274 24274 24274 24274

PACTIV CORPORATION S 1974 1 VOC 10754 10855 10978 10999

PASTORIA ENERGY FACILITY, LLC S 1549 1 VOC 82952 83873 84795 84794

RECOT INC S 1464 1 VOC 54968 57523 60078 60078

RECOT INC (DBA FRITO-LAY) S 16 1 VOC 76 96 74 72 

RECOT INC (DBA FRITO-LAY) S 768 1 VOC 55 57 58 58 

SAN JOAQUIN FACILITIES MGMT S 648 1 VOC 116 93 118 120 

SAN JOAQUIN FACILITIES MGMT S 677 1 VOC 61 50 61 66 

SAN JOAQUIN FACILITIES MGMT S 1253 1 VOC 41 46 50 44 

SAN JOAQUIN FACILITIES MGMT S 1509 1 VOC 11 14 14 14 

SAN JOAQUIN FACILITIES MGMT S 1813 1 VOC 51741 46456 50539 55824

SEMI TROPIC COOP GIN S 426 1 VOC 1 0 1 28 

SENECA RESOURCES S 874 1 VOC 94 1541 2266 1754

SENECA RESOURCES S 875 1 VOC 7 11 1 3 

SHELL PIPELINE COMPANY LP S 1807 1 VOC 86 58 26 26 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix B- Current List of Emission 

 Reduction Credits

B-20 

List of NOx and VOC Emissions Reduction Credits 

July 2004- (cont.)

 Emissions (lbs/quarter)

Facility Name Certificate NumberPollutant 1st

QTR

2nd

QTR 

3rd

QTR 

4th

QTR

SMITHERS-OASIS S 1838 1 VOC 160 179 159 159 

SOUTHERN CALIF GAS CO S 671 1 VOC 570 576 583 583 

SOUTHERN CALIF GAS CO S 1739 1 VOC 1322 1337 1354 1352

TAFT PRODUCTION COMPANY S 1960 1 VOC 122 124 125 125 

TEXACO EXPLOR & PROD INC S 904 1 VOC 492 551 403 459 

TEXACO EXPLOR & PROD INC S 1049 1 VOC 3461 0 0 0 

TEXACO EXPLOR & PROD INC S 1055 1 VOC 14573 13985 11845 12671

TRC OPERATING COMPANY INC S 767 1 VOC 394 399 403 403 

UNIVERSITY ENERGY SERVICES S 561 1 VOC 63 54 59 61 

VISALIA WASTEWATER 

TREATMENT S 1837 1 VOC 5067 2634 4107 4614

WESTERN COTTON SERVICES S 606 1 VOC 0 0 0 9 
Regional Transportation 

Planning Agency Commitments

APPENDIX C 
❖
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix C- Regional Transportation 

 Planning Agency Commitments 

 C-1 

PREFACE 

This Appendix consists of several hundred pages of control measure 

commitments developed by local governments in the San Joaquin Valley Air 

Basin (SJVAB) and compiled and submitted through the Regional Transportation 

Planning Agencies. The two-volume set is organized by county, and the 

resolution and associated specific commitments for each are presented in 

alphabetical order by local government name within each county. A summary 

table at the beginning of each county section gives an overview of the control 

measure commitments adopted by each government within the county. The 

complete title of the documents comprising this uncirculated appendix is 

Regional Transportation Planning Agency Commitments for Implementation 

Document (Volumes 4 and 5, dated March 2004). 

This appendix is available for viewing in hardcopy at the San Joaquin Valley 

Unified Air Pollution Control District, 1990 E. Gettysburg, Fresno, California, 

93726. Contact: Don Hunsaker at (559) 230-5800. 

This Appendix is also available for viewing in hardcopy at the following locations: 

• U.S. Environmental Protection Agency, Region IX, 75 Hawthorne Street, 

San Francisco, California 94105. Contact: David Wampler at (415) 972-

3975 

• California Air Resources Board, 1001 I Street, Sacramento, California 

95812. Contact: Ravi Ramalingam at (916) 322-2085 
❖
MODELING AND ATTAINMENT 

DEMONSTRATIONS

APPENDIX D 
❖
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix D - Modeling and 

 Attainment Demonstrations 

D-1

D.1 Overview 

This document presents modeling documentation and results in support of a 1-hour 

ozone State Implementation Plan (SIP) update for the San Joaquin Valley Air Pollution 

Control District. The modeling results are for the July/August 2000 Central California 

Ozone Study (CCOS) episode, one of three ozone episodes intensively measured 

during the summer 2000 field study. Of the three CCOS episodes, the July/August 

episode was selected for use in this SIP. This determination was based on both the 

representativeness of the meteorology, ozone concentrations, and the performance of 

model for this period. Other ozone episodes are in development by the districts and 

their contractors, and may also be available for ozone SIP use by some or all of the 

districts in the region. 

The process to develop and validate an air quality model is very complex and resource 

intensive. The development of the July/August CCOS episode was no exception. A 

great deal of time and effort was spent in the development and review of the modeling 

inputs, and in the application and validation of the air quality model. Many stakeholders 

have participated in this process, including local air districts and transportation planning 

agencies in the region, and members of the CCOS Technical Advisory Committee. The 

modeling for this episode is an ongoing effort, since it will eventually support many uses 

in addition to one-hour ozone SIP planning, and to reflect new information and 

improvements in the science. However, the modeling results presented in this 

document satisfy accepted model performance criteria and we believe they are 

acceptable and appropriate for use in SIP planning. 

The remaining sections and appendices of this document provide a description of the 

model development and application process, the episode, the model inputs, the results 

of the model performance evaluation, and the results from application of the model to 

future years. 

D.2 Episode Characterization 

The characteristics and evolution of the July/August 2000 Central California Ozone 

Study (CCOS) episode are comprehensively documented by Technical and Business 

Systems (T&B, 2003). The reader is referred to that document for detailed information 

about the episode. In this section we briefly summarize the air quality and meteorology 

of the episode, and describe the CCOS database, which provides online access to all of 

the data collected during the field study. 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix D - Modeling and 

 Attainment Demonstrations 

D-2

Table D-1 summarizes the peak one-hour ozone concentrations measured during the 

July/August episode. The highest ozone concentration during this episode was 151 ppb 

on August 2 at Edison in the southern portion of the San Joaquin Valley. Peak ozone 

values on July 30 occurred in the San Joaquin Valley, where values near 130 ppb were 

recorded at Parlier and Edison; the Bay Area and Sacramento region experienced no 

federal 1-hour exceedances that day. On July 30, only the San Joaquin Valley 

exceeded the 1-hour NAAQS for ozone. Concentrations at Parlier and Edison were 129 

and 128 respectively. The highest reading on July 31 occurred at Livermore in the Bay 

Area; the measured peak value was 126 ppb. This was the only exceedance of the 

federal standard on that day in the CCOS domain. The only federal 1-hour 

exceedances on August 1 occurred in the Sacramento region, which experienced its 

highest ozone readings of the episode. On that day the Sloughouse site recorded a 

peak value of 133 ppb. Similarly, the only exceedances on August 2 occurred in the 

San Joaquin Valley, which had peak readings of 131 ppb in the northern part of the 

valley (Turlock and Modesto) and the maximum concentration for the episode at Edison 

of 151 ppb. 

Table D-1 

Measured ozone concentrations during the July/August CCOS Episode 

Peak 1-Hour Ozone Concentrations 

Date Sacramento 

Nonattainment Area Bay Area San Joaquin Valley - North 

San Joaquin 

Valley - South 

Basin 

Max 

(ppb) 

Station 

Basin 

Max 

(ppb) 

Station

Basin 

Max 

(ppb) 

Station 

Basin 

Max 

(ppb) 

Station

7/30/2000 121 Sloughhouse 82 Livermore 

(old)

129 Parlier 128 Edison

7/31/2000 103 Davis 126 Livermore 

(old)

118 Clovis 115 Edison

8/1/2000 133 Sloughhouse 94 Livermore 

(new)

118 FresnoSierra 

Skypark 

#2 

116 Arvin 

8/2/2000 116 Cool 98 Livermore 

(old)

131 Modesto & 

Turlock 

151 Edison

There were several large wildfires during the July/August CCOS episode, and some of 

the peak ozone readings during the episode are suspected to have been influenced at 

least in part by wildfire emissions. Day-specific emissions from these wildfires have 

been included in the modeling inventories for the episode. Table D-2 summarizes the 

locations of, and total acres burned from, the largest fires that occurred during the 

episode. 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix D - Modeling and 

 Attainment Demonstrations 

D-3

Table D-2

Summary of wildfire activity and acreage burned during the 

July/August 2000 CCOS episode.

Day-Specific 

Point 

Sources? 

DaySpecific 

Wildfires? 

Characterization of Wildfires

Total Acres Burned July 29 - Aug 2, 

2000 

Largest Fires in 

Domain, Acres 

County 

67,300 Tulare 

2,500 Washoe, NV

Yes Yes 700 Kern 

99,000 acres burning in California 

(92,000 acres in CCOS domain). Fires 

burning in Oregon (9,100 acres) and in 

Nevada (112,000 acres). 

300 Kern 

D.3 Meteorological Conditions During the July/August 2000 CCOS 

Episode 

The CCOS episode of July 27 through August 2, 2000, was typical of the weather types 

where exceedances of the one hour NAAQS have occurred. Historically exceedances 

of the NAAQS in the CCOS region occur during strong ridging. Lehrman, et. al., (2003) 

typed weather patterns and determined that the episode began as a stagnant/flat type 

and ended with strong ridging. This was the same sequence of meteorology that 

occurred in the last episode used for the San Joaquin Valley ozone attainment plan 

done in 1994. That episode, August 3—6, 1990, also began with a stagnant/flat type 

and ended with strong ridging. Statistical analyses indicate that this episode is in the 

upper range of poor air pollution dispersion meteorology that results in exceedances of 

the NAAQS in the San Joaquin Valley. Lehrman (2003) reported that all days during 

the July-August 2000 ozone episode fall into meteorology categories within one 

standard deviation of the mean for days greater than the NAAQS. 

A typical Great Basin high pressure system was observed during the course of this 

episode. The 500 mb analysis also showed the existence of a relatively large high 

pressure ridge with a maximum geopotential height of 5960 m that was centered over 

Utah and vicinity. A second high pressure center was also located off the coast of 

California around 35o

N latitude. 

The high pressure ridge recorded by both surface and 500 mb analyses resulted in 

relatively calm winds with magnitude of less than 2 m/s near the surface. Dry bulb 

temperatures recorded by the surface observational network at 2 m height exceeded 

100 o

F, and dew point temperatures were around 40 oF within the SJV. Temperatures 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix D - Modeling and 

 Attainment Demonstrations 

D-4

at 850 mb over the San Joaquin Valley (SJV) were larger in magnitude (80 oF/27 oC) 

than those recorded in a typical steady state atmosphere (less than 20oC). 

The pressure, temperature, and wind patterns observed near the surface persisted 

throughout the episode. The Great Basin high pressure system and 500 mb ridge 

remained nearly stationary, while the high pressure system located off the coast of 

California increased in strength and moved in a north-south direction during the 

episode. 

Analysis of upper level winds at 300 mb did not indicate the existence of a well defined 

subtropical jet-stream, while the polar jet-stream was located at 55oN latitude. The subtropical jet appears to have been reduced in magnitude over the continental United 

States, and was especially weak over California with a maximum value of only 20 m/s. 

Since upper level winds are the driving forces for near surface conditions, their absence 

typically implies weak near-surface winds. 

An overall analyses of near-surface winds and temperature, 850 mb temperatures, 500 

mb pressures, and 300 mb winds all suggest the existence of a blocking high pressure 

ridge located over the California-Nevada corridor. This pressure pattern can slow the 

progression of atmospheric motion from west to east, and its main effect can be seen as 

the creation of a relatively stagnant atmosphere within the SJV. While some inland 

penetration of the sea breeze was noted from surface and upper level weather maps, its 

effect on the circulation pattern within the SJV and its inland penetration distance does 

not appear to have been significant. 

D.4 Field Study Data 

The CCOS database is comprised of data collected under contract to CCOS as well as 

a variety of routine, supplemental sources. More specific information regarding the 

CCOS field study design and CCOS data collection efforts, including information on the 

supplemental data sources, can be found in the documents located under the following 

link: 

http://www.arb.ca.gov/airways/CCOS/CCOS.htm

In addition, CCOS field data can be accessed in two ways: 

• CCOS data and version-specific documentation are available under the following 

FTP link (Version 1A-06092003 of the CCOS database is used for model 

performance): 

ftp://eos.arb.ca.gov/pub/DATA/ccos/

• Interactive web queries (using the latest version of the database) are available at: 

http://www.arb.ca.gov/airways/Datamaintenance/default.asp
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix D - Modeling and 

 Attainment Demonstrations 

D-5

D.4.1 Field Data Quality Assurance (QA) and Quality Control (QC) 

CCOS field study contractors were required to provide data to the database manager at 

QA Level 1B (a description of data QA/QC levels is provided at the end of this section). 

Sources of routinely collected, supplemental data (e.g. AIRS and CIMIS data) are also 

represented in the database and are assumed to be at QA Level 2. Further information 

on the CCOS database (e.g. data validity flags, system design, etc.) can be found at: 

http://www.arb.ca.gov/airways/CRPAQS/lookups.htm

Prior to utilizing data in model validations, the data are plotted and screened for outliers 

by modeling staff. In general, few changes are made in elevating the status of a data 

record from Level 1B to Level 2 (i.e. in terms of the entire quantity of records in the 

database). Since some analyses are applied to episodes rather than to all samples, 

some data records in a file will achieve Level 2 designation while the remaining records 

will remain at Level 1B. Only a few data records will be designated as Level 3 to 

identify that they have undergone additional investigation. Data designated as Levels 2 

or 3 validations are not necessarily “better” than data designated at Level 1B. The level 

only signifies that they have undergone additional scrutiny as a result of the tests 

described above. 

D.4.2 Summary of QA/QC Levels 

Level 1A (1A): These data have passed several validation tests applied by the field 

operator/investigator prior to data submission. The general features of Level 1A QA are: 

1. Retain all data values and use the appropriate flags. Missing values 

should be ‘null’ and flagged as missing; 

2. Flagging measurements when significant deviations from 

measurement assumptions have occurred; 

3. Verifying computer file entries against data sheets; 

4. Replacement of data from a backup data acquisition system in the 

event of failure of the primary system; 

5. Adjustment of measurement values for quantifiable baseline and span 

or interference biases; and

6. Identification, investigation, and flagging of data that are beyond 

reasonable bounds or that are unrepresentative of the variable being 

measured (e.g. high light scattering associated with adverse weather). 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix D - Modeling and 

 Attainment Demonstrations 

D-6

Level 1B (1B): Level 1B consists of univariate checks such as maxima and minima, 

rates of change, and diurnal variations.

Level 2 (2): Level 2 validation is the first step in data analysis. Level 2 data validation 

takes place after data from various measurement methods have been assembled in the 

master database. Level 2 tests involve the testing of measurement assumptions (e.g. 

internal nephelometer temperatures do not significantly exceed ambient temperatures), 

comparisons of collocated measurements (e.g. filter and continuous sulfate and 

absorption), and internal consistency tests (e.g. the sum of measured aerosol species 

does not exceed measured mass concentrations). 

Level 3 (3): Level 3 is applied when the results from different modeling and data 

analysis approaches are compared with each other and with measurements. The first 

assumption upon finding a measurement, which is inconsistent with physical 

expectations, is that the unusual value is due to a measurement error. If upon tracing 

the path of the measurement, nothing unusual is found, the value can be assumed to be 

a valid result of an environmental cause. The Level 3 designation is applied only to 

those variables that have undergone this re-examination after the completion of data 

analysis and modeling. Level 3 validation continues for as long as the database is 

maintained. A higher validation level assigned to a data record indicates that those data 

have gone through, and passed, a greater level of scrutiny than data at a lower level. 

D.4.3 Database File Format and File Naming Convention 

The data are organized in Parameter Group files as listed below in Table D-4. These 

files are in a standard, normalized file format and consist of data that span all CCOS 

monitoring periods and parameters. Documentation regarding these parameter group 

files is available at the following URL: 

http://www.arb.ca.gov/airways/CRPAQS/lookups.htm

The file format standard is designed to facilitate incorporating user validation and QA 

back into the database. If users require to or intend to have data validation work 

integrated back into the database, a specific re-submittal process is required. 

Documentation of the file format, file naming convention, and data resubmittal standards 

is contained in the following two documents: 

• Standard File Format and File Naming Convention: FINAL – Parameter Groups – 

Record Layout – Rev. 2.0: http://www.arb.ca.gov/airways/CRPAQS/lookups.htm

• Resubmittal Standards: Data Review, Revision and Resubmits – release v2.0 

(12/20/02): http://www.arb.ca.gov/airways/CRPAQS/lookups.htm
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Table D-4 

Parameter Groups*

Aircraft Air Quality and Meteorological – Parameter Group #14 

Surface Continuous Gaseous Air Quality – Parameter Group #5 

Surface Continuous Meteorological – Parameter Group #1 

Surface VOC Canister – Parameter Group #13 

Upper Level Air Quality – Parameter Group #6 

Upper Level Virtual Temperature – Parameter Group #3 

Upper Level Wind – Parameter Group #2 

Upper Level Meteorological – Parameter Group #4 

Surface DNPH Cartridge Carbonyl – Parameter Group #XX (still being created) 

* Some of these

D.5 Meteorological Modeling 

D.5.1 Introduction 

Meteorological conditions leading to elevated ozone levels during summer 2000 Central 

California Ozone Study (CCOS) episodes were studied using the Pennsylvania State 

University/National Center for Atmospheric Research (PSU/NCAR) Mesoscale Model 

version 5 (MM5) (Grell et al, 1995) and the CALMET objective/diagnostic model (Earth 

Tech, 2000). The MM5 model best describes the physics that define the movement of 

the atmosphere. However, the meteorological regimes defined by such models do not 

always reproduce what is shown by meteorological measurements. As an alternative, 

the CALMET model generates meteorological fields by extrapolation of existing 

measurements. Therefore, the CALMET model may be better suited for use with the 

extensive measurements collected during the summer 2000 CCOS field study. 

However, meteorological measurements were not collected uniformly across the CCOS 

study domain. To best utilize the available CCOS meteorological measurements and to 

take advantage of the physics in MM5, a hybrid approach was utilized which matches 

measured meteorological parameters where measurements were made and relies on 

the physics within MM5 to estimate meteorological parameters where measurements 

were not available. This approach is described in more detail in sub-section D.5.3. 

D.5.1.1 MM5 

MM5 is a limited area, terrain-following sigma coordinate model based on a Lambert 

Conformal projection, and was developed by PSU and NCAR as a community 

mesoscale model. It is a non-hydrostatic numerical model that allows users to study the 

atmospheric motions at small scales by explicitly treating the effects of convective 

motions on atmospheric circulations. It has continuously been improved by 
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contributions from a broad scientific community and improvements into the model are 

regularly incorporated. MM5 is maintained by and at NCAR, along with the necessary 

input meteorological and geographical data. 

MM5 was set up with three nested grids of 36, 12 and 4 km (Figure D.1). The coarse 

grid nest with 36 km horizontal resolution provides the synoptic scale conditions to all 

three grids while the innermost grid with 4 km horizontal resolution resolves the fine 

details of atmospheric motions within the modeling domain. There are several options 

in MM5 to calculate the components of internal and external forces acting on a volume 

of air, such as radiation and microphysics, which may affect model results. Therefore, a 

number of alternative parameterizations were tested to develop the best possible 

meteorology for the CCOS episodes. Among the options tested were the Kain and 

Fritsch (1993) cumulus parameterization scheme for coarse grids, the MRF or Gayno 

Seaman planetary boundary layer (PBL) scheme for calculation of boundary layer 

fluxes, Dudhia’s simple ice scheme for the treatment of excess moisture, the RRTM 

scheme for longwave radiation calculation (Mlawer, 1997) along with Dudhia’s short 

wave radiation calculation, and the Blackadar multi-layer, force-restore method soil 

model. 

Initial and boundary conditions were prepared using the analyses of observations 

prepared by the National Center for Environmental Prediction (NCEP) and archived at 

NCAR. Surface and upper air synoptic observations obtained by NCEP were also used 

to further refine the initial and boundary conditions. CCOS episodes were first 

simulated using initial and boundary conditions (IC/BCs) with no analysis or 

observational nudging on the two coarse grids. Then, IC/BCs were prepared from the 

12 km grid output for the 4 km grid. Four-dimensional data assimilation, using surface 

and upper air observations collected during CCOS by surface stations, towers, 

rawinsondes, sodars, and radar wind profilers was used to improve IC/BCs for the 4 km 

grid. The model was used to simulate a 144 hour period during July 29-August 4, 2000, 

which included one of the CCOS episodes. The 3-D wind and temperature values 

simulated by the model were compared against surface and upper air observations to 

study the temporal and 3-D spatial structure of atmospheric motions as well as to 

evaluate the model performance. 
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Figure D.1 

The location of the three nested grids adopted for the 

numerical modeling of CCOS episodes using MM5. 

D.5.1.2 CALMET 

The CALMET program is essentially a model that develops 2- and 3-dimensional fields 

of meteorological parameters using distance-weighted averaging (i.e., objective 

analysis). It is considered a 'diagnostic' model because it also includes features for 

averaging the results of the objective analysis with an input 'initial guess' wind field, for 

terrain adjustments, and algorithms for minimizing mass divergence. In addition to 

geographical inputs such as terrain heights and land use, CALMET requires 

meteorological observations over land and water, and upper-air meteorological profiles. 

D.5.2 Domain and Vertical Structure 

The CCOS study domain was defined in a Lambert Conical Projection with 2 Parallels 

(Table D-5). The domain extends from Los Angeles County in the south to the 

California/Oregon boundary in the north, and from the Pacific Ocean into Nevada in the 

east (Figure D.2). The horizontal study domain is comprised of 189 x 189, 4-km grid 

cells. Conventional wisdom indicates that cells on the boundary of a modeling domain 

can contain numerical anomalies, therefore a 2-cell offset was used to create an air 

quality modeling domain of 185 x 185, 4-km grid cells. 

The vertical structure of the air quality modeling domain was defined based on the 

source of the meteorological inputs. For the July/August, 2000 CCOS episode, two 
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meteorological models were used; each with a unique vertical structure: MM5 and 

CALMET. The MM5 prognostic meteorological model uses as vertical coordinates a 

normalized pressure index in a 'sigma' coordinate system. In this coordinate system, 

vertical heights are temperature- and pressure- dependent. Approximate vertical layer 

heights for sea level are shown in Table D-6. The CALMET meteorological model uses 

a fixed-height vertical structure and these levels are also shown in Table D-6. Both the 

MM5 model and the CALMET model use terrain-following coordinate systems and the 

heights are defined as height (meters) above ground level (magl). 

The number and thickness of the vertical layers in the air quality modeling domain is 

also dependent on the height of the top of the domain. Ozonesonde measurements 

(data not shown) during the July/August, 2000 CCOS episode showed relatively high 

concentrations of ozone at heights above 5000 magl. Because these measurements 

suggested a natural vertical boundary, the top of the air quality modeling domain was 

set at 5000 magl (see Table D-6). For both meteorological models, 16 vertical layers 

were selected. 

Table D-5 

Lambert Conical Projection coordinate system used 

to define the CCOS modeling domain

Reference Latitudes 30 N 60 N 

Central Meridian 120.5 W 

Northing Offset 768.28 km 

Easting Offset 0.0 km 

Grid Cell Number 189 x 189 

Grid Cell Size 4 km 

Northing Origin -300.0 km 

Easting Origin -384.0 km 
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Table D-6 

The vertical structure of the air quality modeling domain for the July/August, 2000 

CCOS episode based on the MM5 and CALMET meteorological models 

MM5 CALMET 

Layer 

Number 

Thickness 

(m) 

Height 

(m AGL) 

Thickness 

(m) 

Height 

(m AGL) 

1 

2 

3 

4

5 

6 

7 

8

9 

10 

11 

12

13 

14 

15 

16 

24 

26 

56 

66

74 

133 

161 

182

205 

232 

265 

356

488 

666 

926 

1140 

24 

50 

106 

172

246 

379 

540 

722

927 

1159 

1424 

1780

2268 

2934 

3860 

5000 

20 

40 

40 

100

100 

100 

200 

200

200 

500 

500 

500

500 

500 

500 

1000 

20 

60 

100 

200

300 

400 

600 

800

1000 

1500 

2000 

2500

3000 

3500 

4000 

5000 
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Figure D.2 

Air quality modeling domain for the CCOS 

July/August, 2000 episode.

D.5.3 Developing CALMET/MM5 Hybrid Meteorological Fields for CCOS Modeling 

Prognostic meteorological models such as MM5 have shown promise for modeling 

areas that include complex meteorology. However, historically it has proven difficult to 

apply them successfully within California without modification. The 1994 San Joaquin 

Valley SIP was based on a version of MM5 that was altered from its original form 

(referred to as the “SARMAP Meteorological Model (MM5)” – Tesche and McNally, 

1997). In their 2003 Air Quality Management Plan, the South Coast Air Quality 

Management District used MM5 for some ozone modeling; however, only after postprocessing the MM5 outputs to make corrections (SCAQMD, 2003). Kumar and Russell 

(1996) concluded that prognostic meteorological models tend to overestimate wind 

velocities and underestimate air temperatures. They recommended that air quality 

models could get improved results with meteorological inputs from diagnostic models. 

The SCAQMD (2003) used CALMET for the greater part of their ozone modeling. Robe 

and Scire (1998) recommended a hybrid approach that combines MM5 and CALMET 

and this approach was successfully applied for ozone modeling by Barna et. al. (2000). 
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As described previously, a hybrid approach was utilized in this study which best utilizes 

the available CCOS meteorological measurements and takes advantage of the physics 

in MM5. This approach matches measured meteorological parameters where 

measurements were made and relies on the physics within MM5 to estimate 

meteorological parameters where measurements were not available. The 

CALMET/MM5 hybrid meteorological fields developed for the July/August 2000 CCOS 

episode include a weighted average of the wind fields generated by an objective 

analysis and the wind fields resulting from the prognostic meteorological model MM5. 

The CALMET meteorological model (EarthTech, 2000) has provisions for the 

incorporation of MM5 wind fields as CALMET 'initial guess' fields. However, because of 

the size of the CCOS modeling domain and the necessity of converting MM5 fields into 

text format for input into CALMET, this approach for developing hybrid meteorological 

fields is cumbersome. Also, the approach described by EarthTech presumes sufficient 

observational data for objective analysis throughout the modeling domain. The Central 

Valley of California is well represented with routine meteorological observational sites 

and the CCOS field study included a supplemental network of upper-air meteorological 

measurements. However, there are relatively few meteorological measurements for 

large portions of the CCOS domain, including over the Pacific Ocean and in Nevada. 

Therefore, an alternative approach to developing a hybrid meteorological field was 

developed that allows the use of 'virtual observations' from MM5-generated 

meteorological fields to fill in where other observations were not available. 

To generate the CALMET/MM5 hybrid meteorological fields for the CCOS episodes, 

four pieces of software were used. The first piece of software was the CALMET model 

itself. For the CCOS modeling study, the CALMET v3.0 model code was used with 

modifications. Earth Tech (2000) describes CALMET v5.x and contains a number of 

improvements over version v3.0. However, these improvements were not sufficient to 

supercede CALMET v3.0 when considering the modifications to the code that had 

already been made (however, incorporating the modifications into CALMET v5.x would 

be straightforward). The most significant modification was to allow a CALMET output 

file to be used as an initial-guess field. This, and other modifications to CALMET v3.0, 

are described in following sections. 

The second piece of software used is called 'mm5fmt'. This program reads the output 

file from the MM5 v3.x prognostic meteorological model and performs two functions. 

The first function is to extract meteorological parameters at selected spatial intervals 

and format them for input into CALMET as over-water observations, surface 

observations, and upper-air meteorological profiles. The second function is to reformat 

the MM5 model output into a CALMET output format.

The other two pieces of software required are utility programs to allow the list of virtual 

meteorological observations from MM5 and their respective site identifications to be 

merged with those actual observations and site locations. 
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D.5.3.1 Software 

D.5.3.1.1 CALMET v3.0 and Code Modifications for CCOS 

To use the CALMET output meteorological fields for CCOS air quality modeling, a 

number of modifications to the CALMET code were made. The air temperature fields 

are calculated within CALMET using objective analysis. However, the CCOS modeling 

domain includes complex topography with large changes in terrain elevations. Since 

most of the monitoring sites recording air temperatures within the domain were at lower 

elevations, the air temperatures at higher elevations would be over-estimated using 

objective analysis. To correct for this over estimation of temperatures, the CALMET 

code was modified so that air temperatures are adjusted for differences in terrain 

elevation prior to averaging. The vertical air temperature gradient was set to 

-0.0049 °C/m (note: the vertical temperature gradient was originally set to -0.0098 °C/m 

for the July/August, 2000 episode, but this was latter considered too extreme). 

For some areas of the CCOS modeling domain, the network of monitoring sites for 

surface meteorology was fairly dense. However, in its default mode, CALMET uses 

these surface-based observations only in the vertical layer closest to the ground with a 

depth of 20 m. Above 20 m, meteorological parameters are averaged from the much 

less dense upper-air profile measurements. The CALMET model has a provision to 

extrapolate surface measurements vertically, but if this option is selected, the surface 

observations are extrapolated to the top of the modeling domain. For CCOS the 

domain top was set at 5000 magl and considered too high to be represented by surfacebased observations. The CALMET code was modified to allow surface wind 

observations to be extrapolated for a set number of vertical layers. For the CCOS 

modeling study, an exponential increase in wind speed with height was assumed to a 

height of 200 magl. 

The upper-air meteorological profiles input into CALMET must extend from the surface 

to the top of the modeling domain. For the CCOS model domain, the top was set to 

5000 magl. However, the radar wind profilers used during the field study rarely 

recorded winds and temperatures above 2500 magl. To meet the CALMET input 

requirements, these profiles were extended to above 5000 magl, with the resulting 

potential for inaccuracies above the highest measurements. To partially compensate 

for these potential inaccuracies, a vertical profile of weighting factors was assigned and 

used to weight the objective analysis wind field with respect to the initial guess wind 

field (see Table D-7 – in CALMET, this weighting factor normally has a constant value 

for all levels). In the modified CALMET, the relative weight of the objective analysis field 

was gradually decreased with height until the 16th layer (above 4000 magl) where the 

objective analysis was weighted less than 10% relative to the initial guess field. 
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Table D-7 

Vertical profile of weighting factors used to weight 

the objective analysis wind components relative to 

the initial guess field in CALMET

Layer 

Layer Top 

(magl) 

Weighting 

Factor 

 1 

 2 

 3 

 4

 5 

 6 

 7 

 8

 9 

10 

11 

12

13 

14 

15 

16 

 20 

 60 

 100 

 200

 300 

 400 

 600 

 800

1000 

1500 

2000 

2500

3000 

3500 

4000 

5000 

1.0 

1.0 

1.0 

1.0

1.0 

1.0 

0.91 

0.82

0.73 

0.64 

0.55 

0.45

0.36 

0.27 

0.18 

0.09 

D.5.3.1.2 The Program ‘mm5fmt’ 

The program 'mm5fmt' was written to reformat MM5 v3.x model output as a CALMET 

model output. As a secondary function, the program outputs MM5-generated 

meteorological parameters at selected spatial intervals as 'virtual observations' for input 

into the CALMET model. The CALMET output file format contains 3-dimensional arrays 

of meteorological parameter fields, 2-dimensional arrays of dynamic variables, and 1-

dimensional arrays of meteorological parameters specific to surface-based monitoring 

sites. 

The 3-dimensional parameter fields within a CALMET output file are hourly horizontal 

wind speed components, vertical wind velocity, and air temperatures. These wind and 

temperature fields are mapped from the MM5 output file into the fixed-height vertical 

domain defined for CALMET (see Table D-10). The hydrostatic assumption was used 

to map the vertical layers in MM5, which is based on 'sigma' coordinates, to the fixedheight domain of CALMET. 

The 2-dimensional parameter fields in the CALMET output file define the modeling 

domain, and hourly dynamic variables. Terrain heights and land use are taken directly 

from the MM5 output fields (the 24 MM5 land use categories are mapped into the 11 

expected by CALMET). However, many of the hourly dynamic meteorology variables 

must be calculated. The PBL heights and aerodynamic roughness can be taken directly 

from MM5 output fields. However, the Monin-Obukov length, friction velocity, and scale 
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convective velocity must be calculated. The energy fluxes necessary to calculate the 

Monin-Obukov length explicitly are available in the MM5 output fields; however, it was 

found that the sensible heat flux was not always consistent with the vertical temperature 

gradient near the surface. Therefore, the Monin-Obukov length is approximated from 

the gradient Richardson number, calculated using the 2 vertical layers closest to the 

surface. 

The CALMET output file format also includes hourly air temperature, air density, solar 

radiation, and relative humidity at each of a number of surface monitoring sites. To 

satisfy the CALMET requirement for data at monitoring sites, arbitrary site locations 

were specified and extracted from MM5 (note: even though they are created in the 

same manner, this list of monitoring sites is distinctly different from the 'virtual sites' 

created in the following section). The parameter values for these arbitrary sites were 

taken from the appropriate grid cells in the MM5 output fields. 

The second function of the program 'mm5fmt' is to generate files containing 

observations for 'virtual monitoring sites' required in CALMET files. The 3 types of 

CALMET input files that require observational data are for surface monitoring sites, 

over-water surface monitoring sites, and upper-air meteorology profiles. A fourth file is 

also required to identify and locate the 'virtual' sites. 

The locations of the 'virtual monitoring sites' are selected at a user-specified spatial 

interval. For the CCOS modeling domain, the interval was 40 grid cells, resulting in 25 

individual sites within the domain (Figure D.3); for simplicity, the surface and upper-air 

monitoring sites are identical. However, a separate distinction is made for surface sites 

located over water (based on land use). For the CCOS modeling domain, there were 7 

sites over water. To be consistent with CALMET input requirements, the over-water 

and upper-air profiles are output as individual files, one for each site, in the appropriate 

formats required for input into CALMET. The surface meteorology parameters were 

output in a single file, again in the required CALMET input format. The site list and 

location file is output in a format consistent with the CALMET input control file. 

D.5.3.1.3 Utility Programs 'cm_sfmt' and 'cm_contr' 

The utility programs 'cm_sfmt' and 'cm_contr' allow the CALMET input files generated 

from MM5 using 'mm5fmt' to be merged with CALMET input files containing actual 

observations. The program 'cm_sfmt' reads 2 files, both of which contain hourly surface 

meteorology observations formatted for CALMET input, and generates a CALMET input 

file containing the merged observations from both files. The program 'cm_contr' reads 

the site list file generated by 'mm5fmt' and a CALMET control file. The output of 

'cm_cntr' is a new CALMET control file in which the surface and upper-air sites lists 

from the two input files have been merged. 
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Figure D.3 

Locations of virtual monitoring sites defined for the CCOS modeling 

domain. 

A BC D E

FGH I J

K LM NO

P Q R ST

U VW X Y

D.5.3.2 Generating the CALMET/MM5 Hybrid Meteorology Fields

The generation of the CALMET/MM5 hybrid meteorological fields for the CCOS 

modeling domain, once the software described above is in place, was no more difficult 

than running CALMET by itself. The most difficult task was preparing the CALMET 

input files using available surface and upper-air meteorological observations (for file 

requirements and formats, see Earth Tech, 2000). Once these files were prepared, the 

files generated from MM5 using 'mm5fmt' were merged and CALMET was run (note that 

if no actual observations are available, the data files generated by 'mm5fmt' are 

sufficient to run CALMET). 

The program 'cm_cntr' merges the site list generated by 'mm5fmt' with the list in the 

CALMET input control file. However, in the control file, the assigned names of the overwater site files and the upper-air site files must be edited by the user. The CALMET 

model used for the CCOS domain was modified to accept a file formatted as CALMET 

output as the input initial guess field. For the CCOS domain, the file output in CALMET 

format by 'mm5fmt' containing the MM5 wind field was used as this initial guess field. 
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For the objective analysis and the initial guess fields to be averaged by CALMET, the 

keyword in the CALMET input file 'IPROG=' must be set to '2' (Input Group 5). The 

CALMET model averages only the wind components for the 2 meteorological fields. All 

other parameter fields within the 'initial guess' input file are ignored. 

Because the program 'mm5fmt' generates 'virtual' sites at regular intervals throughout 

the modeling domain, there will be some overlap in coverage between the network of 

actual meteorological monitoring sites and the 'virtual sites'. However, because the 

density of the 'virtual sites' is relatively low (at least compared to sites within the Central 

Valley) the impact of this overlap on the resultant wind fields was expected to be 

minimal. 

D.5.3.3 Application of the CALMET/MM5 Hybrid to the July/August, 2000 

CCOS Episode 

For the July/August, 2000 CCOS episode, meteorological fields required by the CAMx 

air quality model were developed using the CALMET/MM5 hybrid model. A brief 

summary of the CALMET model inputs is described within this section. 

For the period July 29-August 2, 2000, surface meteorological variables were available 

at 109 sites, and 21 upper-air meteorological profiles were available. However, the 

monitoring locations were not distributed uniformly across the modeling domain. Most 

of the monitoring sites were located within the Central Valley of California, and relatively 

few were located east and north of the Valley. Also, many of the monitoring sites were 

clustered in urban areas where adjacent wind speed, direction, and temperature 

measurements often showed significant differences. 

To prepare the surface meteorological measurements for input into CALMET, a subset 

of the monitoring network was selected. Where wind measurements were clustered, 

the number of monitoring sites was reduced. Monitoring sites for which measured wind 

speeds or directions appeared to be influenced by small-scale, local topography were 

also removed. Ultimately, 86 sites with surface wind measurements were used in the 

CALMET input file. Surface temperatures were also edited to minimize strong local 

temperature gradients that could not be accounted for by geography or topography. 

Interpolation barriers were defined to minimize the extrapolation of observed winds 

across mountain boundaries (Figure D.4). 

The vertical wind measurements from the 21 available monitoring sites were used for 

CALMET inputs (see Figure D.5). The top of the CALMET modeling domain was set to 

5000 magl. However, few of the vertical wind measurements extended that high. 

Where they did not, the wind speed and direction of the highest level was assigned to 

5010 magl and the highest available temperature was extended vertically assuming an 

adiabatic lapse rate. 

Because of the lack of observed meteorological monitoring sites in some regions of the 

CCOS modeling domains, and because of the uncertainties in winds higher than a few 

thousands of meters, CALMET/MM5 hybrid meteorological fields were generated using 
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the methodologies described in subsection D.5.3. The CALMET/MM5 hybrid is an 

overlay of MM5 generated wind fields with the objective analysis wind fields generated 

within CALMET. The MM5 wind fields used were a from a simulation run by NOAA 

(2003) using ETA initialization and no observational FDDA (this MM5 simulation was 

selected based on a comparison of CAMx simulation results using meteorological fields 

generated solely from MM5). 

Figure D.4 

Wind speed and direction interpolation barriers defined 

within CALMET for the July/August, 2000 CCOS episode. 

The program 'mm5fmt' was used to reformat the MM5 model output into a file with a 

CALMET format and to generate a series of 'virtual' monitoring sites. Virtual monitoring 

sites were generated at intervals of 40 grid cells, resulting in a total of 25 for the CCOS 

modeling domain (see Figure 3.2.1). The wind speed and direction, and air 

temperatures simulated by MM5 at these 25 virtual sites were added to the 86 surface 

and 21 upper-air sites from the CCOS field study with actual meteorological 

measurements. The CALMET model was run in 26 hour intervals and the resulting 

meteorological fields were reformatted for input into the CAMx air quality model. 
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Figure D.5 

The location of upper-air wind measurements in the CCOS 

modeling domain. 

D.5.3.4 Preparation of CAMx Input Meteorological Files 

The CAMx air quality model requires 5 input files for meteorological parameters. These 

files define hourly, 3-dimension horizontal wind speed components, air temperatures, 

relative humidities, vertical diffusivities, and pressure and height fields. The wind 

components and air temperatures can be mapped directly from the CALMET output 

fields. The relative humidities, vertical diffusivities, and pressure vs. height fields must 

be calculated. 

The CALMET output file includes relative humidities, but only for identified surface 

monitoring sites. To develop 3-dimensional relative-humidity fields, these surface 

values were extrapolated throughout the modeling domain. For each cell in the surface 

layer, the nearest surface site was identified and the relative humidity from that site was 

assigned. For grid cells above the surface, the relative humidity was assumed constant 

to the mixing height, and then was assumed to be one-half that value above the mixing 

height. 
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To calculate vertical diffusivity, algorithms were borrowed from 2 sources. The 

subroutine for calculating vertical diffusivity was taken from the CALGRID air quality 

model (Scire, et al., 1989). However, the vertical diffusivity equations for an unstable 

atmosphere were replaced with those of McRae et.al. (1982). These algorithms 

calculate vertical diffusivity as functions of the height of the planetary boundary layer 

(PBL – also known as mixing height). Most meteorological models (including CALMET 

and MM5) tend to overestimate PBL heights. Therefore, prior to the calculation of 

vertical diffusivity, PBL heights within the Central Valley were scaled to approximate 

mid-day values measured at Granite Bay and Parlier using the results from ozonesonde 

flights. 

The CAMx air quality model requires as input a file defining the height and pressure for 

the vertical boundaries of each grid cell. For the CCOS modeling domain, a fixed-height 

vertical layer structure was assumed (see Table D-10). However, the CALMET 

meteorological model does not output atmospheric pressures. To calculate the required 

pressures, a constant sea-level pressure of 1013 mb was assumed. The adiabatic 

lapse rate was used to extrapolate the temperature of the surface layer from the cell 

terrain height to sea level. The hydrostatic equation was then used to extrapolate the 

sea-level pressure vertically, to the surface, and then above the surface using available 

grid-cell air temperatures. 

D.6 Emissions 

One of the necessary inputs to air quality modeling is temporally and spatially resolved 

emissions estimates. Emissions are broadly categorized into major stationary or point 

sources, area sources (which include off-road mobile sources), on-road mobile sources, 

and biogenics. In the following sections, we will describe how the emissions data are 

estimated and how they were used to develop base case and future year emissions 

estimates. 

Due to the large area covered by CCOS, the development of the emission inventory has 

been a major effort. In addition to the size of the study domain, the emission inventory 

needed to support the modeling of the field study data must be much more detailed than 

the more routine summer seasonal emission inventory. The emission inventory needed 

to support the CCOS modeling is a series of day-specific, hourly, gridded emission 

inventories that cover each day of the ozone episodes captured during the field study. 

To help coordinate this effort, an Emission Inventory Coordination Group (EICG) was 

established in February 1999 to determine the process for preparing the emission 

inventories needed to support air quality modeling for CCOS. Participating in the group 

were many local air districts, several local councils of government, Caltrans, the 

California Energy Commission, U.S. EPA, and the ARB. Local air districts that 

participated included San Joaquin Valley Unified APCD, Bay Area AQMD, Sacramento 

Metropolitan AQMD, Mendocino County APCD, Northern Sierra AQMD, Yolo-Solano 
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AQMD, Placer County APCD, San Luis Obispo County APCD, and Monterey Bay 

Unified APCD. All local air districts in the CCOS region were invited to participate. 

The EICG met on a regular basis to discuss CCOS emission inventory development 

issues into 2002. As modeling inventories became available, the Air Resources Board 

established a Gridded Inventory Coordination Group (GICG) in February 2003. The 

GICG consists primarily of government agencies and their contractors that are 

responsible for the variety of data used to develop gridded emission inventories. Many 

of the participants in the EICG now participate in the GICG. The purpose of the GICG is 

to conduct quality assurance of the emissions, and to distribute and coordinate the 

development of emission inputs for SIP modeling. Minutes from the GICG meetings are 

provided in section D.9. 

D.6.1 Background 

California’s emission inventory is an estimate of the amounts and types of pollutants 

emitted from thousands of industrial facilities, millions of motor vehicles, and of 

hundreds of millions of applications of other products such as paint and consumer 

products. The development and maintenance of the inventory is a multi-agency effort 

involving the ARB, 35 local air pollution control and air quality management districts 

(districts), metropolitan planning organizations (MPOs), councils of governments 

(COGs), and the California Department of Transportation (Caltrans). The ARB staff is 

responsible for the compilation of the final, statewide emission inventory, and maintains 

this information in a complex electronic database. Each emission inventory reflects the 

best information available at the time. 

To produce regulatory, county-wide emissions estimates, the basic principle for 

estimating emissions is to multiply an estimated, per-unit emission factor by an estimate 

of typical usage or activity. For example, on-road motor vehicle emission factors are 

estimated for a specific vehicle type and model year based on dynamometer tests of a 

small sample of that vehicle type and applied to all applicable vehicles. The usage of 

those vehicles is based on an estimate of such activities as a typical driving pattern, 

number of vehicle starts, typical miles driven, and ambient temperature. It is assumed 

that all vehicles of this type in each region of the state are driven under similar 

conditions. 

Developing emission estimates for stationary sources involves the use of per unit 

emission factors and activity levels. Under ideal conditions, facility-specific emission 

factors are determined from emission tests for a particular process at a facility. More 

commonly, a generic emission factor is developed by averaging the results of emission 

tests from similar processes at several different facilities. This generic factor is then 

used to estimate emissions from similar types of processes when a facility-specific 

emission factor is not available. Activity levels from point sources are measured in such 

terms as the amount of product produced, solvent used, or fuel used. 
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As mentioned previously, ARB maintains an electronic database of emissions and other 

useful information. Annual average emissions are stored for each county, air basin and 

district. The database is called the California Emission Inventory Development and 

Reporting System (CEIDARS). Emissions are stored in CEIDARS for criteria and toxic 

pollutants. The criteria pollutants are total organic gases (TOG), carbon monoxide 

(CO), oxides of nitrogen (NOx), oxides of sulfur (SOx), and total particulate matter (PM). 

Reactive organic gases (ROG) and particulate matter 10 microns in diameter and 

smaller (PM10) are calculated from TOG and PM, respectively. Following are more 

details on how emissions are estimated for point and area sources, on-road motor 

vehicles, and biogenics. Additional information on emission inventories can be found at 

http://www.arb.ca.gov/emisinv/eib.htm. 

D.6.2 Point and Area Source Emissions 

D.6.2.1 Base Year Emissions 

The stationary source component of the emission inventory is comprised of more than 

11,000 individual facilities, called “point sources”, and over 100 categories of 

“aggregated point sources”. Aggregated point sources are many small point sources 

that are grouped together and reported as a single source category (gas stations, dry 

cleaners, and print shops are some examples). These emission estimates are based 

mostly on area source methodologies or emission models. Thus, the aggregated point 

sources include emissions data for the entire category of point sources, not each 

specific facility. Some districts include only the larger stationary sources in the 

inventory as point sources and include the smaller sources as aggregated point 

sources, whereas other districts include all stationary sources as point sources. 

The area-wide source component includes emissions data only at the aggregated level. 

Examples of the categories are emissions from consumer products, pesticide 

applications, and wind-blown dust from agricultural lands. There are several hundred 

categories of area-wide sources. The emissions for these categories, which are 

associated with human activity, are located mostly within major population centers. 

Some of the emissions in these categories come from agricultural centers and from oil 

production complexes. 

The off-road mobile sources are an estimate of the population, activity, and emissions 

estimate of the varied types of off-road equipment. The major categories of engines 

and vehicles include agricultural, construction, lawn and garden, and off-road 

recreation, and includes equipment from hedge trimmers to cranes. The OFF-ROAD 

model estimates the relative contribution of gasoline, diesel, compressed natural gas, 

and liquefied petroleum gas powered vehicles to the overall emissions inventory of the 

state. For more information , see http://www.arb.ca.gov/msei/off-road/off-road.htm. 

Local air districts estimate emissions from point sources. Estimating emissions from 

area sources is a cooperative effort between ARB and air district staffs. The emission 
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inventory for CCOS will be developed from the 1999 CEIDARS inventory for TOG, NOx, 

SOX, CO and PM. 

D.6.2.2 Forecasted Emissions 

Air pollution programs have always depended on predictive models for gaining a better 

understanding of what the emissions will be in the future—these predictions are based 

on expectations of future economic conditions, population growth, and emission 

controls. 

ARB’s model to forecast emissions is known as the California Emission Forecasting 

System (CEFS). A major feature of the model is its ability to track the effects of 

emission control rules and growth activity for stationary and other mobile sources by 

linking these factors directly to the emission categories. A key component of the new 

model is the Rule Tracking Subsystem (RTS), which was developed to link emission 

control rules to the emission process level (identified by Source Classification Code 

(SCC) and Standard Industrial Classification (SIC) or Emission Inventory Code (EIC)—

which comprises more than 30,000 possible emission process/industry categories 

statewide). 

Reports of forecasted emissions are available on-line. The reports can be generated for 

a variety of years, pollutants, source types, seasons and geographical areas. The 

forecasted reports for use in SIP modeling within the Central California Ozone Study 

(CCOS) domain can be accessed at: 

http://www.arb.ca.gov/app/emsinv/ccos/tableofcontent.php

Please note that the reports provided under this link do not take into account dayspecific emission adjustments, which are described in section D.6.2.3. 

D.6.2.2.1 Growth Factors 

Growth factors are derived from county-specific economic activity profiles, population 

forecasts, and other socio/demographic activity. These data are obtained from a 

number of sources: data from districts and local COGs are used when they are 

available; economic activity studies contracted by the ARB; and demographic data (e.g. 

population survey data from DOF, and VMT data from CALTRANS). Growth profiles 

are typically associated with the type of industry and secondarily to the type of emission 

process. For point sources, economic output profiles by industrial sector are linked to 

the emission sources via SIC. For area-wide and aggregated point sources, other 

growth parameters such as population, dwelling units and fuel usage may be used. 
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D.6.2.2.2 Control Factors 

Control factors are derived from adopted State and Federal regulations and local district 

rules that impose emission reductions or a technological change on a particular 

emission process. These data are provided by the agencies responsible for overseeing 

the regulatory action for the particular emission categories affected. For example, the 

ARB staff develops the control factors for sectors regulated by the ARB, such as 

consumer products and clean fuels; the districts develop control factors for locally 

enforceable stationary source regulations that affect emissions from such equipment as 

IC engines or power plant boilers; and the Department of Pesticide Regulation (DPR) 

supplies control data for pesticides. In general, control factors account for three 

variables: Control Efficiency which estimates the technological efficiency of the 

abatement strategy; Rule Effectiveness which estimates the “real-world” application of 

the strategy taking into account factors such as operational variations and upsets; and 

Rule Penetration which estimates the degree a control strategy will penetrate a certain 

regulated sector taking into account such things as equipment exemptions. Control 

factors are closely linked to the type of emission process and secondarily to the type of 

industry. Control levels are assigned to emission categories, which are targeted by the 

rules via emission inventory codes (SCC/SIC, EIC etc.) that are used in CEIDARS. 

D.6.2.3 Day-specific Emissions 

As part of CCOS, the Emission Inventory Coordination Group (EICG), made up of ARB 

and district staff to guide inventory development for CCOS, requested that districts 

within the CCOS domain collect day-specific data from facilities and other sources 

within their jurisdiction. The EICG requested hourly/daily emission information from: 

1) large point sources (> 100 tons per year of NOx or ROG) 

2) sources with large variability in emissions (e.g. power plants) 

3) unusual events (e.g. source shut down, variances, breakdowns) 

4) agricultural or prescribed burning 

5) wildfires 

D.6.2.3.1 Point Sources 

Eleven air districts provided daily or hourly emission estimates for 67 facilities. The 

districts which provided data were Amador County APCD, Bay Area AQMD, Colusa 

County APCD, Monterey Bay Unified APCD, Placer County APCD, Sacramento Metro 

AQMD, San Joaquin Valley Unified APCD, San Luis Obispo County APCD, Shasta 

County AQMD, Tehama County APCD, and Yolo/Solano AQMD. Day-specific 

emissions replaced emissions estimated from CEFS. Additionally, the Bay Area AQMD 

provided emission estimates from unusual events, such as breakdowns. These 
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emissions were added to the modeling inventories on the day when the unusual event 

occurred. 

D.6.2.3.2 Area Sources 

Three districts provided day-specific data for agricultural burning. In most districts, no 

agricultural burning occurred because no-burn days were declared during the episode. 

D.6.2.3.3 Wildfires 

Emissions were estimated for known wildfires that occurred during the CCOS episodes. 

Two large wildfires occurred during the July/August 2000 episode: the Manter fire in 

Tulare County and the Plaskett fire in Monterey County. UC Berkeley’s Center for the 

Assessment and Monitoring of Forest and Environmental Resources (CAMFER) 

laboratory estimated the emissions for these two fires, in consultation with the ARB. To 

develop emission estimates, CAMFER implemented the fire emissions module of the 

USDA Forest Service First Order Fire Effects Model (FOFEM, Reinhardt et al. 1997) 

within a Geographic Information System (GIS). FOFEM is a standard fire effects model 

used by federal and state land management agencies. The CAMFER model, called the 

Emissions Estimation System (EES), was initially devised to develop annual ARB fire 

emission inventories. CAMFER was tasked to extend the EES to enable the model to 

estimate temporally resolved emissions for individual fires, for an expanded suite of 

pollutants. 

The CAMFER EES runs within ArcView software and utilizes emission algorithms, 

emission factors, combustion efficiencies, fuel loadings, and other parameters from 

FOFEM. In the EES, GIS-based spatial data layers (polygon shapefiles), representing 

burned areas, are overlayed onto a GIS vegetation data layer in which vegetation 

community types are coupled with corresponding FOFEM biomass fuel profiles. For 

each fuel component (there are 10 fuel components representing foliage, litter, and 

stem diameter classes) in each vegetation type, the EES determines pre-burn fuel 

loadings (tons per acre), fuel mass consumed by the fire, combustion efficiency, and 

emissions released. Burning occurs in two distinct phases: flaming and smoldering. 

The temporal evolution of emissions from a burning area is therefore a function of the 

phase in which a fire is burning, and the time elapsed since ignition. The FOFEM and 

CAMFER EES models generate daily emissions from both phases. Emissions 

generated by the EES from flaming and smoldering phases are combined in the final 

outputs. 

These emissions were then utilized to develop a plume profile, using the techniques 

outlined in a recent report of the Fire Emissions Joint Forum (FEJF) of the Western 

Regional Air Partnership (WRAP) (Air Sciences, 2002). The hourly emissions were 

assigned based on the following standard profile (all values are taken directly from the 

FEJF report): 
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Hour 1 2 3 4 5 6 7 8 9 10 11 12 

% 0.53 0.53 0.53 0.53 0.53 0.53 0.53 0.53 0.53 2.0 4.0 7.0 

Hour 13 14 15 16 17 18 19 20 21 22 23 24 

% 10.0 13.0 16.0 17.0 12.0 7.0 4.0 0.53 0.53 0.53 0.53 0.53 

For each hour of the episode, the wildfire virtual acreage was calculated using the fuel 

loading factors provided by ARB, and the virtual acreage sizes were used to determine 

the size classes of the fires. The size classes were then used to determine the 

parameters required to calculate the plume characteristics: 

Class 1 2 3 4 5 

Size (virtual 

acres) 

0-10 >=10-100 >=100-1000 >=1000-5000 >=5000 

BE (size) 0.4 0.6 0.75 0.85 0.9 

Ptop Max (m) 160 2400 6400 7200 8000 

Pbot Min (m) 0 300 800 1600 1600 

These values, along with the buoyancy efficiency as a function of the hour of the day, 

were used to calculate the bottom of the plume, the top of the plume, and the proportion 

of the emissions fumigated into the first layer, for each grid cell in the fire area, and for 

each hour of the episode. 

To model the vertical distribution of the plumes, a series of stack parameters were 

constructed for each grid cell, and each hour of the episode. The portion of the 

emissions attributed to the plume, rather than the fumigation layer, was distributed to 

each of the stack release points, with the fumigation portion going directly to the first 

layer (zero plume rise). The stack points were inserted into the emissions model at 25, 

75, and 100 meters, and then at every 100 meters up to the top of the plume. 

Emissions were evenly allocated to each release point, beginning in the layer 

corresponding to the bottom of the plume, and continuing to the top of the plume. 

For all other fires, emissions were calculated based on the number of acres of three 

vegetation types: chaparral, grass, and timber. The U.S. Forest Service provided fuel 

loading and emission factors. The number of acres, vegetation type, fire duration, and 

location information were taken from California Department of Forestry (CDF) fire 

incident reports and newspaper articles. The vertical distributions of the plumes were 

calculated using the FEJF methodology described above. 

D.6.2.4 Temporally and Spatially Resolved Emissions 

In addition to forecasting emissions, CEFS can create temporally resolved inventories 

for modeling purposes, for the base year and future years. The annual average 

emissions are adjusted to account for monthly and weekly variations. CEFS will 

generate an inventory for point and area sources (including off-road mobile sources) for 

a weekday and weekend day in the year and months needed for the CCOS episodes 
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(e.g. July 2000 and August 2000). Emissions will be estimated for each county, air 

basin and district combination. In addition, information on how the daily emissions are 

to be distributed to each hour of the day is carried forward to the emissions processor. 

D.6.2.5 Terminology 

There can be confusion regarding the terms “point sources” and “area sources”. 

Traditionally, these terms have had two different meanings to the developers of 

emissions inventories and the developers of modeling inventories. The following table 

summarizes the difference in the terms. In the context of this document, section 4.2 

(point and area source emissions) uses the emission inventory terms. In the remainder 

of the document, modeling terms are used. In modeling terminology, “point sources” 

refers to emission sources that exit from a stack and have a potential plume rise. “Area 

sources” refers collectively to area-wide sources, stationary-aggregated sources, and 

other mobile sources. 

Emission Inventory Term Examples Modeling Term 

On-Road Mobile Automobiles On-road Motor Vehicles 

Off-Road Mobile Farm Equipment, 

Construction Equipment, 

Aircraft, Trains 

Area 

Area-wide Consumer Products, 

Architectural Coatings, 

Pesticides 

Area 

Stationary - Aggregated Industrial Fuel Use Area 

Stationary – Point Facilities Stacks at Individual 

Facilities 

Point 

Biogenic Trees Biogenic 

D.6.3 Surface T and RH Objective Analysis 

The calculation of gridded emissions for some categories of the emissions inventory is 

dependent on gridded air temperature, relative humidity, and solar radiation fields. 

Biogenic emissions are sensitive to air temperatures and solar radiation, and emissions 

from on-road mobile sources are sensitive to air temperature and relative humidity. 

Gridded temperature, humidity, and radiation fields are readily available from prognostic 

meteorological models such as MM5, used to prepare meteorological inputs for the air 

quality model. However, analysis of the MM5 outputs prepared for the July/August, 

2000 episode revealed poor agreement between simulated humidity and temperature 

fields and the available measurements. 

As an alternative to the data fields generated using the prognostic meteorological 

model, air temperature and humidity fields for calculation of the emission inventory were 

prepared by objective analysis. In the objective analysis, hourly temperatures for each 
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grid cell within the study domain were calculated using a distance-weighted average of 

the nearest three temperature measurements. Because few temperature 

measurements were available at higher terrain elevations, temperatures were adjusted 

using the adiabatic lapse rate (-0.0098 C/m) multiplied by elevation differences prior to 

averaging. 

Relative humidity measurements show a wide range of variability. Within the CCOS 

study domain, it was not unusual to find differences in relative humidity of 40% among 

sites within a 25 km radius. To reduce large horizontal variations in the relative humidity 

fields developed for the emission inventory calculations, relative humidity fields were 

calculated assuming a daily constant absolute humidity for each grid cell, based on an 

assumed daily maximum relative humidity of 80%. 

The solar radiation fields needed for emission inventory calculations were taken directly 

from the MM5 simulation. 

D.6.4 On-Road Mobile Source Emissions 

D.6.4.1 Introduction 

EMFAC is the ARB approved on-road motor vehicle emission inventory model. The 

current version is EMFAC2002 v2.2 [1]. This model provides emission estimates for 13 

classes of vehicles for exhaust, evaporation, and PM emissions from tire wear and 

brake wear. EMFAC also produces estimates of fuel consumption, vehicle mile traveled 

(VMT), and the number of vehicles in use. EMFAC does not output a gridded emission 

file. However, EMFAC will also produce a file of emission rates that can be used with 

the Direct Travel Impact Model (DTIM) or other external on-road motor vehicle emission 

gridding program. These same emission rates are part of the information used by 

EMFAC to produce emission estimates for California counties or air basins. 

It is important to recognize that EMFAC (and its associated activity), and not DTIM, is 

used to calculate county-specific emissions. DTIM output, using the Integrated 

Transportation Network (ITN) activity as inputs, were used to create hourly emission 

ratios for each grid-cell in a county. These ratios were used to distribute countyspecific, daily EMFAC emissions to each hour and grid cell. A horizontal grid resolution 

of 4 x 4 kilometers was used. 

DTIM4 [2] is the latest version of DTIM, and is used to estimate gridded on-road motor 

vehicle emissions. In addition to the EMFAC emission rate file, DTIM4 uses digitized 

roadway segments (links) and traffic analysis zone activity centroids to allocate 

emissions for travel and trip ends. DTIM4 gridded emission files have fewer categories 

than EMFAC outputs. Each DTIM4 output category were used to spatially allocate 

emissions for several EMFAC emission categories. There are also several categories 

of emissions that EMFAC produces that are not estimated by DTIM4. 

DTIM4 is used to estimate both the spatial and temporal distribution of all on-road motor 

vehicle emissions. The DTIM4 results are used as surrogates to distribute the EMFAC 
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emissions for each category. Below we describe the procedures that were used with 

EMFAC and DTIM4 to produce day-specific gridded on-road motor vehicle emission 

estimates. The procedures described here are carried out separately for each of the 53 

counties in the CCOS emission modeling region. 

D.6.4.2 EMFAC Emission Categories 

EMFAC produces emission estimates for the following 13 vehicle classes: 

1. LDA Light Duty Autos 

2. LDT1 Light Duty Trucks < 3,750 pounds GVW 

3. LDT2 Light Duty Trucks > 3,750 - 5,750 

4. MDV Medium Duty Vehicles > 5,750 – 8,500 

5. LHD1 Light Heavy Duty Vehicles > 8,500 – 10,000 

6. LHD2 Light Heavy Duty Vehicles > 10,000 – 14,000 

7. MHD Medium Heavy Duty Vehicles > 14,000 – 33,000 

8. HHD Heavy Heavy Duty Vehicles > 33,000 

9. LHV Line Haul Vehicles 

10. SBUS School Bus 

11. UBUS Urban Bus 

12. MH Motorhomes 

13. MCY Motorcycles 

Additionally, there are up to 3 technology groups within each vehicle type: 

1. Catalyst 

2. Non-catalyst 

3. Diesel 

For each of the combinations of vehicle type and technology there can be many 

emission categories: 

1. Start Exhaust 

2. Running Exhaust 

3. Idle Exhaust 

4. Hot Soak 

5. Running Evaporatives 

6. Resting Evaporatives 

7. Partial Day Resting Evaporatives 

8. Multi-Day Resting Evaporatives 

9. Diurnal Evaporatives 

10. Partial Day Diurnal Evaporatives 

11. Multi-Day Diurnal Evaporatives 

12. Break Wear PM 

13. Tire Wear PM 
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A DTIM4 preprocessor calculates fleet average emission factors for each EMFAC 

technology type for each emission category. The vehicle type distribution used to 

calculate fleet emission factors is an input, so it can be varied as needed. 

D.6.4.3 DTIM4 Emission Categories 

During DTIM4 operation, all emissions are collapsed into a total of 20 emission 

categories that depend only on the technology and whether the vehicle is catalyst, noncatalyst or diesel: 

SCC Description

1. Non TOG Exhaust Emissions 

2. Catalyst Start Exhaust 

3. Catalyst Running Exhaust 

4. Non-catalyst Start Exhaust 

5. Non-catalyst Running Exhaust 

6. Hot Soak 

7 Diurnal Evaporatives 

8. Diesel Exhaust 

9. Running Evaporatives 

10. Resting Evaporatives 

11. Multi-Day Resting 

12. Multi-Day Diurnal 

13. PM Tire Wear 

14. PM Brake Wear 

15. Catalyst Buses 

16. Non-catalyst bus 

17. Diesel Bus 

18. Catalyst Idle 

19. Non-catalyst Idle 

20. Diesel Idle 
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D.6.4.4 Creating the Emission Rate File 

EMFAC will create an emission rate file for any desired combination of vehicle speeds, 

ambient temperatures, and relative humidities. However, DTIM places restrictions on 

the total array size. The sets of values we use to build the array are: 

Speed: 5, 10, 15, 20, 25, 30, 35, 40, 45, 50, 55, 60, 65 

Temp: 30, 45, 60, 70, 75, 80, 85, 90, 100, 110 

RH: 0, 30, 50, 70, 80, 90, 100 

D.6.4.5 Day-specific EMFAC Inventories 

EMFAC is used to produce emission estimates for each day of each episode, by county. 

County average hourly temperatures, weighted by gridded VMT, are input to EMFAC to 

produce a ‘BURDEN’ inventory in a comma separated (.bcd) format. Both DTIM 

exhaust and evaporative emissions are scaled by category to the EMFAC emissions 

estimates for each county/air basin area. EMFAC bus and idle emission categories are 

not estimated by DTIM. These categories are added to the gridded emission files. 

D.6.4.6 CCOS Emission Gridding 

The method to estimate on-road mobile emissions at the grid cell level is described 

briefly in the following five steps: 

Step 1. Gridded, hourly temperature (T) and relative humidity (RH) fields for each 

episode day are prepared for input to DTIM. The T and RH fields are derived either 

from meteorological model predictions, observations, or some hybrid combination of 

model predictions and observations. 

Step 2. EMFAC is run to prepare on-road mobile source emissions factors by speed, 

temperatures, and relative humidities for each county. 

Step 3. DTIM4 is run using data from the Integrated Transportation Network (ITN) and 

EMFAC to estimate gridded, hourly on-road mobile source emission estimates by day 

for DTIM categories. 

Step 4. EMFAC is run again using episode-specific T and RH data to provide 

countywide on-road mobile source emission estimates by day for EMFAC categories. 

The episode-specific meteorological inputs for EMFAC are generated via averaging 

(VMT-weighted) the gridded, hourly meteorology from Step1 by county and hour. 
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Step 5. Two sub-steps are taken: 

Weekend adjustments. EMFAC currently does not make weekend day 

estimates, so EMFAC daily emissions are scaled to represent weekend 

estimates based upon available data. The ITN network has activity estimates for 

a weekend day. In order to approximate an EMFAC weekend day inventory we 

scaled each county’s EMFAC pollutants, except NOx, by the ratio of DTIM VMT 

for a weekend day divided by the DTIM VMT for a midweek day. Since heavyduty diesel VMT is drastically reduced on weekends and their effect is largely on 

NOx emissions, we reduced the NOx by a factor of 0.536, which represents the 

average reduction in NOx for a South Coast Air Basin weekend day. This NOx 

reduction was derived from CalTrans Weigh-in-Motion traffic counts that can 

differentiate between vehicle types. This NOx factor could be improved by using 

traffic count data specific to Northern California counties. Monday and Friday 

EMFAC emissions were also factored by the DTIM VMT for Monday vs. midweek 

or Friday vs. midweek, for all pollutants. 

Spatial/Temporal Distribution. EMFAC daily, countywide emissions (adjusted for 

weekend days, if needed), are disaggregated by category into grid-cells for each 

hour of the day using the DTIM output (Step 3) as a spatial and temporal 

surrogate. The disaggregation follows the equation: 

Ep,ij,hr,cat = EFp,cat * DTIMp,ij,hr,cat / DTIMp,daily,cat,cnty

where: 

E = grid cell emissions 

EF = EMFAC emissions 

DTIM = DTIM emissions 

P = pollutant 

Ij = grid cell 

hr = hourly emissions 

cat = Emission Category 

daily = daily emissions 

cnty = county 

The 5 steps above are used to generate sets of day-specific, gridded on-road 

emissions. These emissions are our best estimates at the present time, however future 

work in two areas will improve the estimates. The most important may be in the 

allocation of heavy-duty truck emissions. At present, the only heavy-duty transportation 

modeling is done for Southern California counties. Also, weekend emissions should be 

considered an approximation since there are no transportation models to describe 

weekend traffic. Even though we feel that the weekend inventories are approximate at 

the hour and county level, the lack of weekend transportation models result in the same 

hourly spatial distribution for each county for both weekday and weekend days. As a 
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result, there is considerable uncertainty in the spatial distribution within each county for 

weekends. Weekend on-road inventories should be used with caution. 

Fleet Emission Factors

An important input to DTIM emissions is the vehicle type weighting for emission rate 

compositing done in IRS4. We use the vehicle type VMT for each county/air basin 

output from EMFAC. If we run LM and HDV separately the VMT for LM is the sum of 

LDA, LDT1, LDT2, MDV, MCY and MH. The HDV VMT is the sum of LHDV1, LHDV2, 

MHD and HHD. 

Besides the composite emission rate file from EMFAC/CNVIRS4/IRS4, DTIM4 needs 

link and trip end activity files. All activity has been resolved to one-hour periods for 

each county by Jim Wilkinson of Alpine Geophysics under contract to the ARB. This 

was done for midweek days, Mondays, Fridays, and an average weekend day. The 

estimated activity for Mondays, Fridays, and weekend days are different than the 

midweek activity. The differences are due to the differences seen in traffic counts. 

When we processed Mondays, Fridays, and weekend days, we scaled the daily 

emissions according to the ITN county VMT to EMFAC VMT ratio. 

D.6.4.7 Evaporative Emissions 

DTIM4 and EMFAC use different methods to estimate evaporative emissions. 

However, as mentioned previously, we use the DTIM4 evaporative emissions as spatial 

and temporal “surrogates” to resolve EMFAC emission estimates. During processing, 

we drop the DTIM evaporative categories 11 and 12 (because those emissions are 

included in EMFAC’s estimates for diurnal and resting emissions) and put all EMFAC 

resting emissions in category 10, and all diurnal emissions in category 7. 

D.6.4.8 Exhaust Emissions 

The exhaust emissions from EMFAC are also resolved spatially and temporally by 

DTIM4 emission estimates. Since transportation models do not estimate VMT for buses 

or excess idling categories, these are added to DTIM4 emissions. The exhaust CO, 

NOx, SOx, and PM emissions that DTIM4 allocates to category 1 are reassigned to 

catalyst starts, non-catalyst starts, catalyst stabilized, non-catalyst stabilized, and diesel 

exhaust categories according to the appropriate day-specific EMFAC inventory. 

D.6.5 Biogenic Emissions 

Development of effective ozone control strategies in California requires accurate 

emission inventories, including biogenic volatile organic compounds (BVOCs) such as 

isoprene and monoterpenes. Due to the heterogeneity of vegetation landcover, species 

composition, and leafmass distribution in California, quantifying BVOC emissions in this 

domain requires an emission inventory model with region-specific input databases and 
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a high degree of spatial and temporal resolution. In response to this need, the 

California Air Resources Board (CARB) has developed a GIS-based model for 

estimating BVOC emissions, called BEIGIS, which uses California-specific input 

databases with a minimum spatial resolution of 1 square km and an hourly temporal 

resolution. 

The BEIGIS isoprene emission algorithm (Guenther et al. 1991, 1993) is of the form 

I = IS × CL × CT

where I is the isoprene emission rate (grams per gram dry leafmass per hour) at 

temperature T and photosynthetically active radiation flux PAR. IS is a base emission 

rate (grams per gram dry leafmass per hour) at a standard temperature of 30 °C and 

PAR flux of 1000 μmol m-2s-1. CL and CT are environmental adjustment functions for 

PAR and temperature, respectively. The monoterpene emission algorithm adjusts a 

base monoterpene emission rate by a temperature function (Guenther et al. 1993). 

Methylbutenol (MBO) emissions are modeled with an algorithm developed by Harley et 

al. (1998) similar to that for isoprene. Dry leaf mass/leaf area ratios, and base emission 

rates for isoprene, monoterpenes, and MBO, are plant species-specific and assembled 

from the scientific literature. Modeled BVOC emissions for a given spatial domain 

therefore represent the contribution by various plant species (through their leaf mass 

and emission rates) to the total BVOC emissions. 

The main inputs to BEIGIS are land use and vegetation landcover maps, gridded leaf 

area indices (LAI) derived from AVHRR satellite data (Nikolov 1999), leaf area/dry leaf 

mass factors, base emission rates, and gridded hourly ambient temperature and light 

intensity data (from a meteorological model). For urban areas, land use/vegetation 

landcover databases were developed from regional planning agency data and botanical 

surveys (Horie et al. 1990; Nowak 1991; Sidawi and Horie 1992; Benjamin et al. 1996, 

1997; McPherson et al. 1998). Natural areas are represented using the GAP vegetation 

database (also satellite-derived and air photo interpreted) developed by the U.S.G.S. 

Gap Analysis Program (Davis et al. 1995). Agricultural areas are represented using 

crop landcover databases developed by the California Department of Water Resources 

(http://www.waterplan.water.ca.gov). Ground surveys have been funded by ARB to 

validate the vegetation landcover and LAI input databases used in BEIGIS (Winer et al. 

1998; Karlik and McKay 1999; Winer and Karlik 2001, Karlik 2002). Validation using 

flux measurements in the field is on going. 

Using BEIGIS, the ARB developed develop hourly-resolved emissions of isoprene, 

monoterpenes, and methyl butanol (MBO), gridded at a 1-km resolution. Two additions 

are then made to the biogenic emissions estimate for input to air quality models. 

First, biogenic OVOCs (other VOCs) are added. Biogenic OVOCs comprise around 

twenty percent of some biogenic inventories and are known to affect air quality 

modeling predictions (e.g. Hanna et al., 2002). Guenther et al. (1994) estimate that the 

OVOCs comprise 8-73% of total BVOCs. OVOCs are estimated by ARB as an added 

fraction of 30%, scaled to the total isoprene, monoterpene, and MBO emissions. 
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Second, biogenic NO emissions are added. Biogenic NO emissions were estimated 

using a soil NO algorithm found in BEIS-3. However, due to the large uncertainty 

associated with these emissions, they were not used in the air quality modeling. 

For a more detailed description of the estimation of biogenic emissions, see section 

D.10. 

D.6.6 Emissions Processing 

ARB used an emissions processor, such as the EMS-95 emissions modeling system, to 

develop spatially and temporally resolved emissions for the point and area sources. 

ARB will chemically speciate the VOC component of the point, area, biogenics and onroad mobile sources. ARB will then reformat the emissions estimates for input to air 

quality models. 

Other data are necessary to prepare emissions estimates for input to air quality models. 

These data include the following: 

• Spatial surrogates 

• Assignment of spatial surrogate to area source category 

• Organic gas speciation profiles 

• Assignment of organic gas speciation profile to source category 

The spatial surrogates are used to spatially allocate countywide area source emissions 

to individual grid cells. In this context, “area source emissions” refers to all source 

categories that are not point sources, biogenics or on-road motor vehicles. Each area 

source category is assigned a spatial surrogate. 

The organic gas speciation profiles are used to separate the TOG emissions into the 

individual organic gas components that are modeled within the chemistry processes of 

the air quality model. Organic gas speciation profiles exist for both the CB-IV and 

SAPRC99 chemical mechanisms. Each source category, including area, point, 

biogenics, or on-road motor vehicles is assigned an organic gas speciation profile. 

D.6.7 Modeling Files 

The development of the inventory for SIP modeling has been a process that has 

spanned many years and much effort by many people. The first complete set of 

modeling files that included all source types was available in March 2003. Since then, 

there have been many revisions of the modeling files to correct errors or include 

updated data. Emissions summaries from these files were prepared to aid ARB and 

district staff to QA the information. These modeling files can be found on the ftp site 

provided by Alpine Geophysics. 

A file naming convention was established to track the changes made to each inventory. 

The files were named according to the following formula: 
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CCAQS_Episode_Type_Version_Revision_Chemistry_Model_MODELFILES.tar.gz 

Where: 

Episode = JULY2000 (July/August 2000) 

Type = ELEV, AR, MV, BI, FIRES (Elevated point, area, motor vehicles, biogenics, or 

fires) 

Version = “V” + date produced (e.g. V050503 for May 5, 2003) 

 (Note: When emissions data undergo a major revision, the new file is given a 

version number corresponding to the date it was produced.) 

Revision = “R” + revision number (e.g. R001 or R002) 

 (Note: Minor changes, such as small revisions to only a few sources are noted 

with a revision number; the version number remains the same.) 

Chemistry = CBIV or SAPRC 

 (Note: Several changes occurred to the version of the chemical mechanism used 

to produce the files. Following is a description of each version name and its description. 

Version Description 

CBIVV01 Initial CBIV without MEOH, ETOH 

CBIVV02 CBIV, including MEOH and ETOH 

CBIVV03 CBIVV02 with adjustments to split factors for hot soak and agricultural 

pesticides 

SAPRCV1 ARB SAPRC version S01 

SAPRCV2 ARB SAPRC version S02 

SAPRCV3 SAPRC with adjusted pollutant list, MTBE, MBUT and ETOH not 

broken out 

SAPRCV4 SAPRC with adjusted pollutant list, including MTBE, MBUT and ETOH 

SAPRCV5 SAPRCV4 with adjustments to split factors for hot soak and agricultural 

pesticides 

Model = CAMX or SAQM 

Following is a list of modeling file names that have been produced since January 2003 

and the reason for each revision. This list covers only changes to the base case 

July/August 2000 episode. It is provided as an example of the changes that have 

occurred to the emission inventories over time. Similar file changes have occurred to 

other episodes as well. This information helped ARB and district staff track the latest 

revision to the inventory for use in modeling and QA. The tables are separated by 

source type. Rather than list the entire file name, only the version and revision numbers 

are listed. Follow the naming convention described above to determine the entire name 

of the modeling file. 
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Area Sources: 

Version and Revision Number Reason for Change 

V030303_R001 CEFS version RF#861 

V050503_R001 Revised to include CEFS emissions dropped during 

original processing 

V050503_R002 Adjust TOG and SOx emissions for Bay Area 

refinery one-time events 

V071003_R001 Adjustments to household pesticides; adjustments to 

Bay Area gas can emissions; adjustment of train 

emissions; revisions to growth for agricul. categories 

V091203ship_R001 Adds the day-specific shipping emissions 

Point Sources: 

Version and Revision Number Reason for Change 

V030303_R001 CEFS version RF#861 

V050503_R001 Revised to include CEFS emissions dropped during 

original processing; include revised Bay Area 

refinery one-time events 

V050503_R002 Adjust TOG and SOx emissions for Bay Area 

refinery one-time events 

V050503_R003 Revise stack parameters for flaring emissions in 

Solano and Contra Costa Counties 

V071003_R001 Re-run of all point sources to ensure that all 

corrections are in place (in conjunction with changes 

to area sources) 

V092703_R001 Added locations for facilities with missing UTMs, 

especially Solano County refineries (Exxon and 

Huntway). Added refinery default stack parameters 

to Exxon facility in Solano County. 

Fires: 

Version and Revision Number Reason for Change 

V030303_R001 Wildfire and controlled burn emissions, with large 

wildfires treated as elevated point sources 

V060903_R003 Revised plume rise calculation, resulting in higher 

plume distributions 

V100203_R001 Added plume rise for smaller wildfires, in addition to 

major fires 

On-Road Motor Vehicles: 

Version and Revision Number Reason for Change 

V032403_R001 Original MV emissions files 

V042903_revmet Revised using CALMET temperatures 
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Biogenics: 

Version and Revision Number Reason for Change 

V010103_R001 Original biogenic emissions files 

V042803_revmet Revised using CALMET temperatures 

V060903_remet Added biogenic NOx 

V091703_R001 Revised to correct temporal error in data inputs 

D.6.7.1 July/August 2000 Base Case 

Below is a list of the names of the modeling files used in the base year modeling runs. 

The files follow the naming convention described above. 

Type File Name 

Point CCAQS_JULY2000_ELEV_V071003_R001_SAPRCV5_CAMX_MODELFILES.tar.gz 

Area CCAQS_JULY2000_AR_V071003_R001_SAPRCV5_CAMX_MODELFILES.tar.gz 

MV CCAQS_JULY2000_MV_revmet_V042903_R001_SAPRCV5_CAMX_MODELFILES.tar.gz 

Bio CCAQS_JULY2000_BI_revmet_V091703_R002_SAPRCV5_CAMX_MODELFILES.tar.gz 

Fires CCAQS_JULY2000_FIRES_V060903_R003_SAPRCV5_CAMX_MODELFILES.tar.gz 

D.6.7.2 July/August 200 Future Year Base Case- 2005 

Below is a list of the names of the modeling files used in the 2005 future year base case 

modeling runs. The files follow the naming convention described above. 

Type File Name 

Point CCAQS_JULYFY_ELEV_V071003_R002_SAPRCV5_CAMX_MODELFILES.tar.gz 

Area CCAQS_JULYFY2005_AREA_V071003_R01R02_SAPRCV5_CAMX_MODELFILES.tar.gz 

MV CCAQS_JULYFYA_MV_V071003_R001_SAPRCV5_CAMX_MODELFILES.tar.gz 

Bio CCAQS_JULY2000_BI_revmet_V091703_R002_SAPRCV5_CAMX_MODELFILES.tar.gz 

Fires Not included 
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D.6.7.3 July/August 2000 Future Year Base Case- 2010 

Below is a list of the names of the modeling files used in the 2010 future year base case 

modeling runs. The files follow the naming convention described above. 

Type File Name 

Point CCAQS_JULYFY_ELEV_V071003_R002_SAPRCV5_CAMX_MODELFILES.tar.gz 

Area CCAQS_JULYFY2010_AREA_V071003_R01R02_SAPRCV5_CAMX_MODELFILES.tar.gz 

MV CCAQS_JULYFY2010_MV_V071003_R001_SAPRCV5_CAMX_MODELFILES.tar.gz 

Bio CCAQS_JULY2000_BI_revmet_V091703_R002_SAPRCV5_CAMX_MODELFILES.tar.gz 

Fires Not included 

D.7 Photochemical Modeling 

D.7.1 Domain and Vertical Structure 

The CCOS study domain and modeling vertical structure were described in subsection 

D.5.2. The reader is referred to that section for details. However, here we repeat two 

tables and one figure from that section for completeness: the description of the 

modeling domain (Table D-8); a map of the modeling domain (Figure D.6); and the 

vertical structure of the air quality modeling domain (Table D-9), which is dependent 

upon the meteorological model used. 

Table D-8 

Lambert Conical Projection coordinate system used 

to define the CCOS modeling domain

Reference Latitudes 30 N 60 N 

Central Meridian 120.5 W 

Northing Offset 768.28 km 

Easting Offset 0.0 km 

Grid Cell Number 189 x 189 

Grid Cell Size 4 km 

Northing Origin -300.0 km 

Easting Origin -384.0 km 
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Figure D.6 

Air quality modeling domain for the CCOS 

July/August, 2000 episode. 
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Table D-9 

The vertical structure of the air quality modeling domain for the July/August, 2000 

CCOS episode based on the MM5 and CALMET meteorological models. 

MM5 CALMET 

Layer 

Number 

Thickness 

(m) 

Height 

(m AGL) 

Thickness 

(m) 

Height 

(m AGL) 

 1 

 2 

 3 

 4

 5 

 6 

 7 

 8

 9 

10 

11 

12

13 

14 

15 

16 

 24 

 26 

 56 

 66

 74 

 133 

 161 

 182

 205 

 232 

 265 

 356

 488 

 666 

 926 

1140 

 24 

 50 

 106 

 172

 246 

 379 

 540 

 722

 927 

1159 

1424 

1780

2268 

2934 

3860 

5000 

 20 

 40 

 40 

 100

 100 

 100 

 200 

 200

 200 

 500 

 500 

 500

 500 

 500 

 500 

1000 

 20 

 60 

 100 

 200

 300 

 400 

 600 

 800

1000 

1500 

2000 

2500

3000 

3500 

4000 

5000 

D.7.2 Initial and Boundary Conditions 

The relatively large size of the CCOS air quality modeling domain was intended to 

minimize the influence of boundary concentrations. Ideally, modeling domain 

boundaries should be located where the air is relatively clean, or they should be located 

sufficiently far away from modeling areas of interest to minimize their impact if the 

boundary inflow is not clean. 

The western boundary and part of the southern boundary of the CCOS modeling 

domain are located over the Pacific Ocean. Over the Pacific Ocean the air is thought to 

be clean, therefore boundary concentrations were assigned based on clean air as 

defined by the U.S. EPA (1991). This clean air definition is comprised of 40 ppb ozone, 

2 ppb oxides of nitrogen (NOx), and approximately 22 ppbC of reactive hydrocarbons 

(see Table D-10). However, simulation experiments have suggested that the 

conversion of NOx to nitrates is such that nitrogen oxide (NO) concentrations over the 

ocean should be very low with any appreciable residence time. Therefore, nitrogen 

oxide concentrations were set to zero over the ocean. 

The determination of over land boundary concentrations is less certain. Air quality 

monitoring sites in remote areas are few, and extrapolating existing measurements over 

long boundaries is fraught with uncertainties. In the 2003 State Implementation Plan 

update prepared by the South Coast Air Quality Management District (SCAQMD, 2003), 
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a concentration profile was defined for over land, remote areas. This concentration 

profile, referred to herein as "SCAQMD clean", is similar to the USEPA definition of 

clean air except that the concentration of reactive hydrocarbons is 60.7 ppbC. This 

concentration was adopted for over land boundaries of the CCOS domain (see Table D10). Initial conditions were set equal to the eastern boundary conditions with the 

exception of VOC. Based on measured data the VOC was multiplied by a factor of two 

for the San Joaquin Valley only. VOC initial conditions in the SJV were set at 121.4 

ppbC. 

Defining concentration profiles for the boundary at the top of the modeling domain (note: 

5,000 magl – see subsection D.5.2) is confounded by the few air quality measurements 

above the ground. The few aircraft measurements available recorded concentrations 

only at a few times, locations, and heights. During the CCOS field study, ozonesondes 

were launched daily on episode days at Granite Bay and at Parlier. These 

measurements suggested ozone concentrations of 70 ppb or greater at 5,000 magl that 

persisted throughout the July/August episode period. Based on these few 

measurements, the top boundary concentrations selected were based on the clean air 

profile defined by the U.S. EPA (1991), with the exception that ozone concentrations 

were set to 70 ppb. 

Table D-10 

Carbon Bond IV boundary concentration profiles for the July/August, 2000 CCOS 

episode. These same boundary condition totals were used with SAPRC99 

Compound(s) 

USEPA (1991) 

Clean 

SCAQMD (2003) 

Clean 

Reactive hydrocarbons 21.9 ppbC 60.7 ppbC 

Carbon Monoxide 350 ppm 200 ppm 

Oxides of Nitrogen 2.0 ppb 2.0 ppb 

Ozone 40.0 ppb 40.0 ppb 

D.7.3 Base Year Model Performance Evaluation 

The period July 29–August 2, 2000 was simulated using the CAMx air quality model, 

alternatively with the Carbon Bond IV and SAPRC99f chemical mechanisms. The 

meteorological models MM5 and the CALMET/MM5 hybrid were also used to provide 

inputs to CAMx. Overall, model performance of CAMx using the CALMET/MM5 hybrid 

was superior to those resulting from MM5 alone; therefore, only the results simulated 

using the CALMET/MM5 hybrid are reported here. 

The U.S. EPA (1991) provided guidelines for the evaluation of an ozone air quality 

model. In these guidelines, three statistical measures are used to compare simulated 

and observed 1-hour ozone concentrations above a threshold of 60 ppb; unpaired peak 

ratio (UPR), normalized bias (NB), and gross error (GE). The UPR compares daily 

peak simulated ozone concentration, unpaired in time and space, with the daily peak 

observed. Tesche et al. (1990) provide definitions for these and other statistical 
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measures. To meet acceptance criteria, the UPR must be within the range of 0.80 to 

1.20. The NB is the average percent difference between observed and simulated ozone 

concentrations paired in time and space, and the GE is the average absolute percent 

difference. To meet acceptance criteria, the NB must be within the range of +/- 15% 

and the GE less than 35%. 

The U.S. EPA (1991) performance guidelines allow simulated and observed ozone 

concentrations for the whole modeling domain to be pooled into one set of statistical 

measures. However, in a domain as large and geographically diverse as the CCOS 

modeling domain, pooling all concentrations into a single set of statistical measures 

would not allow an assessment of model performance across the domain. Therefore, 

for this analysis, the CCOS domain was subdivided into 9 subregions (Figure D.7) and 

statistical measures for model performance assessments were calculated for each one. 

Statistical measures of ozone model performance for the July/August, 2000 episode are 

summarized in Table D-11. Simulation results for both the Carbon Bond 4 and 

SAPRC99f chemical mechanisms are shown. In general, ozone concentrations 

simulated using the SAPRC99f chemical mechanism are higher than those simulated 

using Carbon Bond 4. On those days for which a subregion had peak ozone 

concentrations in excess of 125 ppb, the simulations met model performance 

guidelines. Several visual and statistical depictions of the base year simulation results 

are provided in an uncirculated appendix. 

Figure D.7 

Performance evaluation subregions for the CCOS air quality modeling domain. 
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Table D-11 

Base year ozone model performance for the July/August CCOS episode 

(July 29–August 2, 2000) using CAMx with CALMET/MM5 hybrid 

meteorology. Highlighted statistical measures indicate those meeting U.S. 

EPA (1991) model performance guidelines. 

CAMx/CB4 CAMx/SAPRC99f 

Subregion Obs. Peak 

(ppb) Sim. Pk. 

(ppb) UPR 

NB 

(%) 

GE 

(%) 

Sim. Pk. 

(ppb) UPR 

NB 

(%) 

GE 

(%) 

July 29, 2000

Zone 3 

Zone 6 

Zone 7 

Zone 8 

 82 

121 

129 

128 

107 

129 

130 

123 

1.31 

1.07 

1.01 

0.96 

+13 

+09 

-08 

-12 

24 

19 

18 

20 

102 

147 

144 

149 

1.24 

1.21 

1.12 

1.16 

+10 

+13 

-03 

-02 

24 

22 

17 

25 

July 30, 2000

Zone 3 

Zone 6 

Zone 7 

Zone 8 

126 

110 

118 

115 

117 

137 

128 

119 

0.93 

1.25 

1.09 

1.04 

+01 

+05 

+03 

-12 

22 

16 

17 

18 

124 

149 

138 

132 

0.98 

1.35 

1.17 

1.15 

+04 

+04 

+06 

-07 

22 

17 

18 

20 

August 1, 2000

Zone 3 

Zone 6 

Zone 7 

Zone 8 

109 

134 

118 

116 

111 

137 

124 

114 

1.01 

1.02 

1.05 

0.98 

-10 

-04 

-09 

-15 

25 

17 

20 

19 

121 

145 

132 

120 

1.11 

1.08 

1.12 

1.04 

-05 

-02 

-05 

-10 

28 

19 

21 

19 

August 2, 2000

Zone 3 

Zone 6 

Zone 7 

Zone 8 

100 

131 

131 

151 

084 

127 

127 

129 

0.84 

0.97 

0.97 

0.85 

-44 

-16 

-10 

-13 

44 

21 

22 

21 

 90 

137 

137 

140 

0.90 

1.05 

1.04 

0.92 

-41 

-09 

-02 

-07 

41 

20 

22 

20 

• UPR = Unpaired Peak Ratio; NB = Normalized Bias; GE = Gross Error 

• Subregion assignments: 

 Zone 3 = San Francisco Bay Area Zone 6 = Sacramento/Delta area 

 Zone 7 = Fresno area Zone 8 = Bakersfield area 

D.7.4 Base Case Sensitivity to Natural Sources 

Biogenic emissions from plants are significant contributors to the hydrocarbon emission 

inventory, and are known to contribute to ozone concentrations measured within 

California. In addition to these emissions, wildfires are frequent occurrences in summer 

and can also generate hydrocarbons that can contribute to observed ozone 

concentrations. Using the CAMx base case simulation with Carbon Bond IV chemistry, 

the impact of these natural emissions on ozone concentrations during the July/August, 

2000 episode was investigated. 

Sensitivity simulations were conducted wherein emissions input into the air quality 

model were modified. After the air quality model was run, differences from the basecase simulation results were determined to assess impacts. To assess the impact of 

natural emissions, three emissions scenarios were evaluated: 1) removing all wildfires; 
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2) increasing biogenic emissions by 25%; and 3) removing all biogenic emissions. The 

results of the air quality simulations using these scenarios were summarized in Table D12. 

Removing wildfire emissions had little impact on peak simulated ozone concentrations, 

except in the southern San Joaquin Valley. Simulated ozone concentrations within the 

SF Bay Area and the Sacramento/Delta regions of the modeling domain were altered by 

less than 1 ppb for all sites (data not shown). These results suggest that the high ozone 

concentration in Kern County on August 2 was impacted by fires, since removing the 

wildfires reduced the simulated ozone peak by approximately 7%. 

Increasing biogenic emissions by 25% had a modest impact on simulated ozone 

concentrations throughout the modeling domain. The largest impact was on July 31; 

peak ozone concentrations in the San Francisco Bay Area and Sacramento/Delta 

subregions increased by 4 ppb. At individual sites, the increases were greater (data not 

shown). The magnitude of these changes approximate the impact of large errors in the 

temperature fields (~ 3 oC) used to calculate biogenic emissions. 

Removing all biogenic emissions had the greatest impact of all natural sources. 

Removing all biogenic emissions reduced peak simulated ozone concentrations 

throughout the modeling domain by as much as 22%; however, the impacts were not as 

great for all subregions, and on each day. 

Table D-12 

Differences in peak simulated ozone concentrations using CAMx/CB4 and simulated 

peak concentrations without wildfires, with a 25% increase in biogenic emissions, and 

without biogenic emissions for the July/August, 2000 CCOS episode. 

No Fires +25% 

Biogenics 

No 

Base Biogenics 

Case 

ppb 

% 

change ppb 

% 

change ppb 

% 

change 

July 31 (Julian Day 213): 

 Zone 3 (SF Bay) 

 Zone 6 (Sacramento/Delta) 

 Zone 8 (Kern County) 

126 

131 

129 

 0 

 0 

 0 

 0 

 0 

 0 

4 

4 

2 

3 

3 

2 

-22 

-21 

- 8 

-17 

-16 

- 6 

August 1 (Julian Day 214): 

 Zone 3 (SF Bay) 

 Zone 6 (Sacramento/Delta) 

 Zone 8 (Kern County) 

119 

132 

119 

 0 

 0 

-2 

 0 

 0 

-2 

1 

2 

1 

1 

2 

1 

-24 

-27 

- 8 

-20 

-20 

- 7 

August 2 (Julian Day 215): 

 Zone 3 (SF Bay) 

 Zone 6 (Sacramento/Delta) 

 Zone 8 (Kern County) 

 93 

133 

135 

 0 

 0 

-9 

 0 

 0 

-7 

2 

4 

1 

2 

3 

1 

-10 

-29 

-10 

-11 

-22 

- 7 
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D.8 References 

Air Sciences, Inc. (2002) 1996 Fire Emissions Inventory. Draft Final Report. 

Lakewood, CO. On-line link: 

http:/www.wrapair.org/forums/FEJF1/emissions/FEJF1996EIReport_021208.pdf 

Baldocchi, D., Fuentes, J., Bowling, D., Turnipseed, A., and Monson, R. (1999) 

“Scaling isoprene fluxes from leaves to canopies: test cases over a boreal aspen 

and a mixed species temperate forest.” Journal of Applied Meteorology 38: 885-

898. 

Barna, M., B. Lamb, S. O'Neill, and H. Westberg. (2000) “Modeling ozone formation 

and transport in the Cascadia region of the Pacific northwest.” Atmos. Environ. 

39:349-366. 

Benjamin, M., Sudol, M., Bloch, L. and A. Winer. (1996) “Low-emitting urban forests: a 

taxonomic methodology for assigning isoprene and monoterpene emission rates.” 

Atmospheric Environment. 30 (9): 1437-1452. 

Benjamin, M., Sudol, M., Vorsatz, D. and A. Winer. (1997) “A spatially and temporally 

resolved biogenic hydrocarbon emissions inventory for the California south coast air 

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emission rate variability: observations with eucalyptus and emission rate algorithm 

development.” Journal of Geophysical Research. 96: 10799-10808. 
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Technical Support Division, California Air Resources Board, Sacramento, CA. June, 

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Sacramento, CA. 
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D.9 Gridded Inventory Coordination Group Minutes 

D.9.1 February 26, 2003 Minutes 

Attendees Affiliation 

Amir Fanai, Glen Long, Toch Mangat, Phil Martien Bay Area AQMD 

Bruce Katayama, Aleta Kinnard, Hao Quinn, Greg Tholen Sacramento Metro AQMD 

Cyndi Loomis, Jim Wilkinson Alpine Geophysics 

Vernon Hughes, Ajith Kaduwela, Cheryl Taylor ARB 

Welcome 

Cheryl welcomed everyone to the call. Introductions were made. 

General Discussion 

Purpose of the Coordination Group 

This group was formed as an outgrowth of the February 19 modeling conference call, 

where several districts expressed a desire to review the gridded inventories to be used 

in modeling for the SIPs. The group agreed that the more people who review the 

inventories, the more likely they will spot problems quickly. More reviewers can also 

share the burden of reviewing such large amounts of information. The districts have 

specific knowledge about the inventories in their regions, so are more likely to discover 

problems. 

Goals/Expectations of the Group 

The goal of the group is to provide gridded inventories for review in an easily accessible 

and coordinated manner. There are several gridded inventories that will be available for 

review by the group, including episodes for July/August 2000, September 2000, and 

June 2000. The creation of gridded inventories for July 1999 and a 2002 episode are 

being considered. ARB, Alpine Geophysics, and Environ are creating pieces of the 

various gridded inventories. ARB will receive all the pieces and will be assembling them 

for each episode. The group agreed that inventories should be made available for 

review whenever they are available, regardless of priority for the SIPs. Cheryl will 

distribute minutes. 

Timeframe for Reviewing Inventories 

The group agreed that an email would be broadcast when a new inventory had been 

posted for review. A period of two weeks for review would begin once the notification 

had been sent. 
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Feedback from Reviewers – What Will be the Process to Incorporate/Investigate 

any Comments or Requested Changes? 

It was suggested that there be a structured form for comments; this will be discussed at 

future meetings. Requests to change emissions should be made through the normal 

channels, such as the Emission Inventory Branch at ARB. The entire group is to be 

notified if there are changes to the emissions or if other problems are identified. 

Frequency of Meetings 

The group did not specifically determine the frequency of the meetings, but they agreed 

to meet again in three weeks. 

Discuss Specifics of How to Review Gridded Inventories 

Vernon described the basic steps to creating model-ready gridded inventories. Base 

year criteria emissions are fed from CEIDARS (California Emission Inventory 

Development and Reporting System) into CEFS (California Emission Forecasting 

System). CEFS creates base year and future year inventories by air basin, county, and 

source category (SIC/SCC for point sources or EIC for all other sources) for either a 

weekday or a weekend day for a specified month. Day-specific data are then merged 

in. Next, EMS-95 is used to distribute the emissions both spatially and temporally 

(down to grid cell by hour). Then the emissions are speciated and reformatted to create 

model-specific gridded inventories. 

The group agreed that the following reports would be useful: 

Tabular reports from CEIDARS/CEFS (summary of emissions of criteria pollutants by 

county/air basin and by 3-digit EIC – base year and forecasted years) 

Tabular and graphical (tile plots) reports of the model-ready gridded inventories 

Intermediate SAS files (gridded hourly criteria inventory with categories in tact) 

Model-ready files 

Speciation profiles 

Spatial Surrogates 

Temporal Profiles 

Cyndi said that she already has summary reports that she would be willing to run on the 

gridded inventories as they become available for review. Gridded inventories for the 

July/August 2000 episode are available now for review. Vernon emphasized that 

version control (e.g. version of EMFAC used in the gridded inventory) is very important 

and needs to be stated clearly for each gridded inventory. 
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Discuss How to Access Gridded Inventories 

Cyndi volunteered Alpine Geophysics to be the repository of information by hosting an 

ftp site accessed through the Web. ARB may take over this duty in the next few weeks 

after ARB finalizes its global file directory syntax. 

Cyndi and Vernon will discuss the details of exactly what will be posted. ARB will then 

distribute a one-page proposal to the group for comment. The proposal would detail 

what reports and version control information would be provided for review. Cyndi will 

set up a website and post data within a couple of weeks. The group will be notified 

when data are available and how to access the site. At the next call, the group will 

discuss the website and reports; changes will be incorporated as agreed. 

Other Districts Who May Wish to be Involved? 

Phil suggested that Bob Nunes from Monterey Bay Unified APCD might be interested in 

participating in this group. Vernon will call him. 

Jim suggested that representatives from the COGs might also be interested in reviewing 

the on-road mobile source emissions. Jim has a list of the COG representatives that he 

has spoken with in preparing the roadway network for the CCOS domain. He will send 

the list to Vernon who will give them to Ed Yotter for review. Ed will be asked to join this 

group. 

Other Issues 

No other issues were discussed. 

Plans for Next Meeting 

The next conference call is scheduled for Wednesday, March 19. 
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D.9.2 March 19, 2003 Minutes 

Attendees Affiliation 

Amir Fanai, Toch Mangat, Phil Martien Bay Area AQMD 

Bob Nunes Monterey Bay Unified 

APCD 

Bruce Katayama, Charles Parker, Greg Tholen, 

Brigette Tollstrup 

Sacramento Metro AQMD 

Donald Hunsaker, David Nunes, Evan Shipp, Michelle 

Stanley 

San Joaquin Valley Unified 

APCD 

Vincent Liu Kern COG 

Harold Brazil MTC 

Cari Anderson Earth Matters 

Cyndi Loomis, Jim Wilkinson Alpine Geophysics 

Vernon Hughes, Cheryl Taylor, Ed Yotter ARB 

Welcome and Feedback on February 26 Minutes 

ARB welcomed everyone to the call. Introductions were made. There were no 

comments on the February 26 minutes. 

Discuss How to Efficiently Transfer and Track Review of Gridded Inventories 

Alpine Geophysics described how they propose to set up the ftp site (not a web page) to 

efficiently transfer and track the review of the gridded inventories. There will be three 

main parts: “read me” files, a data-tracking log, and the files/reports themselves. The 

“read me” files and data tracking log are described below; the files/reports are 

discussed in Item 3. 

The “read me” files will contain several pieces of information. One part will discuss the 

naming convention used to describe each gridded file for review. ARB has developed a 

naming convention that describes the file. The name will state the domain (CCAQS), 

episode day, source type (point, area, on-road motor vehicle, or biogenics), sourcespecific information (e.g. version of EMFAC), when the file was created and the version, 

chemical mechanism (e.g. SAPRC), speciation version, and model format (e.g. ascii). 

Another “read me” file will describe the data-tracking log, how to use it, and what to do if 

you find problems in the gridded inventories. The BAAQMD suggested that a “read me” 

file include a discussion of what each file contains (e.g. data dictionary) as well as other 

information such as the units of the emissions. A “read me” file will also describe how 

Alpine Geophysics developed a model to add commercial VMT to the Integrated 

Transportation Network (ITN) (see Item 4 below). A “read me” file will describe the 

differences in VMT between the ITN and EMFAC 2002 (see Item 4 below) 
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Alpine Geophysics has developed a data-tracking log. The log shows the current 

inventory, date released, problems identified, who identified the problem and when, how 

the problem was fixed, and who fixed the problem and when. Per the group’s request, 

Alpine Geophysics will include a list of standard QA procedures that they have 

implemented in reviewing the inventories to avoid duplication of effort. 

ARB will develop a one-page proposal that will detail what information will be posted on 

the ftp site, and distribute it to the group for comment. ARB reminded everyone that 

both time and resources are growing shorter, so the number of custom reports may be 

limited. The San Joaquin Valley district said that they might be able to provide 

assistance to other districts by providing plots and/or reports. 

Discuss New Site for Accessing Gridded Inventories 

The ftp site is not available yet for viewing, but should be ready next week. Below is a 

list of the reports that will be available on the ftp site. Information for the July/August 

2000 episode will posted first. Information for other episodes will be posted when 

available. Episodes that are planned include September 2000, July 1999, and June 

2000. 

Alpine Geophysics is putting together a report that describes how the gridded on-road 

motor vehicle inventory was created. The report will describe how the Integrated 

Transportation Network (ITN) for the entire CCOS/CRPAQS domain was developed. It 

will also describe how the day-specific data, which were collected by Dr. Deb Niemeier 

of UC Davis, were incorporated. The report should be available in two weeks and will 

be distributed to the group a few days prior to the next call. 

List of data/reports that will be available on the ftp site: 

1) Tabular reports from CEFS, the inventory forecasting system (summary of 

emissions of criteria pollutants by county/air basin and by 3-digit EIC – base year and 

forecasted years) 

2) Tabular and graphical (tile plots) reports of the model-ready gridded inventories 

by 3-digit EIC by county 

3) Intermediate SAS files (gridded hourly criteria inventory by 3-digit EIC) 

4) Model-ready files (will include 4 sets - CAMx and SAQM models each using CBIV and SAPRC chemical mechanisms) 

5) Speciation profiles 

6) Spatial surrogates 

7) Temporal profiles 

8) Day-specific data for point sources 

9) Integrated Transportation Network (ITN) (ARC format) 

10) DTIM-ready files 
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Other Issues – On-Road Motor Vehicle Gridded Inventory 

Alpine Geophysics briefly described how the on-road gridded inventory was developed. 

First they developed an Integrated Transportation Network (ITN) that combines demand 

model networks from agencies such as MTC, SACOG, four COGs in the San Joaquin 

Valley, and Caltrans’ statewide network. The VMT provided by each of these agencies 

was adjusted in three ways. First, the VMT were adjusted to represent the year 2000. 

For instance, the statewide network was for year 1995 and was grown to reflect year 

2000. Second, the VMT was adjusted to distinguish between weekday and weekend 

volumes. Third, Alpine Geophysics developed a model to add commercial VMT to the 

ITN. 

Alpine Geophysics compared the VMT for 2000 from the ITN with EMFAC 2002. There 

were some discrepancies, which Alpine Geophysics understands and will document in a 

“read me” file. 

Plans for Next Meeting 

The next conference call will focus on the on-road motor vehicle gridded inventory. The 

call is scheduled for Monday, April 7. 
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D.9.3 April 7, 2003 Minutes 

Attendees Affiliation 

Toch Mangat, Phil Martien Bay Area AQMD 

Charles Anderson, Matt Jones, Bruce Katayama, 

Greg Tholen, Brigette Tollstrup Sacramento Metro AQMD 

Donald Hunsaker, David Nunes, Stephen Shaw, 

Evan Shipp, Michelle Stanley 

San Joaquin Valley Unified 

APCD 

Harold Brazil MTC 

Cari Anderson Earth Matters 

Cyndi Loomis, Jim Wilkinson Alpine Geophysics 

Vernon Hughes, Anne Lin, Cheryl Taylor, Ed 

Yotter ARB 

Welcome and Feedback on March 19 Minutes 

ARB welcomed everyone to the call. Introductions were made. There were no 

comments on the March 19 minutes. The BAAQMD asked if the one-page summary 

that details the information that will be posted on the ftp site had been distributed (as 

referenced in the minutes). ARB responded that the summary had not been written yet. 

Status of Ftp Site for Accessing Gridded Inventories 

Alpine Geophysics described the ftp site (not a web page) that they set up to transfer 

and track the review of the gridded inventories. To access the information, ftp to 

agftp.com (host name). The user ID is agftp and the password is pass4ftp. 

To review emissions files, change to directory “CCAQS_Emissions”. There are subdirectories for three episodes: June 2000, July 2000, and September 2000. Data are 

available under July 2000 for the July/August 2000 episode. Under the July 2000 subdirectory are five sub-directories: a) CEFS_files, b) Gridded_SAS_files, c) 

Modeling_Files, d) Plots and e) Summaries. 

a) CEFS_files: Contains the actual files provided by the ARB’s Emission Inventory 

Branch as they come out of CEFS. 

b) Gridded_SAS_files: Contains the gridded SAS datasets in SAS trans format. 

This format allows SAS files to be transferred to versions of SAS running on different 

platforms (i.e. PC, Linux, Sun). Alpine Geophysics will include an example of SAS code 

that can be used to extract the transport files to your local systems. SAS will be 

required to access and use these files. The files are broken into source types: area, 

point, biogenics, on-road, and fires. There is a file for each source type and episode 

day. 

c) Modeling_Files: These are the model-ready files for input into SAQM and CAMx. 

Each model is run using both SAPRC and CBIV chemistry. These files are further 
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separated into source types (point, area, biogenics, on-road, and fires). These are 

ASCII (text) format files. 

d) Plots: These are gif plots (not animated) showing hourly and daily total 

emissions (kilograms per day) of NOx and ROG for point, area, and on-road sources for 

August 1, 2000. 

e) Summaries: There are two reports. One shows county totals for point, area, and 

on-road. The second report shows point and area source emissions by county by EIC 

with day-specific data merged in. 

Several additions will be posted to the ftp site soon. ARB will develop a one-page 

summary that will detail what information will be posted on the ftp site. Alpine 

Geophysics will add a description of the file naming convention. Alpine will post to the 

ftp site a data-tracking log that shows the current inventory, date released, problems 

identified, who identified the problem and when, how the problem was fixed, and who 

fixed the problem and when. The September 2000 point and area source files are 

ready, so they will be posted to the ftp site. Emissions from soil NO will also be posted. 

Gridded On-road Motor Vehicle Emissions 

Alpine Geophysics distributed to the group a draft report (available on the ftp site) that 

describes how the gridded on-road motor vehicle inventory was created. The report 

describes how the Integrated Transportation Network (ITN) for the entire 

CCOS/CRPAQS domain was developed. The report describes the addition of a 

commercial travel model to the ITN. It also describes how the day-specific data were 

used to create hourly VMT distributions and make adjustments for weekdays and 

weekend days. Please provide any comments to Jim Wilkinson (Alpine Geophysics). 

Other Issues 

The group asked how much time is available to review the gridded inventories. ARB 

has already begun modeling with the emission inventories that have been developed, 

so any issues that are discovered will need to be addressed as soon as possible. 

Provide any comments or questions to Cheryl Taylor (cataylor@arb.ca.gov). 

Plans for Next Meeting 

The next conference call is scheduled for Wednesday, April 23. 
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D.9.4 April 23, 2003 Minutes 

Attendees Affiliation 

Toch Mangat, Phil Martien, Steve Soong Bay Area AQMD 

Bob Nunes Monterey Bay Unified APCD 

Charles Anderson, Matt Jones, Bruce Katayama, 

Aleta Kennard, Hao Quinn, Greg Tholen Sacramento Metro AQMD 

David Nunes, Stephen Shaw, Michelle Stanley San Joaquin Valley Unified 

APCD 

Harold Brazil MTC 

Cari Anderson Earth Matters 

Cyndi Loomis Alpine Geophysics 

Daniel Chau, Vernon Hughes, Doug Ito, Bruce 

Jackson, Anne Lin, Tess Sicat, Cheryl Taylor, 

Eugene Yang, Ed Yotter 

ARB 

Welcome and Feedback on April 7 Minutes 

ARB welcomed everyone to the call. Introductions were made. There were no 

comments on the April 7 minutes. 

Status of Ftp Site for Accessing Gridded Inventories 

Alpine Geophysics described the status of the information on the ftp site. Alpine has 

placed several items on the ftp site since the last call. 1) Alpine has added the point 

and area source files for the September 2000 episode. 2) Alpine has placed an 

example of SAS code that can be used to extract the SAS transport files to your local 

system. This will enable you to review the gridded SAS files that are in SAS trans 

format. The file on the ftp site is called “example_import.sas”. 3) Alpine has placed a 

program to convert ASCII to binary that will allow the modeling files to be imported into 

PAVE, as requested by Sac Metro AQMD. The program on the ftp site is called 

“binary_convert.tar.gz”. [Note: To access the information, ftp to agftp.com (host name). 

The user ID is agftp and the password is pass4ftp. The emission information can be 

found under the directory “CCAQS_Emissions”. A detailed description of the contents 

of the CCAQS_Emissions directory can be found in the April 7 minutes.] 

Several additions will be posted to the ftp site soon. 1) Alpine will place an overview 

document that describes what information is posted on the ftp site. 2) Revised on-road 

motor vehicle and biogenic emissions for the July/August episode will be posted soon. 

These emissions were recalculated using different meteorological data. 3) Alpine will 

add a description of the file naming convention. 4) Alpine will post to the ftp site a datatracking log that shows the current inventory, date released, problems identified, who 

identified the problem and when, how the problem was fixed, and who fixed the problem 

and when. 5) Emissions from soil NO will also be posted. 6) Spatial surrogate 
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information (report and graphics) will be posted. 7) The results of a CCOS project to 

update specific district area source categories will be available. 8) Future year 

emissions will be posted when they become available. 

BAAQMD stated that they would be revising emission and stack data for refineries. Sac 

Metro AQMD raised questions about inconsistencies in the summary reports. ARB also 

expressed concerns about discrepancies in county total emissions between the 

summary reports on the ftp site with reports run in-house by ARB. ARB will work with 

Alpine to correct and clarify the summary reports. Sac Metro AQMD also expressed 

concern that their day-specific emissions didn’t appear to be incorporated correctly. 

ARB will work with the district and Alpine to ensure the inclusion of the day-specific 

data. 

Comments on Alpine Geophysics’ Report on the Integrated Transportation 

Network 

The group provided comments on the draft report (available on the ftp site) that 

describes how the gridded on-road motor vehicle inventory was created using the 

Integrated Transportation Network (ITN). ARB noted that they are working with the 

COGs to specifically define the hours in the am/pm peaks for their region. ARB will 

work with Alpine to incorporate any corrections needed to the motor vehicle emission 

calculations. SJVUAPCD expressed concern about Caltrans’ statewide network being 

used for their four northern counties rather than local data. Earth Matters, who 

represents the valley COGs, will work with ARB and Alpine to look into acquiring local 

network data. SJVUAPCD also noted that the ITN represents reality fairly well in the 

urban areas, but can be off by more than a grid cell in more remote areas like the 

foothills. Also, Earth Matters sent questions about the commercial travel model that 

Alpine included; ARB and Alpine will discuss the questions on a separate call. Please 

provide any additional comments to Jim Wilkinson (Alpine Geophysics). 

Other Issues 

No other issues were discussed. 

Plans for Next Meeting 

The next conference call is scheduled for Wednesday, May 7. 
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D.9.5 May 7, 2003 Minutes 

Attendees Affiliation 

Toch Mangat, Phil Martien, Amir Fanai Bay Area AQMD 

Bob Nunes Monterey Bay Unified APCD 

Matt Jones, Greg Tholen Sacramento Metro AQMD 

Donald Hunsaker, David Nunes, Evan Shipp San Joaquin Valley Unified 

APCD 

Harold Brazil MTC 

Cari Anderson Earth Matters 

Cyndi Loomis, Jim Wilkinson Alpine Geophysics 

Leonard Seitz Caltrans 

Paul Allen, Daniel Chau, Vernon Hughes, Doug 

Ito, Bruce Jackson, Anne Lin, Cheryl Taylor, 

Bruce Tuter, Ed Yotter 

ARB 

Welcome and Feedback on April 23 Minutes 

ARB welcomed everyone to the call. Introductions were made. There were no 

comments on the April 23 minutes. 

Status of Ftp Site for Accessing Gridded Inventories 

Alpine Geophysics described the status of the information on the ftp site. Alpine has 

placed several items on the ftp site since the last call: 

a) Alpine has posted modeling files that reflect revised on-road motor vehicle and 

biogenic emissions using CALMET temperatures (higher temperatures) for the 

July/August 2000 episode. The on-road emissions increased about 10-20% and the 

biogenic emissions increased about 30% from the previous version. It was noted that 

the on-road emissions were adjusted so that the county totals match the emissions from 

EMFAC2002 v2.2. These emissions were spatially allocated using the output from 

DTIM, which uses the ITN activity as input, to create hourly emission ratios for each grid 

cell in a county. The revised files contain “revmet” in the name. 

b) Alpine has posted new summaries of emissions by county and by category (EIC3 

level) for point and area sources. The new summaries reflect the correction to the EIC 

mapping that was causing some point and area source emissions to be dropped. The 

summaries also reflect a clearer accounting of the processing that occurred from the 

CEFS output files to the SAS gridded files (e.g. some ag burn emissions are dropped 

because no burning occurred on the episode day). Close attention should be paid to 

the files names in order to retrieve the latest version; the revised summaries have 

V050503 (Version dated May 5, 2003) added to the file name. 
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c) Alpine has posted point and area source model-ready files (SAPRC format) for 

January 2001. 

d) Alpine has placed the EMS-95 Technical Formulation Documentation on the ftp 

site under the directory "EMS-95 Technical Formulation Documentation". These are old 

WordPerfect files that should load into newer versions of WordPerfect and probably into 

Word. Much of this same information is available on-line at 

ww.ladco.org/emis/guide/ems95.html. 

e) The Emission Inventory Branch at ARB has developed a website with information 

regarding SIP Baseline Emission Inventory Projections. The site contains report 

generators for annual average, seasonal average planning, and modeling inventories. 

There are sections on control rule reports, documentation, and memoranda. This site 

should be helpful in checking the summary reports from CEFS that are posted on the ftp 

site. The address is http://www.arb.ca.gov/app/emsinv/ccos/index.php 

f) Spatial data are now available on the ftp site. The reports and plots created by 

Sonoma Technology Inc. (STI) are available for review. A "read me" file describes the 

files. The directory is called "CCOSI_STI". 

g) Future year surrogate information is also available from STI. It is in the directory 

"NewSurrogates_STI". 

h) The results of the project to update specific district area source categories for 

small districts in the Mountain Counties, Sacramento Valley, and Mendocino can be 

found in the directory "CCOSII_STI". A "read me" file describes where to find the 

information. 

The BAAQMD noticed as they reviewed the plots that the southern portion of the 

domain had a different timing for when motor vehicle emissions began than the rest of 

the domain. ARB is having on-going discussions with the COGs about the definition of 

“peak hour”. There are multiple period definitions for different networks. ARB is 

working with Alpine to ensure that the actual hours as defined by am, pm, and off-peak 

periods are reflected correctly on the Integrated Transportation Network (ITN). The 

BAAQMD has also created animations of the NOx and TOG plots for on-road motor 

vehicles and volunteered to post them on the ftp site. 

The group discussed the labeling information on the plots. The units are in kg/grid cell 

for each hour. The time shown is local time (PDT for July 2000). Alpine will check the 

labels to make sure that the units and a description of the plot are displayed. 
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Comments on Alpine Geophysics’ Report on the Integrated Transportation 

Network 

Alpine Geophysics received two sets of comments on the draft ITN report. Alpine will 

draft responses to the comments. 

Additionally, the San Joaquin Valley Unified APCD and Earth Matters had expressed 

concern in previous meetings that the ITN uses the statewide model for the four 

northern counties in the San Joaquin Valley. The SJVUAPCD is continuing to study the 

ITN in the northern SJV to determine if the ITN is acceptable as a replacement for local 

data. The SJVUAPCD and Earth Matters expressed acceptance of the ITN for use in 

the SIPs. Earth Matters expressed acceptance of the ITN for use in the SIPs. The 

SJVUAPCD is still discussing in-house the acceptability of the ITN. ARB and 

SJVUAPCD will discuss the subject further during the next weekly modeling call. Earth 

Matters agreed to work with ARB to provide updated data for all eight counties in the 

SJV. There is not sufficient time to incorporate these data into the ITN for use in the 

upcoming SIPs. Perhaps they can be used for future work, such as transport analysis. 

Monterey Bay Unified APCD expressed surprise that local transportation data were not 

used for the Monterey area since they believe that data were available. AMBAG did not 

respond to the original request for data from Alpine. Monterey Bay district will look into 

what data are currently available. 

Caltrans noted that they would have a new statewide model available soon that will 

represent calendar year 2000. 

Other Issues 

Earth Matters had a question about the TOG emissions for area sources in the San 

Joaquin Valley. They compared the August 1, 2000 inventory with an average summer 

day inventory and noticed a large difference (about 1100 tpd). ARB will look into the 

question. 

Plans for Next Meeting 

The next conference call is scheduled for Wednesday, May 21. 
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D.9.6 May 21, 2003 Minutes 

Attendees Affiliation 

Toch Mangat, Phil Martien, Amir Fanai Bay Area AQMD 

Bob Nunes Monterey Bay Unified APCD 

Charles Anderson, Matt Jones, Bruce Katayama, 

Aleta Kennard, Greg Tholen Sacramento Metro AQMD 

David Nunes, Evan Shipp, Michelle Stanley San Joaquin Valley Unified 

APCD 

Harold Brazil MTC 

Cari Anderson Earth Matters 

Cyndi Loomis, Jim Wilkinson Alpine Geophysics 

Leonard Seitz Caltrans 

Ravi Ramalingam, Cheryl Taylor, Ed Yotter ARB 

Welcome and Feedback on May 7 Minutes 

ARB welcomed everyone to the call. Introductions were made. There were two 

comments on the May 7 draft minutes. The SJVUAPCD did not agree with the 

statement in Section 3 “The SJVUAPCD and Earth Matters expressed acceptance of 

the ITN for use in the SIPs.” The SJVUAPCD is still discussing in-house the 

acceptability of the ITN. ARB and SJVUAPCD will discuss the subject further in the 

next weekly modeling call. 

Caltrans questioned the following statement on the ITN in Section 2, part 1): “These 

emissions were spatially adjusted using VMT on the Integrated Transportation Network 

(ITN).” This statement incorrectly reflected what was said at the meeting. The 

statement should read “These emissions were spatially allocated using the output from 

DTIM, which uses the ITN activity as input, to create hourly emission ratios for each grid 

cell in a county.” After discussing the spatial distribution of the emissions, Caltrans was 

satisfied with the method. ARB will correct the minutes to reflect these comments. 

Data on Ftp Site 

Alpine Geophysics described the information posted to the ftp site since the last call. 

[To access the site, ftp to agftp.com (host name). The user ID is agftp and the 

password is pass4ftp.] Since there have been several revisions to some of the files, 

Alpine has created a Version_Control_Log (found under CCAQS_Emissions/July 

2000/Modeling_Files) that describes the reason for each revision and the revision 

number. This log will be very helpful in understanding what is in each file. 

a) Alpine posted revised point and area source files for the July/August 2000 

episode that reflect corrections in the processing of the CEFS output files. There are 

revised summaries (emissions by county as well as emissions by county and EIC 
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category). There are revised modeling files. All the summaries and modeling files for 

the revised point and area sources contain the date the version was revised, V050503. 

b) There have been changes to the list of species in both the CB-IV and SAPRC 

chemistries. These changes relate to whether certain species are treated explicitly or 

are lumped together with other species. The species are methanol (MEOH), ethanol 

(ETOH), MTBE, and methyl butanol (MBUT). The BAAQMD reminded all that changes 

to the speciation will cause the modeling files to change, but not the base CEFS files 

and plots. 

Alpine noted that there are several outdated versions of files on the ftp site that could 

cause confusion to reviewers. They asked if the files could be deleted. ARB requested 

that the files be moved to a different directory to lessen confusion, but retained for now. 

Alpine will look into creating a subdirectory for outdated versions. Space on the ftp site 

may become a concern. 

SMAQMD expressed concern that the day-specific emissions may not be processed 

correctly for begin hour codes of “-1”, which indicate that the emissions are in kg/day 

rather than kg/hour. This may cause the emissions to be underestimated. ARB will 

investigate. 

BAAQMD noted that some of the day-specific data recently submitted for the Bay Area 

contained emissions for only certain hours of the day, not the entire day. Following a 

discussion with Alpine on the methodology for processing the data, BAAQMD was 

satisfied that the data are being processed correctly. 

Comments on Alpine Geophysics’ Report on the Integrated Transportation 

Network 

Alpine Geophysics has placed the raw data files that they used to create the ITN on 

their FTP site. Each network is contained in its own zip file. The zip files are located in 

the directory "ITN_2000/Raw Data Used To Develop ITN." The name of the zip files 

states their relation to the network. ARB noted that the SACOG file was missing; Alpine 

will post Sacramento to the ftp site. 

Alpine also posted a zip file on the FTP site that contains all the documentation and 

supporting data sets for the gravity model used in the Integrated Transportation Network 

(ITN). The file is called “ucd_gravity.zip” and is located in the "ITN_2000/Commercial 

VMT Gravity Model" directory. The gravity model estimates commercial VMT based on 

trip counts for 2, 3, 4, and 5 axle vehicles. The model uses AADT data from Caltrans 

and apportions trip counts across the domain. Alpine noted that the commercial VMT 

using the gravity model was only applied to the portions of the ITN developed with the 

Caltrans statewide model; local transportation networks already include commercial 

VMT. 
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Alpine plans to provide a draft final version of the ITN report on May 23. Alpine will 

notify the group when the report is available. 

Earth Matters asked when Alpine would be responding to their questions about the ITN. 

Alpine hopes to complete their response by the end of the week. 

Earth Matters asked if ARB still wants the latest COG data since it may not be used in 

the ITN for SIP modeling. ARB would like the data since ARB is creating its own ITN for 

uses other than SIP modeling. The alternate ITN would be on a different grid system 

than CCOS, using a Teale Albers projection. Earth Matters said they would request the 

data from the TPAs. 

The BAAQMD mentioned that the time profiles in the on-road inventory of the modelready files show a noontime “dip” in emissions on the weekend. Alpine pulled up the 

data and said that the “dip” is caused by the day-specific data that were developed by 

Dr. Niemeier of UC Davis. The data show a 1-2 hour decrease in emissions around 

noon and then a return to previous levels. Alpine will post the UC Davis information to 

the ftp site. Alpine will also post information that was generated to QA the ITN that may 

be helpful to other reviewers. 

Other Issues 

No other issues were raised. 

Plans for Next Meeting 

The next conference call is scheduled for Wednesday, June 4. 
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D.9.7 June 4, 2003 

Attendees Affiliation 

Phil Martien, Amir Fanai Bay Area AQMD 

Charles Anderson, Matt Jones, Bruce Katayama, 

Greg Tholen Sacramento Metro AQMD 

David Nunes, Stephen Shaw, Michelle Stanley, 

Jim Sweet 

San Joaquin Valley Unified 

APCD 

Harold Brazil MTC 

Leonard Seitz Caltrans 

Cari Anderson Earth Matters 

Cyndi Loomis, Jim Wilkinson Alpine Geophysics 

Paul Allen, Vernon Hughes, Tess Sicat, Cheryl 

Taylor, Bruce Tuter, Ed Yotter ARB 

Welcome and Feedback on May 21 Minutes 

ARB welcomed everyone to the call. Introductions were made. The May 21 and 

revised May 7 minutes were approved as written. 

Data on Ftp Site 

Very little new information was posted to Alpine Geophysics ftp site since the last call. 

[To access the site, ftp to agftp.com (host name). The user ID is agftp and the 

password is pass4ftp.] When reviewing the various files on the ftp site, check the 

Version Control Log to determine the version you wish to review. The 

Version_Control_Log (found under CCAQS_Emissions/July 2000/Modeling_Files) 

describes the reason for each revision and the revision number. 

Alpine will be posting revised area and point source modeling files. A small amount of 

emissions were being left out because some SIC/SCC combinations were missing a 

speciation profile assignment. Alpine and ARB should have the problem corrected 

soon. 

In previous meetings, SMAQMD expressed concern that the day-specific emissions 

may not be processed correctly for begin hour codes of “-1”, which indicate that the 

emissions are in kg/day rather than kg/hour. This may cause the emissions to be 

underestimated. SMAQMD also expressed concern that emissions reported for multiple 

hours (rather than a single hour at a time) were being treated for only the first hour. 

Alpine and ARB investigated the concerns and discovered that SMAQMD was correct. 

Alpine modified the program to read multiple hours and reformatted the emissions 

reported with a “-1” to be hourly emissions. The day-specific emissions are now being 

processed correctly. 
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Comments on Integrated Transportation Network (ITN) Report 

Alpine hopes to complete the draft final ITN report by June13. The group will be notified 

when it is available for review. 

Alpine provided a response on June 3 to comments submitted by Earth Matters on the 

ITN report. Earth Matters said that they had a couple of questions (editorial comments) 

about the response. Earth Matters plans to talk to the San Joaquin Valley APCD 

(SJVUAPCD) and provide a response to Alpine and ARB the week of June 9. Alpine 

plans to include the response to Earth Matters’ comments in the ITN report. 

The SJVUAPCD staff continued to express concern about the statewide network being 

used for the four northern counties of the SJV rather than local transportation networks 

in the ITN. SJVUAPCD staff has raised the concern to their management. [As a 

reminder, Stanislaus provided information that couldn’t be incorporated and the other 

three counties did not respond at the time when Alpine gathered the local data for use in 

the ITN.] 

Earth Matters will continue to work with Ed Yotter to provide local networks to the ARB. 

At the last meeting, the BAAQMD mentioned that the time profiles in the on-road 

inventory of the model-ready files show a noontime “dip” in emissions on the weekend. 

Alpine mentioned that the “dip” is caused by the day-specific data that were developed 

by UC Davis. The BAAQMD reminded Alpine to post information that was used to QA 

the ITN, which may be helpful to other reviewers. Alpine will post the information. The 

BAAQMD also posted animations showing diurnal profiles of Bay Area traffic counts on 

the ftp site under CCAQS_Emissions\July 2000\Animations. 

Other Issues 

No other issues were raised. 

Plans for Next Meeting 

The next conference call is scheduled for Wednesday, June 25. 
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D.9.8 June 25, 2003 Minutes 

Attendees Affiliation 

Charles Anderson, Matt Jones, Bruce Katayama, 

Greg Tholen, Brigette Tollstrup Sacramento Metro AQMD 

David Nunes, Stephen Shaw, Michelle Stanley, 

Jim Sweet 

San Joaquin Valley Unified 

APCD 

Bob Nunes Monterey Bay Unified APCD 

Wayne Luney Caltrans Headquarters 

Sally Rodeman Caltrans, District 10 

Cari Anderson Earth Matters 

Cyndi Loomis, Jim Wilkinson Alpine Geophysics 

Chris Emery Environ 

Vernon Hughes, Tess Sicat, Cheryl Taylor, Ed 

Yotter ARB 

Welcome and Feedback on June 4 Minutes 

ARB welcomed everyone to the call. There were two comments on the June 4 minutes. 

First, the minutes stated “Earth Matters will continue to work with Ed Yotter to provide 

local networks to the ARB.” Earth Matters noted that ARB has stated that they are not 

ready to collect networks at this time. Second, Earth Matters expressed concern about 

the statement in Section 3: “[As a reminder, Stanislaus provided information that 

couldn’t be incorporated and the other three counties did not respond at the time when 

Alpine gathered the local data for use in the ITN.] Earth Matters thought it might be 

better to say that local data were used for four of the eight counties in the SJV. 

Data on Ftp Site 

Alpine Geophysics reported that information for the September 2000 episode is 

available on the ftp site. [To access the site, ftp to agftp.com (host name). The user ID 

is agftp and the password is pass4ftp.] CEFS output files, summaries, plots, 

intermediate SAS files, and modeling files are available for review. 

The temperature and relative humidity fields used to calculate the on-road motor vehicle 

and biogenic emissions have been posted to the ftp site. 

Revised CEFS files (base year and future years) have been provided by ARB for the 

July/August 2000 episode. Alpine is processing these emissions to create modeling 

files for 2005, 2006, 2007 and 2010. Alpine will post these files to the ftp site this week 

and will generate several reports, including emission summaries by county and EIC as 

well as summaries of speciated emissions for each episode day. 
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ARB is developing the gridded on-road motor vehicle files for the future years needed 

for the July/August 2000 episode. ARB plans to provide these files next week to Alpine, 

who will speciate the emissions. 

In previous meetings, SMAQMD expressed concern that some of the day-specific 

emissions were not being processed correctly. The problems have now been corrected. 

The day-specific data are being incorporated correctly as the inventories are being 

reprocessed with the latest emission data. 

The June 4 minutes reported a small underreporting of emissions due to missing 

speciation profile assignments. This problem has now been corrected. Additionally, 

ARB has provided Alpine with speciation profiles for all the future years. 

SJVUAPCD asked whether the modeling emission files reflect Pacific Daylight Time 

(PDT) or Pacific Standard Time (PST). ARB responded that emissions are usually 

handled in PDT because the temporal profiles of business activities follow local time 

(e.g. a business starts operating at 8 am, regardless of which time base it is). Air quality 

modelers need to be aware that they may need to convert emission data from PDT to 

PST. 

Comments on Integrated Transportation Network (ITN) Report 

Alpine Geophysics is working on the draft final ITN report. The group will be notified 

when it is available for review. 

Previously, Alpine provided a response to comments submitted by Earth Matters on the 

ITN report. Earth Matters provided verbal comments to ARB. ARB will work with Alpine 

to incorporate the comments. Alpine plans to include the response to Earth Matters’ 

comments in the ITN report. 

SJVUAPCD continued to express concern about the statewide network being used for 

the four northern counties of the SJV rather than local transportation networks in the 

ITN. SJVUAPCD would like to see all the local SJV networks included in the ITN in time 

for modeling work to develop future year control strategies for the 1-hour ozone SIP. 

SJVUAPCD is considering options to provide an updated ITN for all or part of the SJV, 

perhaps by the middle of July. SJVUAPCD will discuss a course of action for improving 

the ITN with ARB when a decision has been made, hopefully by the end of the week. 

The entire group agreed that it is important to keep moving forward to update the ITN. 

ARB noted that there is insufficient time to update the ITN and recreate the motor 

vehicle inventories in time for base year model performance, as it will be completed 

shortly. ARB reminded the group that the ITN is only used as a sophisticated spatial 

surrogate; emission estimates for each county come from EMFAC. ARB suggested that 

the difference between the local networks and the statewide network could be 
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assessed. This could be done in GIS by overlaying the 4 kilometer modeling grid over a 

local network and summing the VMT by grid cell. The result could be compared to the 

sum of the VMT by grid cell from overlaying the modeling grid over the statewide 

network. Comparing the VMT by grid cell would quantify the difference between the 

local and statewide networks to see if the spatial distribution would be changed 

significantly. 

Alpine Geophysics will be providing training on how the ITN was developed to ARB and 

other interested parties in Sacramento on July 1, 2, and 3. SJVUAPCD and Earth 

Matters requested information on the training. 

There was some discussion about how each period (for example, am and pm peaks) 

was distributed on the ITN. Alpine agreed to post a table on their ftp site that lists each 

county and the hours that each period represents. This table was developed based on 

data that were provided to Alpine by the local transportation agencies. 

As requested at the June 4 meeting, Alpine posted on their ftp site a comparison of 

weekday and weekend VMT for each county between the UC Davis data, the ITN data, 

and the DTIM data. The BAAQMD had previously noted that the time profiles in the onroad inventory showed a noontime “dip” in emissions on the weekend, which reflected 

the day-specific data that were developed by UC Davis. 

Other Issues 

No other issues were raised. 

Plans for Next Meeting 

The next conference call is scheduled for Wednesday, July 9. 
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D.9.9 July 30, 2003 Minutes 

Attendees Affiliation 

Phil Martien, Toch Mangat Bay Area AQMD 

Charles Anderson, Bruce Katayama, Greg 

Tholen Sacramento Metro AQMD 

David Nunes, Stephen Shaw, Michelle Stanley, 

Jim Sweet 

San Joaquin Valley Unified 

APCD 

Leonard Seitz Caltrans Headquarters 

Cari Anderson Earth Matters 

Cyndi Loomis Alpine Geophysics 

Vernon Hughes, Tess Sicat, Cheryl Taylor, Bruce 

Tuter ARB 

Welcome and Highlights of July 9 Meeting 

ARB welcomed everyone to the call. ARB summarized the items discussed at the July 

9 meeting. The following paragraph will serve as the minutes of the July 9 meeting. 

July 9 Meeting Highlights

Participants represented the Bay Area, Sacramento and San Joaquin districts, Alpine 

Geophysics, and ARB. Alpine stated that they are producing future year modeling 

inventories for the CCOS base case modeling for the July/August 2000 and September 

2000 episodes. Alpine staff are also producing base year and future year modeling 

inventories for the July 1999 episode for the Bay Area AQMD and the August 2002 

episode for the Sac Metro AQMD. Alpine is progressing on the final ITN report. The 

Bay Area mentioned that they had reviewed the data regarding the period definition 

spreadsheet that Alpine had posted on their ftp site (see the June 15 minutes). 

Update on Status of Gridded Inventory 

Alpine Geophysics reported on the status of the gridded inventories. ARB provided 

revised point and area source CEFS files for all episodes to Alpine on July 10. Alpine 

has reprocessed the CEFS files to create revised modeling files for point and area 

sources. The files are for the base year and future years for the July/August 2000, 

September 2000, and August 2002 episodes. The file names will contain 

“V071003_R001”. The revised future year files were inadvertently placed under the 

CCAQS_Emissions/July_2000/Modeling_Files directory, rather than the 

CCAQS_Emissions/July_Aug_FY/Modeling_Files directory. Alpine will generate 

summary reports when time is available. 

Regarding the status of on-road motor vehicle emissions, the modeling files for 2005 

and 2006 for the July/August episode will be ready on August 4. ARB will be providing 
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files for 2010 to Alpine for processing in the next two to three weeks. ARB will also be 

providing files for all future years for the September 2000 episode to Alpine for 

processing in the next two to three weeks. Modeling files for the base year September 

2000 episode are posted on the ftp site. 

The point, area, and biogenic files for the July 1999 episode (base year) will be 

completed and posted the week of August 4. The motor vehicle files will be ready the 

following week. 

The version control log has been updated to reflect the available files (found under 

CCAQS_Emissions/July_2000/Modeling_Files). The version control log also describes 

the various versions of the CBIV and SAPRC chemical mechanisms. Please check the 

version control log for a description of each modeling file. 

Update on Wildfire Emissions 

ARB reported that at the last CCOS Technical Committee (TC) meeting, Gail Tonnesen 

of UCR mentioned that the day-specific wildfire emissions (in particular, the Manter fire 

in southeast Tulare County) had a large effect on model performance. The TC asked 

how the emissions were being treated in the model and if anyone had information on 

alternative methods that could be used, particularly in distributing the emissions 

vertically. UC Berkeley’s Center for the Assessment and Monitoring of Forest and 

Environmental Resources (CAMFER) laboratory calculated the emissions in 

consultation with ARB’s Emission Inventory Branch. [More information on CAMFER 

can be found at: http://camfer.cnr.berkeley.edu/fire/]. Vertical stratification of emissions 

was done using a method developed for the Fire Emissions Joint Forum (FEJF) of the 

Western Regional Air Partnership (WRAP). ARB will distribute these methodologies to 

the group and post them on Alpine’s ftp site. The group was asked to provide any 

additional information they may have. 

Other Issues 

ARB will contact Alpine Geophysics to estimate a date for the availability of the final ITN 

report; ARB will notify the group. 

Caltrans staff asked about the purpose of the ITN training that Alpine gave in early July. 

ARB explained that the contract with Alpine specified that Alpine would provide handson training to ARB. The purpose was to allow ARB to understand firsthand the method 

used to develop the ITN and to do a technology capture for future use by ARB. 

Caltrans staff asked about any efforts to coordinate/organize future updates to a new 

ITN, such as incorporating a revised state travel model or more local COG data. No 

formal coordination has been established; however staff at ARB and Caltrans seemed 

willing to keep the lines of communication open. 
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Bay Area staff mentioned that they had reviewed the hourly profiles developed by UC 

Davis and noticed that cars and trucks were lumped together. ARB reported that UCD 

did not have sufficient data to warrant the development of distinct hourly profiles that 

were statistically significant. 

San Joaquin Valley staff asked if day-specific train data were included in the CCOS 

modeling. SJV staff recalled that train traffic was closed west of the mountains between 

the ocean and valleys during the July/August 2000 episode that may have increased the 

number of trains operating in the valley. ARB and SJV will investigate sources of 

information. 

San Joaquin Valley staff requested that ARB provide the day-specific data that were 

used in CCOS modeling, for documentation purposes. ARB will send the data. 

Plans for Next Meeting 

The next conference call is scheduled for Wednesday, August 13. 
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D.9.10 August 13, 2003 Minutes 

Attendees Affiliation 

Phil Martien Bay Area AQMD 

Charles Anderson, Matt Jones, Bruce Katayama, 

Greg Tholen Sacramento Metro AQMD 

David Nunes, Stephen Shaw, Michelle Stanley, 

James Sweet 

San Joaquin Valley Unified 

APCD 

Harold Brazil MTC 

Leonard Seitz Caltrans Headquarters 

Cari Anderson Earth Matters 

Cyndi Loomis, Jim Wilkinson Alpine Geophysics 

Chris Emery Environ 

Vernon Hughes, Tess Sicat, Cheryl Taylor, Ed 

Yotter ARB 

Welcome and Feedback on July 30 Meeting 

ARB welcomed everyone to the call. ARB summarized the items discussed at the 

July 9 meeting. The July 30 minutes were approved as written, with one clarification. 

The version control log (described in Section 2) applies specifically to the July/August 

2000 episode, although the naming convention of the files is consistent between 

episodes. 

Update on Status of Gridded Inventory 

Alpine Geophysics reported on the status of the gridded inventories: 

July/August 2000 episode – Point and area source modeling files are completed for the 

base year and future years (2005, 2006, and 2010). Biogenics files are completed. Onroad motor vehicle files are completed except 2010, which should be ready next week. 

September 2000 episode – Point and area source modeling files are completed for the 

base year and future years (2005, 2006, and 2010). Biogenics files are completed. Onroad motor vehicle files are available for the base year. Alpine said that the future year 

files for on-road motor vehicles are completed; they will double-check since they are not 

posted on the ftp site. 

July 1999 episode – Point, area, and biogenic modeling files are completed for the base 

year. On-road motor vehicle files for the base year are currently being processed. 

August 2002 episode – Point and area source modeling files are completed for the base 

year and future years (2005, 2007, 2008, 2010, 2012, and 2018). Biogenics files are 
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completed. On-road motor vehicle files for the base year will be completed in the next 

week, and subsequently followed by each future year every 2 or 3 days. 

Discussion of Wildfire Emissions 

As mentioned on the July 30 call, ARB reported that Gail Tonnesen of UCR mentioned 

at the last CCOS Technical Committee (TC) meeting that the day-specific wildfire 

emissions (in particular, the Manter fire in southeast Tulare County) had a large effect 

on model performance. In particular, Gail expressed concern that the emissions from 

the Manter fire were not distributed nearly high enough (i.e. there were not enough 

emissions aloft). The TC asked how the emissions were being treated in the model and 

if anyone had information on alternative methods that could be used, particularly in 

distributing the emissions vertically. UC Berkeley’s CAMFER laboratory calculated the 

emissions in consultation with ARB’s Emission Inventory Branch. Vertical stratification 

of emissions was done using a method developed for the Fire Emissions Joint Forum of 

the WRAP. Alpine Geophysics provided a document that described the development of 

stack parameters and vertical distributions for modeling large wildfires in the CCOS 

domain. ARB distributed these methodologies to the group and posted them on 

Alpine’s ftp site. 

The group discussed the methodology for distributing emissions vertically, based on the 

information mentioned above. The vertical distribution of emissions is determined by 

the size of the fire. Members of the group expressed concern that the method that 

Alpine used limited the size of the fire to the number of acres in a 4 kilometer grid cell, 

and therefore limited the vertical distribution. Alpine agreed to revisit the methodology 

using the entire size of the fire for the day. 

The group also discussed wildfire emissions in future year inventories, which are not 

normally included. ARB will put together some initial thoughts on a protocol to handle 

wildfire emissions in future year modeling. 

Biogenic Emissions 

Alpine Geophysics received biogenic emissions from ARB for the January 2000 

episode. Alpine requested the precise date, start times, and time coordinates for that 

episode. ARB will provide that information. 

Bay Area staff asked about the VOC emissions on August 1 of the July/August 2000 

episode since they appeared different than the other days of the episode. They stated 

that the emissions are fairly high at night and there was a dip in the emissions about 1 

p.m. across the entire domain. Bay Area staff agreed to post animations of the biogenic 

emissions for August 1. Alpine mentioned that the temperature fields used to calculate 

the emissions are posted on the ftp site. Staff from the Bay Area, Alpine Geophysics, 

and ARB agreed to look at the temperature fields and the biogenic emissions. The 
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group was reminded that isoprene and methylbutenol (MBO) emissions are sensitive to 

light and temperature, whereas monoterpene emissions are only sensitive to 

temperature. 

ARB mentioned that SJV staff has expressed concern about the latest biogenic 

emissions since they are very different than the biogenic estimates made during 

SARMAP. ARB will discuss the concern further with SJV staff. 

Other Issues 

After receiving the day-specific data requested from ARB, San Joaquin Valley staff 

commented that they had not provided day-specific data for CRPAQS. SJV staff will 

investigate what information they can provide. 

Bay Area staff requested conversion programs between latitude/longitude, UTM 

coordinates, and Lambert Conformal coordinates. Alpine Geophysics and Environ 

agreed to work with the Bay Area to provide conversion programs. 

Plans for Next Meeting 

The next conference call is scheduled for Wednesday, September 3. 
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D.9.11 September 3, 2003 Minutes 

Attendees Affiliation 

Phil Martien, Toch Mangat, Amir Fanai Bay Area AQMD 

Charles Anderson, Matt Jones, Bruce Katayama, 

Greg Tholen Sacramento Metro AQMD 

David Nunes, Stephen Shaw San Joaquin Valley Unified 

APCD 

Leonard Seitz Caltrans Headquarters 

Cari Anderson Earth Matters 

Cyndi Loomis, Jim Wilkinson Alpine Geophysics 

Vernon Hughes, Tess Sicat, Cheryl Taylor, Bruce 

Tuter, Ed Yotter ARB 

Welcome and Feedback on August 13 Meeting 

ARB welcomed everyone to the call. The August 13 minutes were approved as written. 

Update on Status of Gridded Inventory 

ARB shared with the group a tracking sheet that shows the status of CCOS and 

CRPAQS modeling inventories. The group suggested changes and updates. ARB will 

send out this sheet along with the agenda for future conference calls. 

Alpine Geophysics reported on the status of the gridded inventories: 

July 1999 episode – Point, area, biogenic, and on-road motor vehicle modeling files are 

completed for the base year. Biogenics modeling files for the base year are also used 

as is for all future years (this applies to all episodes). Point and area modeling files for 

future years should be available next week. On-road motor vehicle files are available 

for 2005 and 2007. The group discussed which future years were needed for modeling; 

there was agreement on 2005, 2006, 2007 and 2010. 

July/August 2000 episode – Point and area source modeling files are completed for the 

base year and future years (2005, 2006, and 2010). Biogenics files are completed. Onroad motor vehicle files are available for all years. 

September 2000 episode – Point, area, biogenic, and on-road motor vehicle modeling 

files are completed for the base year and future years (2005, 2006, and 2010). 

August 2002 episode – Point and area source modeling files are completed for the base 

year and future years (2005, 2007, 2008, 2010, 2012, and 2018). Biogenics files are 

completed. On-road motor vehicle files for 2002, 2005, 2007, and 2008 are completed; 

the remaining future years are planned for completion next week. 
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Discussion on Wildfire Emissions 

After discussion at the previous meeting, Alpine Geophysics revised the methodology 

for calculating the vertical distribution of fire emissions based on the entire size of the 

fire for the day rather than limiting the size of the fire to the number of acres in a 4 

kilometer grid cell. The revised files are available on Alpine’s ftp site. 

Various members of the group have gathered information on wildfires. Staff from the 

San Joaquin Valley and Bay Area agreed to send ARB information, who will distribute it 

to the group. Alpine recently presented information on wildfires that occurred during the 

July 1999 and July/August 2000 episodes; ARB will also distribute this to the group. 

The group also discussed wildfire emissions in future year inventories. ARB will present 

information gathered about wildfire emissions at a future conference call of either this 

group or an all-district modeling call. ARB will also put together some initial thoughts on 

a protocol to handle wildfire emissions in future year modeling. 

Biogenic Emissions 

Bay Area staff asked about the VOC emissions on August 1 of the July/August 2000 

episode since they appeared different than the other days of the episode. In particular, 

the emissions are fairly high at night and there was a dip in the emissions about 1 p.m. 

across the entire domain. Alpine Geophysics and ARB agreed to look at the biogenic 

emissions and the temperature fields used to develop the emissions. 

ARB has two documents related to biogenic emissions that they will distribute to the 

group. The first is a one-page overview of biogenic VOC emissions using the BEIGIS 

model. The second is a detailed description of the development of a biogenic 

hydrocarbon emission inventory for CCOS. 

Alpine estimated biogenic NO emissions. These emissions were added to the 

emissions estimated by ARB using BEIGIS for the July 1999, August 2002, and 

July/August 2000 episodes. Biogenic NO has not been added to the September 2000 

episode. ARB will add a column for biogenic NO to the tracking sheet for SIP modeling 

inventories. 

Alpine used a soil NO algorithm found in BEIS-3 to estimate biogenic NO for modeling 

purposes. This estimate is about double a previous estimate from UC Berkeley, which 

is within the uncertainty of the estimation technique. ARB is looking into potential data 

sources or methods that could be used to validate the emission estimates, such as 

using California-specific data. 
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Other Issues 

Alpine Geophysics mentioned that they hoped to resume work on the final Integrated 

Transportation Network (ITN) report soon; a final product is possible in the next two 

weeks. 

Earth Matters asked if updates to VMT on local transportation networks would be used 

since the final modeling inventories will soon be completed. ARB replied that updates 

to the VMT could result in changes to EMFAC. For the development of on-road motor 

vehicle modeling inventories, the ITN is used as a surrogate to spatially distribute 

EMFAC emissions. Revised emission estimates from EMFAC could be used in 

developing attainment targets over the next few months. Earth Matters will be sending 

a letter to ARB providing updates to VMT for the SJV COGs. 

Staff from the Bay Area informed the group that Dr. Rob Harley (UCB) recently 

completed a draft report that applies a fuel-based emissions inventory method to 

estimate CO, NOx, and NMOC on-road motor vehicle emissions in the Sacramento 

Valley, San Joaquin Valley, and the Bay Area. In the report, the fuel-based method is 

compared to EMFAC totals for the same areas. ARB will distribute the report to the 

group. 

It was noted that the emissions summaries produced by Alpine Geophysics have not 

been updated to reflect revisions to the modeling inventories, especially for the 

July/August 2000 episode. Alpine will rerun emission summaries, as time becomes 

available. 

Plans for Next Meeting 

The next conference call is scheduled for Wednesday, September 17. 
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D.9.12 September 17, 2003 Minutes 

Attendees Affiliation 

Phil Martien, Toch Mangat, Amir Fanai Bay Area AQMD 

Bob Nunes Monterey Bay Unified APCD 

Charles Anderson, Bruce Katayama, Greg 

Tholen, Brigette Tollstrup Sacramento Metro AQMD 

Donald Hunsaker, Stephen Shaw, Evan Shipp, 

Michelle Stanley 

San Joaquin Valley Unified 

APCD 

Leonard Seitz Caltrans Headquarters 

Cari Anderson Earth Matters 

Cyndi Loomis, Jim Wilkinson Alpine Geophysics 

Vernon Hughes, Ravi Ramilingam, Klaus Scott, 

Tess Sicat, Cheryl Taylor, Bruce Tuter, Ed Yotter ARB 

Welcome and Feedback on September 3 Meeting 

ARB welcomed everyone to the call. Additional clarification was added to the second 

paragraph under “Other Issues” of the September 3 minutes. Earth Matters clarified 

that the updates to VMT were in response to an 8/15/03 letter from ARB requesting 

review. A letter had been sent to ARB providing comments on the VMT for the SJV 

COGs indicating that four VMT totals needed adjustment. 

Update on Status of Gridded Inventory 

The group reviewed the latest tracking sheet prepared by ARB that shows the status of 

the CCOS modeling inventories. Alpine Geophysics mentioned that they have removed 

all but the most current versions of the modeling files on the ftp site; all the previous files 

will be sent to ARB on tape and are available if anyone needs them. No other files were 

removed. 

Alpine reported on the status of the gridded inventories: 

July 1999 episode – Point, area, biogenic, and on-road motor vehicle modeling files are 

completed for the base year. Biogenics modeling files for the base year are also used 

for all future years (this applies to all episodes). Point and area modeling files are 

available. On-road motor vehicle files are available for the base year, 2005 and 2007. 

On-road motor vehicle modeling files for 2006 and 2010 will be available in the next 

couple of days. 

July/August 2000 episode – Point source modeling files are completed for the base year 

(2000) and future years (2005, 2006, and 2010). The base year (2000) area source 

modeling files have been updated to include day-specific shipping emissions provided 

by the BAAQMD; the revised files will be posted soon. Area source modeling files for 

future years remain unchanged since mid-August. Biogenic modeling files have been 
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revised to correct the error found in the isoprene emissions (see below, section 4. 

Biogenic Emissions). On-road motor vehicle files are available for all years. Revised 

summary reports for point and area sources (by county and EIC) that reflect the latest 

inventories will be posted shortly. 

September 2000 episode – Point, area, biogenic, and on-road motor vehicle modeling 

files are completed for the base year (2000) and future years (2005, 2006, and 2010). 

Biogenic NO emissions have not been included in the biogenic modeling files for this 

episode. 

August 2002 episode – Point, area, biogenic and on-road motor vehicle modeling files 

are completed for the base year (2002) and future years (2005, 2007, 2008, 2010, 2012 

and 2018). 

July 1990 episode – Sacramento Metro AQMD mentioned that some modeling files are 

available for this episode. They requested that the tracking sheet be updated to reflect 

this information and report the vintage of the data. 

Discussion on Wildfire Emissions 

The group discussed the treatment of wildfire emissions in future year inventories. 

Options discussed by the group included: 

Leave the wildfires out of future year modeling (done in past modeling work) 

Include the base year wildfires in the future year modeling (same as the base year) 

Include an average value of emissions based on some number of past years (e.g. 20 

years, 40 years); possibly use map fire return intervals to determine the most likely 

place for fires to occur 

Use a similar method for wildfires to what is being considered by the WRAP for the 

treatment of prescribed fires (Environ is reportedly looking into this) 

Swap out day-specific wildfire emissions for different episodes to determine the effect of 

fires (e.g. swap fires in August 2000 with fires in August 2002) 

Treat in initial conditions/boundary conditions 

Participants on the call were encouraged to send to ARB their conceptual solutions or 

approaches on how to handle wildfire emissions in future year modeling. ARB will 

summarize the information gathered and provide it to the group for discussion at a 

future conference call. 

Biogenic Emissions 

Bay Area staff had previously asked about the VOC emissions on August 1 of the 

July/August 2000 episode since the hourly distribution appeared different than the other 

days of the episode. In particular, the emissions are fairly high at night and there was a 
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dip in the emissions about 1 p.m. across the entire domain. Upon review by Alpine 

Geophysics and ARB, it was discovered that an error had occurred in the processing of 

the isoprene emissions for August 1. The problem only affected isoprene and only that 

day was affected. Alpine has corrected the problem and posted revised modeling files 

on the ftp site. ARB has rerun the air quality model with the revised file and noticed 

about a 1 ppb difference on August 1. 

As mentioned previously, Alpine Geophysics has estimated biogenic NO emissions. 

These emissions were added to the biogenic emissions estimated by ARB using 

BEIGIS for the July 1999, August 2002, and July/August 2000 episodes. Biogenic NO 

emissions have not been added to the September 2000 episode. The tracking sheet for 

SIP modeling inventories has been updated to reflect whether biogenic NO has been 

added or not to the modeling inventories. 

Alpine used a soil NO algorithm found in BEIS-3 to estimate biogenic NO for modeling 

purposes. This estimate is about double a previous estimate from UC Berkeley, which 

is still within the uncertainty of the estimation technique. ARB is looking into potential 

data sources or methods that could be used to validate the emission estimates such as 

using California-specific data. This latest biogenic NO estimate is about 2-3% of the 

total NOx emissions in the domain. ARB is also modeling with and without biogenic NO 

to determine its impact on ozone concentrations. Once the sensitivity to biogenic NO 

emissions has been determined, ARB will consider whether to modify the new biogenic 

NO estimates or leave them as estimated by Alpine Geophysics. 

Other Issues 

Alpine Geophysics mentioned that the final Integrated Transportation Network (ITN) 

report has not been completed. 

Previously, ARB distributed a draft report by Dr. Rob Harley (UCB) that applies a fuelbased emissions inventory method to estimate CO, NOx, and NMOC on-road motor 

vehicle emissions in the Sacramento Valley, San Joaquin Valley, and the Bay Area. 

The fuel-based method is compared to EMFAC totals for the same areas. ARB will 

compile any comments that members of the group would like to provide. 

Dr. Harley’s report suggests that NOx emissions from diesel engines could be 

underestimated in the San Joaquin Valley. Staff from the SJVUAPCD added that 

emissions from seasonal heavy-duty diesel trucks might not be fully captured in the 

current on-road motor vehicle inventory. Many of these trucks only operate two months 

of the year and only travel on local or collector roads. However, little information is 

available on which to base emission estimates. 

ARB staff mentioned that they are looking at a recent heavy-duty truck survey 

completed by Caltrans. ARB staff is comparing VMT estimates from EMFAC with those 
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from the survey. Preliminary findings are that the statewide VMT in EMFAC are in fairly 

good agreement with the survey, but that the distribution of VMT by region is different. 

ARB staff is continuing to investigate. The representative from Earth Matters mentioned 

that the SJV COGs are working on a truck model that will include commodity flow. The 

COGs hope to have a working version of the model in the next few months; the status of 

the model will be given at the next conference call. The topic of heavy-duty truck 

emissions will be added to the agenda. 

BAAQMD staff has been comparing temperature fields used in the models with surface 

temperature observations for the July/August 2000 episode. BAAQMD staff observed 

that the temperatures developed through objective analysis by ARB look low compared 

to observations at some locations in the Bay Area (i.e. there seem to be “cold holes” 

upwind of Livermore). BAAQMD staff agreed to send the information to ARB for review. 

Plans for Next Meeting 

The next conference call is scheduled for Tuesday, September 30. 
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D.9.13 September 30, 2003 Minutes 

Attendees Affiliation 

Charles Anderson, Bruce Katayama, Brigette 

Tollstrup 

Sacramento Metro AQMD 

David Nunes, Stephen Shaw, Michelle Stanley San Joaquin Valley Unified 

APCD 

Frank Law Caltrans 

Sally Rodeman Caltrans District 10 

Jason Paukovits Fresno COG 

Cari Anderson Earth Matters 

Cyndi Loomis, Jim Wilkinson Alpine Geophysics 

Chris Emery Environ 

Mark Carlock, Vernon Hughes, Klaus Scott, Tess 

Sicat, Cheryl Taylor, Ed Yotter ARB 

Welcome and Feedback on September 17 Meeting 

ARB welcomed everyone to the call. Introductions were made. The September 17 

minutes were approved as written. 

Status of Wildfire and Biogenic Emissions 

ARB gave a status report on wildfire and biogenic emissions. On previous calls, the 

group discussed the treatment of wildfire emissions in future year inventories. Several 

options have been discussed. Participants were encouraged to send to ARB their 

conceptual solutions or approaches to ARB. ARB has received two comments to date; 

comments are still requested. ARB will summarize the information gathered and 

provide it to the group for discussion at a future conference call. 

As mentioned previously, the biogenic modeling file for August 1, 2000 has been 

corrected and posted on Alpine’s ftp site. An error occurred during processing of the 

isoprene emissions that caused the hourly isoprene emissions to be distributed 

incorrectly over that day. ARB has rerun the air quality model with the revised file and 

noticed about a 1 ppb change in ozone concentration on August 1. 

As mentioned previously, Alpine Geophysics has estimated biogenic NO emissions. 

These emissions were added to the biogenic emissions estimated by ARB using 

BEIGIS for the July 1999, August 2002, and July/August 2000 episodes; they were not 

added to the September 2000 episode. 

The biogenic NO emissions estimated by Alpine were about double a previous estimate. 

ARB modeled with and without biogenic NO to determine its impact on ozone 

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ARB will not pursue refinements to the biogenic NO estimates for the SIP modeling for 

the 1-hour ozone standard. The group agreed to add biogenic NO emissions to the 

September 2000 episode for consistency with the other episodes. 

Discussion of Heavy-duty Truck Emissions 

Earth Matters mentioned that an update on the truck model being developed by the San 

Joaquin Valley COGs was distributed to the group along with a draft report that is 

available for review. The truck model is jointly managed by Caltrans and the Fresno 

COG. A final report is scheduled for release in October. A steering committee has 

been organized to determine how the truck model will be used. Comments on the draft 

report can be provided to the Fresno COG. ARB asked if the truck model had been 

compared to EMFAC; Earth Matters will find out if a comparison is planned. ARB also 

asked to be included for receiving more details on the truck model. 

Previously, ARB distributed a draft report conducted under CCOS by Dr. Rob Harley 

(UCB) that applies a fuel-based emissions inventory method to estimate CO, NOx, and 

NMOC on-road motor vehicle emissions in the Sacramento Valley, San Joaquin Valley, 

and the Bay Area. Earth Matters provided comments, which will be included in ARB’s 

comments on the report. At this point, the project stands as an independent, CCOSbased study of on-road motor vehicle emissions and will not directly result in changes to 

EMFAC. 

ARB staff mentioned that they are looking at a recent Caltrans survey of 8200 heavyduty trucks. SJVUAPCD staff asked if the survey captured seasonal trucks since they 

do not normally travel on freeways. ARB responded that they are probably not captured 

in the survey because they were conducted at truck stops. ARB pointed out that the 

heavy-duty emissions from EMFAC are based on DMV registration. As long as they are 

registered, the emissions from seasonal trucks are included in EMFAC. SJVUAPCD 

staff said that the seasonal trucks are registered with DMV. Although the emissions are 

included in EMFAC, the seasonal variation of the emissions is not well represented. 

The activity of these trucks is spread over the entire year. The on-road motor vehicle 

emissions used in modeling for the SIPS may be underestimated. ARB staff has been 

directed by its upper management to investigate the seasonality of on-road motor 

vehicle emissions. ARB staff is to determine whether there is a problem for the SIPs 

and, if so, what is its magnitude. If a problem is determined, ARB will make 

adjustments. ARB staff has been directed to review San Joaquin Valley first; changes 

to other areas will be considered after SJV. SJVUAPCD staff commented that modeling 

results are needed by the first of November. Sac Metro staff expressed similar 

concerns to San Joaquin about the seasonality of emissions; modeling results are 

needed by January 1 for Sacramento. 
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Update on Status of Gridded Inventory 

Alpine reported on the status of the gridded inventories. The version control log (for the 

July/August 2000 episode) is being updated. Revised emission summaries and 

speciated summaries will be posted soon. 

July 1999 episode – Point, area, biogenic, and on-road motor vehicle modeling files are 

completed for the base year. Biogenics modeling files for the base year are also used 

for all future years (this applies to all episodes). Point, area, and on-road motor vehicle 

modeling files are available for 2005, 2006, 2007, and 2010. Point source files have 

been revised and posted for the base year and all future years. It was discovered that 

some large facilities were missing UTM coordinates; the default is for the facility to be 

placed at the center of the county. These large facilities were assigned coordinates and 

the files reprocessed. The updated files have version V092703 in the file name. 

July/August 2000 episode – Point, area, biogenic, and on-road motor vehicle modeling 

files are completed for the base year (2000) and future years (2005, 2006, and 2010). 

As described for the July 1999 episode above, base year and future year point source 

files have been revised and posted. The day-specific file for wildfires in the base year is 

being revised to vertically distribute the emissions of the smaller wildfires. Previously, 

only the two large fires (Manter and Plaskett) had vertical distributions. 

September 2000 episode – Point, area, biogenic, and on-road motor vehicle modeling 

files are completed for the base year (2000) and future years (2005, 2006, and 2010). 

Biogenic NO emissions have not previously been included in the biogenic modeling files 

for this episode; Alpine Geophysics will add biogenic NO. As described for the July 

1999 episode above, base year and future year point source files have been revised 

and posted. The day-specific file for wildfires in the base year is being revised to 

vertically distribute the emissions of the smaller wildfires. 

August 2002 episode – Point, area, biogenic, and on-road motor vehicle modeling files 

are completed for the base year (2002) and future years (2005, 2007, 2008, 2010, 

2012, and 2018). As described for the July 1999 episode above, base year and future 

year point source files have been revised and posted. The day-specific file for wildfires 

in the base year is being revised to vertically distribute the emissions of the smaller 

wildfires. Previously, only the McNally fire had vertical distribution. 

August 1990 episode – Sacramento Metro AQMD mentioned that some modeling files 

are available for this episode. They requested that the tracking sheet be updated to 

reflect this information and report the vintage of the data. 
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Status of Integrated Transportation Network (ITN) Report 

Alpine Geophysics reported that they are continuing to work on the final ITN report. 

ARB reported that the CCOS Technical Committee would like to see the report prior to 

modeling results. ARB asked Alpine to complete the final report in the next two weeks. 

Other Issues 

On previous calls, BAAQMD staff mentioned that they have been comparing 

temperature fields used in the models with surface temperature observations for the 

July/August 2000 episode. BAAQMD staff observed that the temperatures developed 

through objective analysis by ARB look low compared to observations at some locations 

in the Bay Area (i.e. there seem to be “cold holes” upwind of Livermore). BAAQMD staff 

is comparing RAMS, MM5, and ARB’s objective analysis against observations. At the 

request of the BAAQMD, Alpine Geophysics has created new biogenic emissions (using 

BEIGIS) and new on-road motor vehicle emissions using RAMS temperatures. 

Biogenic emissions generally increased about 5% overall in the Bay Area, although 

there was a small drop in isoprene in the first three days of the episode due to 

cloudiness. The rest of the domain showed about a 10% increase in isoprene 

emissions. For the new on-road motor vehicle emissions, there was a general increase 

in emissions with three exceptions: 1) In the Sacramento area, the overall TOG 

emissions were about the same. 2) Also in the Sacramento area, the TOG emissions 

increased in the first three days and decreased in the last three days. 3) In the Bay 

Area, the NOx emissions stayed about the same overall, but TOG increased about 5%. 

Alpine agreed to send ARB the RAMS data. BAAQMD staff is generating graphics that 

can be shared. 

Plans for Next Meeting 

The next conference call is scheduled for Wednesday, October 15. 
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D.9.14 October 15, 2003 Minutes 

Attendees Affiliation 

Phil Martien, Amir Fanai Bay Area AQMD 

Bruce Katayama, Greg Tholen, Brigette Tollstrup Sacramento Metro AQMD 

Donald Hunsaker, Tom Jordan, David Nunes, 

Stephen Shaw, Michelle Stanley 

San Joaquin Valley Unified 

APCD 

Dick Fahey Caltrans District 4 

Sally Rodeman Caltrans District 10 

Frank Law, Wayne Luney, Leonard Seitz Caltrans Headquarters 

Cari Anderson Earth Matters 

Jim Wilkinson Alpine Geophysics 

Klaus Scott, Tess Sicat, Cheryl Taylor ARB 

Welcome and Feedback on September 30 Meeting 

ARB welcomed everyone to the call. Introductions were made. The September 30 

minutes were approved as written. 

Freezing Inventory for SIP Planning 

ARB mentioned that the future year attainment-level inventories for the July/August 

2000 episode need to be frozen. The base case model performance and future base 

case are frozen. This item will be discussed further at the October 20 all-district 

modeling call. 

Discussion of Heavy-duty Truck Emissions 

At previous meetings, the truck model being developed for the San Joaquin Valley 

COGs was discussed. ARB asked if the truck model had been compared to EMFAC. 

The representative from Earth Matters said that she believes that a second document 

exists that discusses emissions; she will send the document to ARB for distribution 

when it becomes available. 

Previously, ARB staff mentioned that they are looking at a recent Caltrans survey of 

8200 heavy-duty trucks. Caltrans staff provided additional information about the survey. 

ARB staff is investigating the use of the Caltrans survey information to possibly 

redistribute heavy-duty truck activity. Currently in EMFAC, emissions from heavy-duty 

trucks are based on DMV registration. 

During earlier calls, members of the group have expressed concern that seasonal truck 

activity is not captured well in EMFAC. Although the emissions from seasonal trucks 

are included in EMFAC since they are registered with DMV, the seasonal variation of 

the emissions is not well represented. ARB staff is investigating the seasonality of on-
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road motor vehicle emissions. Sacramento Metro AQMD staff reported at an earlier call 

that SACOG had studied the seasonal activity of trucks in the Sacramento area. ARB 

has requested information from SACOG and is waiting for a response. In addition to the 

seasonal, temporal variation, the spatial variation would also need to be addressed. 

Update on Status of Gridded Inventory 

ARB reported that few changes have been made since the last call. Following is the 

status of the inventories for each episode. 

July 1999 episode – Point, area, biogenic, and on-road motor vehicle modeling files are 

completed for the base year. Biogenics modeling files for the base year are also used 

for all future years (this applies to all episodes). Point, area, and on-road motor vehicle 

modeling files are available for 2005, 2006, 2007, and 2010. An error has been found in 

the weekend on-road motor vehicle emissions. Revised modeling files will be posted 

soon. The weekday on-road motor vehicle emissions were unaffected. 

July/August 2000 episode – Point, area, biogenic, and on-road motor vehicle modeling 

files are completed for the base year (2000) and future base case years (2005, 2006, 

and 2010). 

September 2000 episode – Point, area, biogenic, and on-road motor vehicle modeling 

files are completed for the base year (2000) and future base case years (2005, 2006, 

and 2010). Biogenic NO emissions have not previously been included in the biogenic 

modeling files for this episode; Alpine Geophysics will add biogenic NO. 

August 2002 episode – Point, area, biogenic, and on-road motor vehicle modeling files 

are completed for the base year (2002) and future base case years (2005, 2007, 2008, 

2010, 2012, and 2018). An error has been found in the weekend on-road motor vehicle 

emissions. Revised modeling files for the weekend only have been posted. The 

weekday on-road motor vehicle emissions remain unchanged. 

August 1990 episode – Sacramento Metro AQMD mentioned that some modeling files 

are available for this episode. They requested that the tracking sheet be updated to 

reflect this information and report the vintage of the data. 

Status of Integrated Transportation Network (ITN) Report 

Alpine Geophysics reported that they plan to post the latest revision to the ITN report by 

October 17. ARB will send a note to the group when the report is available for review. 
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Other Issues 

BAAQMD staff has been comparing temperature fields used in the models with surface 

temperature observations for the July/August 2000 episode. BAAQMD staff observed 

that the temperatures developed through objective analysis by ARB look low compared 

to observations at some locations. BAAQMD staff has prepared a revised temperature 

field that will be ready today. BAAQMD staff has directed Alpine to create revised 

biogenic and on-road motor vehicle emissions estimates to determine the change from 

previous emission estimates. BAAQMD will notify ARB when the revised temperature 

field is available on Alpine’s ftp site. ARB will review the information. 

BAAQMD staff said that they have been comparing the emissions summary reports 

from the ftp site with summer planning emission estimates for the Bay Area for the 

July/August 2000 episode. They expressed concern about the CO and TOG emissions 

for the individual days compared to the emissions estimated by ARB available on the 

web. BAAQMD staff agreed to send ARB and Alpine Geophysics the comparison 

information for investigation. 

The group asked that the status of wildfires be added to the agenda for the next call. 

Plans for Next Meeting 

The next conference call is scheduled for Wednesday, October 29. 
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D.9.15 October 29, 2003 Minutes 

Attendees Affiliation 

Amir Fanai, Toch Mangat, Phil Martien Bay Area AQMD 

Charles Anderson, Bruce Katayama, Brigette 

Tollstrup Sacramento Metro AQMD 

Donald Hunsaker, David Nunes, Evan Shipp, 

Michelle Stanley 

San Joaquin Valley Unified 

APCD 

Harold Brazil MTC 

Wayne Luney, Leonard Seitz Caltrans Headquarters 

Cari Anderson Earth Matters 

Cyndi Loomis Alpine Geophysics 

Vernon Hughes, Doug Ito, Anne Lin, Ravi 

Ramalingam, Tess Sicat, Cheryl Taylor, Bruce 

Tuter, Ed Yotter 

ARB 

Welcome and Feedback on October 15 Meeting 

ARB welcomed everyone to the call. Introductions were made. San Joaquin staff 

asked about the accuracy of the write-up related to “Discussion of Heavy-duty Truck 

Emissions.” After discussion and clarification, the minutes were accepted as written. 

Freezing Inventory for SIP Planning 

ARB described the overall process for SIP modeling. There are three phases. The first 

phase is base-case modeling. Meteorology and emissions are developed to simulate 

as closely as possible the conditions during each day of the episode being modeled. 

Model performance must meet EPA’s criteria for model performance. ARB has 

achieved adequate model performance for the July/August 2000 episode. Once 

adequate base-case model performance is achieved, the model is run using future year 

emissions that reflect growth in emission categories as well as the effect of adopted 

control measures. This second phase is base-case future year modeling. Carrying 

capacity diagrams are developed to aid planners in developing reduction strategies to 

reach the air quality standard. ARB has completed carrying capacity diagrams for the 

July/August 2000 CCOS episode and made this information available to the air districts. 

The third phase is attainment strategy modeling. The model is run using inventories 

that reflect proposed control measures needed to attain the standard. 

ARB is now preparing for attainment modeling (third phase) for the July/August 2000 

CCOS episode. At the end of August and early September 2003, ARB sent letters to 

the districts and COGs requesting any changes to emissions or vehicle activity that 

would be included in attainment strategy modeling runs. ARB did receive some 

changes that will be updated. ARB was asked if the first and second phases will be 

rerun due to changes in the inventory. ARB said no, since adequate model 
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performance has been reached. ARB now considers the inventories for the base-case 

modeling and base-case future year modeling frozen. 

Based upon BAAQMD/ENVIRON modeling, BAAQMD staff have expressed some 

concerns about the base year and future year inventories at previous meetings of this 

group and at Bay Area Modeling Advisory Committee meetings. BAAQMD staff wants 

to resolve their inventory concerns before they move on to attainment strategy runs. 

However, BAAQMD staff acknowledged that time is short for SJVUAPCD staff to meet 

SIP deadlines. 

ARB asked each district when they would need the results of draft and final attainment 

modeling runs. Sacramento Metro staff said that they would need draft runs in late 

January 2004. They will be holding a workshop to discuss proposed control strategies 

in March and would need final attainment modeling runs completed in May. San 

Joaquin Valley staff said that they plan to have a workshop in mid-December and would 

like to have the results of draft attainment runs to share at the workshop. Bay Area staff 

replied that the schedule for the Bay Area is uncertain; they will get back to ARB. 

ARB is developing a spreadsheet for receiving control strategy information from the 

districts. ARB asked who from each district would be the best contact for requesting 

this information. Brigette Tollstrup will be the contact for Sacramento, Stephen Shaw 

will be the contract for San Joaquin, and Jean Roggenkamp will be the contact for Bay 

Area. 

Mobile Source Issues 

ARB presented information to the group related to EMFAC and conformity. EMFAC is 

the official EPA-approved mobile source emission factor model in California. EMFAC is 

used to estimate on-road mobile source emissions for use in SIP development and 

transportation conformity determinations. ARB finished a comprehensive update of 

EMFAC last year (EMFAC2002). While EMFAC will be updated in the future, ARB does 

not have a schedule for an update at this time. Travel activity data from travel model 

output provided by local transportation planning agencies were included as part of the 

EMFAC update, and continue for conformity purposes per federal conformity regulation 

requirements. As a result of the EMFAC model update, many SIPs in California also 

had to be updated. Any additional model changes to EMFAC would require model 

approval by EPA for use in the SIPs and conformity, and could effectively require SIP 

updates. 

As discussed at previous meetings, ARB is studying a Caltrans survey of heavy-duty 

trucks, and will work closely with the districts and COGs prior to an EMFAC model 

update that would incorporate any changes. The Caltrans survey indicates a different 

geographic distribution of heavy-duty truck travel than what is currently in EMFAC2002. 
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Members of the group continue to express concern that seasonal truck activity is not 

captured well in EMFAC, causing summertime emissions to be underestimated. ARB 

staff is investigating the seasonality of on-road motor vehicle emissions, but work is not 

yet completed. Updated activity normally comes from local travel demand models. 

ARB staffs believe that the incorporation of seasonal trends would constitute an EMFAC 

model change. It was suggested that districts who are concerned about this issue 

should elevate their concerns to their planning managers to initiate policy discussions 

with ARB’s management. 

Status of Wildfires 

Since the occurrence and extent of wildfires is unpredictable, ARB will exclude wildfire 

emissions from future year modeling runs. Wildfires have been excluded from the 

future year base-case runs used to develop carrying capacities. This group has 

discussed various options on how to treat wildfires in future year modeling runs (both 

base-case and attainment). Although ARB staff believes that wildfires are likely to occur 

in future years, no one knows when or where they will occur. The Smoke Management 

Plan is intended to reduce the likelihood of wildfires by allowing prescribed burning. 

San Joaquin Valley staff expressed the opinion that this subject needs more discussion 

and that this issue is still not decided. They would like to consider putting some 

average wildfire emissions in the future years. They also asked if sensitivity runs could 

be made with and without fires. ARB staff suggested that districts’ staffs who are 

concerned about this issue should raise the issue for discussion with upper 

management at their districts and ARB. 

Temperature Fields for July/August 2000 Episode 

As mentioned previously, BAAQMD staff observed that the temperatures developed 

through objective analysis by ARB looked low compared to observations at some 

locations for the July/August 2000 episode. As a result, BAAQMD staff prepared an 

alternative temperature field and directed Alpine Geophysics to create revised biogenic 

and on-road motor vehicle emissions estimates. BAAQMD staff reported that there are 

differences in the biogenic and on-road motor vehicle modeling inventories, but the 

impact was not as great as they expected to find. BAAQMD’s temperature field is now 

available on Alpine’s ftp site. ARB will review the information. If the ARB agreed to use 

the BAAQMD’s temperature field, it would used for attainment runs. Base-case 

modeling will not be revisited. ARB will give a status report to the group at the next call 

on the results of its review of the BAAQMD’s temperature field and its possible use in 

attainment runs. 
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Update on Status of Gridded Inventory 

ARB reported that one change had been made since the last call. Following is the 

status of the inventories for each episode. 

July 1999 episode – Point, area, biogenic, and on-road motor vehicle modeling files are 

completed for the base year. Biogenics modeling files for the base year are also used 

for all future years (this applies to all episodes). Point, area, and on-road motor vehicle 

modeling files are available for 2005, 2006, 2007, and 2010. Previously, an error was 

found in the weekend on-road motor vehicle emissions. Revised modeling files have 

been posted. The weekday on-road motor vehicle emissions were unaffected. 

July/August 2000 episode – Point, area, biogenic, and on-road motor vehicle modeling 

files are completed for the base year (2000) and future base-case years (2005, 2006, 

and 2010). 

September 2000 episode – Point, area, biogenic, and on-road motor vehicle modeling 

files are completed for the base year (2000) and future base-case years (2005, 2006, 

and 2010). Biogenic NO emissions have not previously been included in the biogenic 

modeling files for this episode; Alpine Geophysics will add biogenic NO. 

August 2002 episode – Point, area, biogenic, and on-road motor vehicle modeling files 

are completed for the base year (2002) and future base-case years (2005, 2007, 2008, 

2010, 2012, and 2018). 

August 1990 episode – Sacramento Metro AQMD mentioned that some modeling files 

are available for this episode. They requested that the tracking sheet be updated to 

reflect this information and report the vintage of the data. 
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Status of Integrated Transportation Network (ITN) Report 

Alpine Geophysics reported that they plan to post the latest revision to the ITN report by 

November 7. ARB will send a note to the group when the report is available for review. 

Other Issues 

During the last call, BAAQMD staff said that they had been comparing the emissions 

summary reports from the ftp site with summer planning emission estimates for the Bay 

Area for the July/August 2000 episode. They expressed concern about the CO and 

TOG emissions for the individual days compared to the emissions estimated by ARB 

and available on the web. BAAQMD staff sent ARB and Alpine Geophysics the 

comparison information for investigation. ARB staff responded that they had looked at 

the emissions comparisons. ARB staff would send the BAAQMD staff the information 

they had gathered along with an explanation that is hoped to alleviate the BAAQMD’s 

concerns. 

BAAQMD staff expressed concern about the volumes of heavy-duty trucks on 

weekdays versus weekend days. ARB said (this statement was later discovered to be 

incorrect; please see Important Note below) that the only differences between weekday 

and weekend emissions are due to day-specific temperatures and relative humidity 

along with the spatial and temporal variations developed by Dr. Deb Niemeier. 

Otherwise the emissions from EMFAC are the same for weekdays and weekends. The 

BAAQMD has received information from MTC showing reduced volumes of trucks on 

the weekends. Several members of the group expressed concern about the volumes of 

cars and trucks not being adjusted on weekend days. [IMPORTANT NOTE: Since this 

meeting, ARB staff discovered that they were incorrect about the statements made in 

the previous paragraph concerning weekday and weekend on-road motor vehicle 

estimates used in modeling. The following paragraph describes how the motor vehicle 

emissions from EMFAC are adjusted for a weekend day in the modeling inventories. 

ARB staff paraphrased this information from a note by Jim Wilkinson, Alpine 

Geophysics, who developed the ITN and developed the on-road motor vehicle modeling 

files for many of the episodes. 

The on-road motor vehicle emissions are calculated using EMFAC, based on the VMT 

in EMFAC. However, the weekend VMT to weekday VMT ratio from the ITN is used to 

scale the EMFAC emissions to a "weekend" estimate. The ITN is comprised of the 

travel networks that were provided to Alpine Geophysics by CCOS domain 

transportation agencies. Again to reiterate, EMFAC estimates average weekday 

emissions based on VMT that resides in EMFAC. To be more specific, the weekend 

day on-road mobile source CO, TOG, and NOx emissions are less than the weekday 

emissions by roughly 12% (i.e., the weekend days are equal to about 88% of the 

weekday on-road mobile source emissions). The exception is for heavy-duty diesel 

vehicle NOx emissions. Heavy-duty diesel NOx emissions are lower by about 46% on 
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the weekend days. ARB developed the scaling factors (i.e., 0.88 for TOG, NOx, and 

CO with the exception for HDDV NOx being 0.54) based on the ratio of weekend VMT 

to weekday VMT.]

Plans for Next Meeting 

The next conference call is scheduled for Thursday, November 13. 
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D.10 Development of a biogenic hydrocarbon emission 

inventory for the Central California Ozone Study domain. 

D.10.1 Introduction

Author: Klaus I. Scott, California Air Resources Board 

The Biogenic Emission Inventory GIS (BEIGIS) is a spatially and temporally resolved 

biogenic hydrocarbon emissions inventory model developed by the California Air 

Resources Board (CARB) that uses California land use/land cover, leaf mass, and 

emission rate databases within a Geographic Information System (GIS). BEIGIS 

simulates hourly emissions of isoprene, monoterpenes, and 2-methyl-3-buten-2-ol 

(MBO, methylbutenol) at a 1 km2 resolution. Development of BEIGIS has been 

motivated by a need to account for the state’s pronounced plant species diversity and 

landscape heterogeneity. There are approximately 6000 native plant species in 

California (25% of the flora of the continental U.S.) distributed over terrain ranging from 

basins below sea-level to mountain ranges over 3000 m in elevation (Hickman 1993). 

Plant canopies range from scattered and open canopy structures typical of scrublands 

and savannas, to more closed canopies typical of coniferous forests. Terrain gradients 

and proximity to marine influence also give rise to more than a dozen climate zones in 

the state (CEC 1992). These considerations have prompted the CARB to develop 

BVOC emission inventory models specific to California. 

D.10.2 BEIGIS Inputs 

D.10.2.1 Land use/land cover maps 

The initial set of inputs to BEIGIS are GIS-based maps of land use and land cover 

types. A composite land use and land cover GIS map for the Central California Ozone 

Study (CCOS) domain was compiled from several sources in order to provide sufficient 

spatial resolution and accuracy to reflect the heterogeneity of vegetation species in the 

study area.

A biodiversity database and mapping effort undertaken by the U.S. Geological Survey – 

Biological Resources Division, called the Gap Analysis Project (GAP), was selected to 

represent natural areas in the California portion of the CCOS domain (Scott et al. 1993; 

Davis et al. 1995; Chung and Winer 1999). The California GAP database was 

generated from summer 1990 Landsat Thematic Mapper satellite images, 1990 high 

altitude color infrared imagery, vegetation maps based on historical field surveys, and 

other miscellaneous vegetation maps and ground surveys. California’s GAP coverage 

is comprised of approximately 21,000 polygons, aggregated into 272 natural community 

types. The GAP minimum mapping unit is 100 hectares (1 km2). Each GAP polygon is 

comprised of up to three vegetation assemblages (a primary, secondary, and for some 

polygons, a tertiary assemblage), with each assemblage occupying a fraction of the 
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polygon area. In addition, each assemblage is comprised of up to three co-dominant 

species, each species contributing ≥ 20% of the assemblage’s relative cover. Species 

canopy cover within individual polygons was estimated as FC × CW, where the 

parameter FC is the fractional area (ranging between 0 and 1) of the polygon occupied 

by an assemblage, and CW is a weighting factor for co-dominant species, such that CW 

= 0.33, 0.50, or 1.0 for assemblages comprised of 3, 2, or 1 species, respectively. For 

example, a hypothetical 100 km2

 polygon is comprised of primary and secondary 

assemblages occupying 65% and 35% of the polygon area, respectively. If the primary 

assemblage is comprised of two species A and B, the co-species weighting factor for 

each is 0.5 and the canopy cover for each species is (0.65 × 0.5 × 100 km2

). If the 

secondary assemblage is comprised of species B, C and D, the canopy cover for each 

species is (0.35 × 0.33 × 100 km2

). The total canopy cover for species B within the 

polygon is then [(0.65 × 0.5) + (0.35 × 0.33)] × 100 km2

 or 44 km2. The estimated 

canopy cover of a given species in a polygon therefore reflects the weighted 

contributions from all assemblages in that polygon. 

Agricultural areas represented by the GAP data set lack crop species information. 

Therefore, a land use/land cover GIS map showing crop coverages for the CCOS 

domain was obtained from scientists of the NASA Ames Research Center. The map 

was compiled from GIS data sets provided by the California Department of Water 

Resources (DWR) (http://www.waterplan.water.ca.gov/). Land use/land cover maps 

were developed by the DWR from periodic ground surveys throughout the state. 

Counties are surveyed and updated on a rotating basis approximately every seven 

years. In the DWR crop GIS data set, polygons correspond to individual cultivated 

fields for which are listed the field area, crop type and the fraction of the field cultivated. 

Urban areas represented by the GAP data set contain information about urban land use 

types such as residential and commercial, but lack information about urban vegetation. 

Urban vegetation databases for three CCOS urban areas (Fresno, Oakland, and 

Sacramento) were therefore utilized to develop BVOC emission rates for urban areas 

throughout the CCOS domain. 

D.10.2.2 Emission factors, leaf mass and landscape-scale emission rates 

For natural areas, GAP plant species were assigned isoprene and monoterpene 

emission factors (μg g-1 [dry leaf weight] hr-1) from Benjamin et al. (1996) and specific 

leaf weight factors (SLW, g [dry leaf weight] m-2 leaf area) from a database compiled by 

Nowak and co-workers (2000) (Table 1). Until relatively recently, emission factor data 

collected in California have been based on branch enclosure rather than leaf cuvette 

measurement methods. Leaf cuvette-based isoprene emission factors have been found 

to be 1.75 to 5 times greater than branch enclosure derived emission factors (Guenther 

et al. 1994 and 1996a; Harley et al. 1998; Geron et al. 2001), ascribed in part to selfshading by leaves within enclosed branches. Since the majority of published emission 

factor measurements in California were developed using branch enclosure methods, the 

BEIGIS model used branch enclosure derived emission factors for isoprene and 
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monoterpenes. Branch enclosure derived emission factors for methylbutenol were 

unavailable, therefore leaf-cuvette derived methylbutenol emission factors from Harley 

et al. (1998) were used for the MBO emitting conifer species. Within-canopy vertical 

variation in leaf mass, temperature and solar radiation were not explicitly accounted for 

in this modeling. Landscape-scale natural area emission rates at reference conditions 

(30 °C and 1000 umoles m-2 s-1 photosynthetically active radiation or PAR) for isoprene, 

monoterpenes and MBO (mg m-2 land hr-1) were derived by mapping GAP species 

fractional canopy cover (FC), co-dominant species weighting factors (CW), specific leaf 

weight factors (SLW), and emission factors (EF), to 1km2 grids and multiplying by a 

remotely-sensed 1 km2 resolution leaf area index (LAI, m2 leaf m-2 land) GIS layer from 

Nikolov (1999). 

Landscape-scale crop emission rates at reference conditions were derived by first 

assigning to the crop GIS layer crop BVOC emission factors and crop specific leaf 

weight (SLW) factors. The DWR land use/land cover map represents 75 agricultural 

classes or crop types (Table 1). A database was developed listing BVOC emission 

factors for isoprene and monoterpenes (μg g−1

 [dry leaf mass] hr−1) at standard 

conditions of temperature and light (30 °C and 1000 μmol PAR m−2 s−1, where PAR is 

solar irradiance in the 400-700 ηm range) and specific leaf weight factors (SLW, g [dry 

leaf mass] m−2 leaf area) for each crop type (Table 2). Very few crops are isoprene 

emitters, while some emit monoterpenes. MBO emissions have been observed in a few 

conifer species. BVOC emission and SLW factors were assigned to crops based upon 

values reported in the scientific literature. BVOC emission factors were assigned based 

upon values reported for measured species, or based upon taxonomic relationship to 

measured species (Benjamin et al. 1996). SLWs were assigned based upon values for 

measured species, related species, or class. A crop calendar was also consulted to 

determine which crop types are in cultivation during the summer ozone season. Crop 

SLW and emission factors were gridded to 1 km2 resolution and multiplied by the 

remotely-sensed 1 km2

 resolution leaf area index GIS layer from Nikolov (1999). 

Urban vegetation survey data for Fresno, Oakland, and Sacramento were utilized to 

develop landscape-scale isoprene and monoterpene emission rates (mg m-2 land hr-1) 

at reference conditions for urban land uses (Table 3). Urban land use emission rates 

represent aggregations of plant species for urban land use types in Fresno, Oakland 

and Sacramento (Sidawi and Horie 1992; Nowak 1991; McPherson 1998) and emission 

factors as developed by Benjamin et al. (1996). 

In addition to isoprene, monoterpenes, and MBO, other organic compounds are emitted 

by vegetation. Guenther et al. (1994) estimate that the other VOCs (OVOCs) comprise 

8% to 73% of total BVOCs. BEIGIS however does not explicitly account for OVOCs at 

this time, because little data exist from which to construct OVOC emission factors or 

emission algorithms for California vegetation. An adjustment factor of 30% is applied to 

the total isoprene, monoterpene and MBO inventory to account for the OVOC fraction, 

to which is applied a chemical speciation profile from Lamanna et al. (1999) (pers. 

comm., Paul Allen, CARB, 2001). The OVOC chemical speciation profile is based upon 

above-canopy ambient air BVOC measurements at Blodgett Experimental Forest, a 
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1315 m elevation Ponderosa Pine plantation in the central Sierra Nevada of California. 

The assumed OVOC profile therefore may have limited applicability to natural areas of 

the CCOS domain, which, in addition to conifer forests, are comprised of savannas, 

chaparral and scrublands. 

Landscape-scale 1 km2

 resolution emission rate layers for natural, urban, and 

agricultural areas were then aggregated to construct single layers of gridded isoprene, 

monoterpene, and methylbutenol emission rates at reference conditions for the CCOS 

domain. 

D.10.2.3 Application of environmental correction algorithms 

In the BEIGIS model, the effects of spatial variation in ambient air temperature and light 

intensity on BVOC emissions are taken into account. Isoprene, monoterpene, and MBO 

emission rate grid layers were environmentally adjusted using emission algorithms 

(Guenther et al. 1993; Harley et al. 1998) driven by hourly gridded air temperature and 

solar radiation fields. The isoprene emission algorithm is given as 

where Is is isoprene emission at reference temperature and light conditions and where 

CL and CT are correction factors for ambient temperature and light 

and where T is ambient temperature (K) and L is ambient sunlight in the PAR range. 

2 2

1

1 L

c L

C L

L

α

α

+

=

( )

( )

RT T

c T T

RT T

c T T

C

S

T M

S

T S

T − +

−

= 2

1

1 exp

exp

T K

T K

c J mol

c J mol

R J K mol

c

M

s

T

T

L

314

303

230,000

95,000

8.314

1.066

0.0027

1

2

1

1

1 1

1

=

=

=

=

=

=

=

−

−

− −

α
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The monoterpene emission algorithm is given as 

( ) ( ) M M s T − Ts = ⋅ exp β

where Ms is monoterpene emission at reference temperature and where 

T K

K

s 303

0.09 1

=

= − β

Methylbutenol emissions are both temperature and light-dependent, 

MBO MBOS CL CT = ⋅ ⋅

where MBOs is MBO emission at reference conditions of temperature and light and 

where CL and CT are correction factors for ambient temperature and sunlight 

2 2

1

1 L

c L

C L

L

α

α

+

=

1.44

0.0011

1 =

=

L c

α

( )

[ ] ( ) ( )

T K

T T R

c kJ mol

c kJ mol

E

c c

E c

C

opt

opt

T

T

opt

C

T T

C

opt T

T T

T

312.3

1/ 1/ /

209

67

1.52

1 exp

exp

1

2

1

1

2 1

2

2

1

=

= −

=

=

=

− − =

−

−

χ

χ

χ

Hourly temperature and solar radiation fields gridded at 4 × 4 km resolution for the 

CCOS domain are generated using the MM5 model (NCAR 2001). PAR is calculated as 

0.42 × SRAD × (4.6 μmol photons m-2 s-1 [W m-2]

-1), where SRAD is full sun (direct + 

diffuse) radiation (W m-2) in the visible spectrum. 
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D.10.3 Field data and model comparison 

Canopy-level emissions of monoterpenes and methylbutenol were simulated for a 2 km 

x 2km area surrounding a measurement site at Blodgett Forest Research Station. 

Located near Georgetown, California, the Blodgett Forest site (38°53’42.9”N, 

120°37’57.9”W) is a long-term micrometeorological flux measurement site located on a 

Ponderosa Pine plantation and operated by the University of California at Berkeley. It is 

the only site where canopy-level BVOC fluxes have been measured in California (Baker 

et al. 1999; Dreyfus et al. 2002; Schade and Goldstein, 2001, 2003; Kurpius and 

Goldstein, 2003; Lamanna and Goldstein 1999; Bauer et al. 2000; Schade et al. 1999; 

Goldstein et al. 2000; Schade et al. 2000; Goldstein and Schade 2000). MBO emissions 

were simulated for two cases. In the first case, emissions were simulated using default 

BEIGIS land cover inputs. In the second case, emissions were simulated using 

Blodgett Forest site-specific land cover inputs. Meteorological data from the Blodgett 

site for the period June 2 – September 8, 1999 were used as input for both simulations. 

Modeled emissions for both cases were compared to measured MBO fluxes for the 

same period. Monoterpene emissions were simulated using default BEIGIS land cover 

inputs and compared to measured fluxes of alph-pinene, beta-pinene, and 3-carene for 

the same period. 

The Blodgett site is near the nexus of four 1 km2

 BEIGIS model grid cells labelled A 

through D), and the boundary of two GAP land cover polygons (GAP id 6658 and 6728) 

(Figure D.8). In BEIGIS, GAP land cover information are gridded at 1 km2 resolution, 

therefore grid cells A and C inherit land cover attributes from GAP polygon 6658, while 

grid cells B and D inherit attributes from polygon 6728. BEIGIS land cover input data for 

model grid cells A through D are shown in Tables 4 and 5. While the default gridded 

BEIGIS model inputs and output are at 1 km2

 resolution, Blodgett land cover and flux 

measurement data represent an upwind “footprint” of only a few hundred meters. 

Although measurements and model simulations ostensibly represent different spatial 

scales, comparisons indicate how variable results can be, based on differences in 

reasonable estimates of the inputs. 

Figure D.9 compares averaged modeled MBO fluxes for BEIGIS model grid cells A 

through D, with the average measured fluxes at the Blodgett site for the period June 2 – 

September 8, 1999. The general shape of the diurnal pattern agrees well with the 

measurements; however, the modeled MBO fluxes for grid cells A and C underpredict 

emissions by a factor of 2, while grid cell B overpredicts by a factor of 2. Modeled MBO 

fluxes for grid cell D are slightly overpredicted. Since there are multiple factors 

contributing to each term in the model (including factors which may not be known), it is 

not possible to accurately determine errors associated with each. The greatest 

uncertainty exists in the determination of leaf mass density (LMD), because of the 

number of factors which can effect it. The emission factor also has uncertainty due to 

its’ possible seasonal variability. Variability in leaf mass densities and MBO emission 

factors measured at Blodgett indicate that canopy-scale reference emission rates (i.e. 

normalized to 30 °C and 1000 μmoles m-2 s-1 PAR) may have ranged from 1.06 to 6.24 
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mg C m-2 hr-1, with a midvalue of approximately 2.98 mg C m-2 hr-1 (Baker et al. 1999). 

The effect of these uncertainties are shown in Figure D.10, where MBO emissions were 

simulated using Blodgett leaf mass density and emission factor ranges reported in 

Baker et al. (1999). The figure illustrates that measured leaf mass density and emission 

factor uncertainties can yield modeled MBO fluxes which are over- or under-predicted 

by a factor 2. Midvalue inputs yield modeled MBO fluxes which were overpredicted by 

approximately 25-30%. 

Monoterpene fluxes for BEIGIS grid cells A through D were modeled using default 

BEIGIS land cover inputs and Blodgett meteorological data. Figure D.11 compares 

averaged modeled monoterpene fluxes (converted from units mg monoterpene m-2 hr-1

to mg C m-2 hr-1) for BEIGIS grid cells A through D, with average measured fluxes of 

three monoterpene species: alpha- and beta-pinene, and 3-carene, for the period June 

2 – September 8, 1999. Monoterpene fluxes were not modeled using Blodgett sitespecific inputs, as variability in the monoterpene-emitting leaf mass density and 

emission factors at this site were not available. For simplicity, the three measured 

monoterpene species are also combined into a single category for comparison with 

BEIGIS-modeled monoterpene fluxes (which are not speciated). BEIGIS-modeled 

monoterpene fluxes for grid cells A and C during midday are slightly greater than 

measured alpha-pinene and 3-carene fluxes, and slightly lower than measured betapinene fluxes. BEIGIS-modeled monoterpene fluxes for grid cell B are a factor 2 to 4 

greater than the combined alpha- and beta-pinene + 3-carene category, and individual 

monoterpene species, respectively. BEIGIS-modeled monoterpene fluxes for grid cell D 

are a factor 2 greater than the individual measured monoterpene species, and in 

approximate agreement with the combined alpha- and beta-pinene + 3-carene category. 

Variability in monoterpene fluxes are of the same order as have been shown for MBO 

fluxes, and presumably due in part to uncertainties in leaf mass densities and 

monoterpene emission factors. 

D.10.4 Model Uncertainties 

Inputs to BEIGIS, such as emission rates, leaf mass factors, land use/land cover maps, 

and satellite-derived LAI values have been assessed by a number of researchers 

(Winer et al. 1998; Chung and Winer 1999; Karlik and McKay 1999; Karlik 2001; Winer 

and Karlik 2001). 

Isoprene and monoterpene emission factors utilized by BEIGIS for plant species in 

California’s urban, agricultural, and natural landscapes are derived from in-situ branch 

enclosure measurements and taxonomic assignments (Benjamin et al. 1996). Although 

measured emission rates are used where available, assignment of measured emission 

factors to unmeasured species based upon taxonomic relationship introduces 

uncertainties. Karlik and Winer (2001) measured isoprene emission factors of plant 

species to test taxonomically assigned emission factors of Benjamin et al. (1996). They 

reported measured branch-level isoprene emission factors for 13 of 19 species were 

within ± 50% of taxonomically predicted emission factors. Genus-level assignments 
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were in generally good agreement with measured isoprene rates, with the exception of 

Quercus, where emissions varied widely about the predicted mean of 24.8 μg g -1 hr-1, 

from below detection limit for Q. suber to 54 μg g-1 hr-1 for Q. kelloggii. The uncertainty 

associated with the monoterpene and OVOC emissions estimates have not been 

quantified. OVOCs are an added fraction to the BEIGIS BVOC inventory to which is 

applied a chemical speciation profile which may not be representative of natural areas 

in the CCOS domain. 

As noted previously, systematic differences have been reported in the literature for leaf 

cuvette versus branch enclosure derived emission factors. Geron et al. (2001) 

assessed taxonomic rate assignments of Benjamin et al. (1996) by measuring leaf 

cuvette isoprene emission factors for a number of eastern U.S. and native California 

oak species. For Quercus chrysolepis, Q. engelmannii, Q. kelloggii, Q. falcata and 

Populus trichocarpa, measured leaf cuvette emissions were approximately a factor of 2 

to 5 times greater than the taxonomically predicted branch-level emission factors, 

attributed in part to differences in enclosure type. Guenther et al. (1996a) also 

observed that isoprene emissions measured via leaf cuvette ranged between 1.5 to 2 

times greater than branch-level measurements, due to differences in leaf orientation, 

self-shading and other factors. 

Plant species composition and abundance predicted by the GAP database have been 

evaluated for several regions of the state. Field data from 8 sites in the Southern 

California Ozone Study (SCOS) domain and 6 sites in central California indicate that the 

GAP database correctly predicted 50% to 70% of the plant species at the sites surveyed 

(Winer et al. 1998; Chung and Winer 1999; Winer and Karlik 2001). In San Diego 

County, isoprene and monoterpene emission potentials for 8 polygons estimated 

according to GAP predicted plant species composition and areal coverage were 

compared to emission potentials estimated from field sampling (Chung and Winer 

1999). For four of the polygons, emission potentials based on GAP predictions were 

more than 50% different from emission potentials calculated from field data. When 

summed over all 8 polygons, the total isoprene emission potential based on field data 

was 7% greater than the total based upon the GAP prediction. The total monoterpene 

emission potential for the 8 polygons based on field data was 2% lower than the total 

based upon the GAP prediction. 

Modeled BVOC emissions are also sensitive to uncertainties associated with leaf mass 

density (g [dry leaf weight] m-2 land). For natural areas, leaf mass density is computed 

from remotely sensed leaf area index, fractional canopy cover, co-species weighting 

factors and plant specific leaf weight factors. Winer and Karlik (2001) found that 

ground-surveyed leaf area indices measured in California oak savannas (LAI ~ 1.3) 

agreed with satellite-derived 1 km2

 resolution LAI values (between 1 and 2) for those 

same sites. In the Winer and Karlik (2001) study, a stand of 14 Blue Oak trees 

(Quercus douglasii) surrounded by open grassland was measured for crown height, 

crown radii, and diameter at breast height (DBH). All 14 trees were then harvested, and 

their stem and leaf areas and (fresh and dried) weights recorded. Mean per-tree leaf 

mass density (LMD) was 730 g m-2, while site leaf mass density, defined as the total leaf 
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mass of the 14 trees divided by the total study area, was 310 g m-2. This site LMD 

value is in the midrange of LMDs (182 – 643 g m-2) reported by Sidawi and Horie (1992) 

for oak woodlands in the southern San Joaquin Valley. When the oak leaf mass of the 

site study area was considered together with surrounding grassland, the LMD 

decreased by a factor of two. In the BEIGIS model, calculated LMDs for 1 km2 grid cells 

in CCOS natural areas are often less than 200 g m-2. Natural area LMDs utilized by 

Benjamin et al. (1997) for the Southern California Air Quality Management Plan 

(SCAQMP) domain ranged from 90 (grassland) to 244 (woodland) to 555 g m-2 (forest). 

Although further data analyses are needed, these preliminary results support the use of 

the satellite-derived LAI database as an input to the BEIGIS model. 

Potential leaf mass estimation biases from multiplying plant species SLWs by fractional 

canopy cover areas and co-species weighting factors together with LAI values for 1 km2

grid cells are unknown. Computing species leaf mass densities in this manner may 

over or under-predict a species’ contribution to total emissions. The technique may be 

less problematic for computing leaf masses and emissions of crops, many of which are 

cultivated in monocultures greater than 1 km2

. 

D.10.5 Conclusion 

Compared to fluxes measured at the Blodgett Forest site, MBO emissions modeled for 

four adjacent BEIGIS 1 km2 grid cells using default BEIGIS inputs were under-predicted 

in two adjoining 1 km2

 grid cells and over-predicted emissions in one adjoining 1 km2

grid cell. Modeled MBO emissions in the remaining grid cell were in relatively good 

agreement with measured MBO fluxes. MBO fluxes modeled using variable Blodgett 

site-specific inputs for leaf mass density and MBO emission factors showed similar 

magnitudes of over- and under-prediction, and relatively good agreement when using 

midvalue inputs. Monoterpene fluxes modeled using default BEIGIS inputs showed a 

similar pattern of over- and under-prediction, when compared to measured fluxes of 

specific monoterpene compounds. 

Studies have shown that uncertainties in canopy biomass distributions and “flux 

footprint” determination can confound BVOC emission model validation using 

micrometeorological flux measurements (Lamb et al. 1996; Guenther et al. 1996; 

Baldocchi et al. 1999; Huber et al. 1999). Model performance is usually achieved only 

after detailed parameterization of the BVOC-emitting leaf mass density within the 

upwind flux “footprint” of the measurement site. At the Blodgett Forest site, Shade et al. 

(2000) were able to achieve good agreement between modeled and measured MBO 

fluxes by representing the MBO-emitting Ponderosa Pine leaf mass according to (three) 

needle leaf age classes, by assigning different emission factors to each age class, by 

varying the emission factors and leaf mass over the growing season, and by adopting a 

sunlit vs. shade leaf PAR scheme. 

Comparisons between BEIGIS modeled and measured BVOC fluxes are preliminary. 

Further analyses of BEIGIS performance with Blodgett data are needed. Regional and 
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canopy-scale flux measurements to test model estimates of BVOC emissions for other 

regions and land cover types of the state are also needed. 

D.10.6 References 

Baker, B., Guenther, A., Greenberg, J., Goldstein, A., and Fall, R. Canopy fluxes of 2-

methyl-3-buten-2-ol over a ponderosa pine forest by relaxed eddy accumulation: field 

data and model comparison. J. Geophys. Res. 104, D21: 26107-26115. 

Bauer, M.R., N.E. Hultman, J.A. Panek, and A.H. Goldstein. (2000) “Ozone deposition 

to a ponderosa pine plantation in the Sierra Nevada Mountains (CA): a comparison of 

two different climatic years.” J. Geophys. Res., 105, D17: 22123-22136. 

Benjamin, M. T., Sudol, M., Bloch, L. and Winer, A. M. (1996) Low-emitting urban 

forests: a taxonomic methodology for assigning isoprene and monoterpene emission 

rates. Atmospheric Environment 30, 1437-1452. 

Benjamin, M. T., Sudol, M., Vorsatz, D. and Winer, A. M. (1997) A spatially and 

temporally resolved biogenic hydrocarbon emissions inventory for the California South 

Coast Air Basin. Atmospheric Environment 31, 3087-3100. 

California Energy Commission (1992) Climate Zone Weather Data Analysis and 

Revision Project. Final Report, Contract No. 400-88-010. Sacramento, California. 

Chung, Y. J. and Winer, A. M. (1999) Field assessment of the California GAP analysis 

program database for San Diego County. Madroño 46, 187-198. 

Davis, F. W., Stine, P. A., Stoms, D. M., Borchert, M. I. and Hollander, A. D. (1995) 

GAP analysis of the actual vegetation of California 1. The southwestern region. 

Madroño 42, 40-78. 

Dreyfus, G., Schade, G., and Goldstein, A. (2002) Observational constraints on the 

contribution of isoprene oxidation to ozone production on the western slope of the Sierra 

Nevada, California. J. Geophys. Res. 107, D19: 4365, 10.1029/2001JD001490, 2002. 

Geron, C. D., Harley, P. and Guenther, A. B. (2001) Isoprene emission capacity for U.S. 

tree species. Atmospheric Environment 35, 3341-3352. 

Goldstein, A.H., N.E. Hultman, J.M. Fracheboud, M.R. Bauer, J.A. Panek, M. Xu, Y. Qi, 

A.B. Guenther, and W. Baugh. (2000) Effects of climate variability on the carbon 

dioxide, water, and sensible heat fluxes above a ponderosa pine plantation in the Sierra 

Nevada (CA). Agricultural and Forest Meteorology (101) 2-3: 113-129. 
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Goldstein, A.H., and G.W. Schade. (2000) Quantifying biogenic and anthropogenic 

contributions to acetone mixing ratios in a rural environment. Atmospheric Environment, 

34, 29-30: 4997-5006. 

Guenther, A. B., Zimmerman, P. R., Harley, P. C., Monson, R. K. and Fall, R. (1993) 

Isoprene and monoterpene emission rate variability: model evaluations and sensitivity 

analyses. J. Geophys. Res. 98, 12609-12617. 

Guenther, A., Zimmerman, P., and Wildermuth, M. (1994) Natural volatile organic 

compound emission rate estimates for U.S. woodland landscapes. Atmospheric 

Environment 94, 1197-1210. 

Guenther, A., Zimmerman, P., Klinger, L., Greenberg, J., Ennis, C., Davis, K., Pollock, 

W., Westberg, H., Allwine, G. and Geron, C. (1996a) Estimates of regional natural 

volatile organic compound fluxes from enclosure and ambient measurements. J. 

Geophys. Res. 101, 1345-1359. 

Harley, P., Fridd-Stroud, V., Greenberg, J., Guenther, A. and Vasconcellos, P. (1998) 

Emission of 2-methyl-3-buten-2-ol by pines: A potentially large natural source of 

reactive carbon in the atmosphere. J. Geophys. Res. 103, 25,479-25,486. 

Hickman, J. C. (ed.) (1993) The Jepson manual of higher plants of California. University 

of California Press, Berkeley, California. 

Huber, L., Laville, P., and Fuentes, J. (1999) Uncertainties in isoprene emissions from a 

mixed deciduous forest estimated using a canopy microclimate model. Journal of 

Applied Meteorology 38: 899-912. 

Karlik, J. F. and McKay, A. H. (1999) Development of methodology and databases for 

estimating leaf masses in California airsheds. Final Report, Air Resources Board 

Contract No. 97-719, University of California Cooperative Extension, Bakersfield, CA. 

Karlik, J. F. (2001) Validation of databases for modeling biogenic volatile organic 

compound emissions in Central California. Final Report, San Joaquin Valleywide Air 

Pollution Study Agency Agreement No. 00-16CCOS, University of California 

Cooperative Extension, Bakersfield, CA. 

Karlik, J. F. and Winer, A. M. (2001) Measured isoprene emission rates of plants in 

California landscapes: comparison to estimates from taxonomic relationships. 

Atmospheric Environment 35, 1123-1131. 

Kurpius, M.R., and A.H. Goldstein, Gas-phase chemistry dominates O3 loss to a forest, 

implying a source of aerosols and hydroxyl radicals to the atmosphere. (2003) 

Geophysical Research Letters, V. 30, 1371, doi:10.1029/2002GL016785, 2003. 
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Lamanna, M. S. and Goldstein, A. H. (1999) In situ measurements of C2-C10 volatile 

organic compounds above a Sierra Nevada ponderosa pine plantation. J. Geophys. 

Res. 104, 21247-21262. 

Lamb, B., Pierce, T., Baldocchi, D., Allwine, E., Dilts, S., Westberg, H., Geron, C., 

Guenther, A., Klinger, L., Harley, P., and Zimmerman, P. (1996) Evaluation of forest 

canopy models for estimating isoprene emissions. Journal of Geophysical Research, V. 

101, No. D17, pp 22787-22797. 

McPherson, E.G. (1998) Structure and sustainability of Sacramento’s urban forest. 

Journal of Arboriculture. 24 (4): 174 – 190. 

NCAR (2001) PSU/NCAR Mesoscale Modeling System Tutorial Class Notes and User’s 

Guide: MM5 Modeling System Version 3. Mesoscale and Microscale Meteorology 

Division, National Center for Atmospheric Research. Boulder, CO. 

Nikolov, N. T. (1999) 1-km resolution database of vegetation leaf area index and canopy 

clumping factor for the western U.S.A. Final Report, USDA Forest Service Agreement 

No. PSW-99-001-RJVA. N & T Services, Oak Ridge, TN. 

Nowak, D.J.N. (1991) Urban forest development and structure: Analysis of Oakland, 

California. Dissertation. University of California, Berkeley, CA. 

Nowak, D. J. N., et al. (2000) Specific leaf weight factor database. Publication in 

preparation. USDA Forest Service – Northeastern Research Station. Syracuse, NY. 

Scott, J. M., Davis, F., Csuti, B., Noss, R., Butterfield, B., Groves, C., Anderson, H., 

Caicco, S., D. Erchia, F., Edwards Jr., T. C., Ulliman, J. and Wright, R. G. (1993) GAP 

analysis: a geographic approach to protection of biological diversity. Wildlife 

Monographs. 57, 1-41. 

Schade, G.W., A.H. Goldstein, and M.S. Lamanna. (1999) Are monoterpene emissions 

influenced by humidity? Geophysical Research Letters. 26, 14: 2187-2190. 

Schade, G.W., A.H. Goldstein, D.W. Gray, and M.T. Lerdau. (2000) Canopy and leaf 

level 2-methyl-3-butene-2-ol fluxes from a ponderosa pine plantation. Atmospheric 

Environment 34, 21: 3535-3544. 

Schade, G.W. and A.H. Goldstein (2001) Fluxes of oxygenated volatile organic 

compounds from a ponderosa pine plantation. J.Geophys. Res., 106, D3: 3111-3123. 

Schade, G.W., and A.H. Goldstein, Increase of monoterpene emissions from a pine 

plantation as a result of mechanical disturbances, Geophysical Research Letters, V. 30, 

1380, doi:10.1029/2002GL016138, 2003 
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Sidawi, S., and Horie, Y. (1992) Leaf biomass density for urban, agricultural and natural 

vegetation in California’s San Joaquin Valley. Final Report, San Joaquin Valleywide Air 

Pollution Study Agency Contract No. 88-41. Valley Research Corporation, Van Nuys, 

CA. 

Winer, A. M., Karlik, J., Arey, J., Chung, Y. J. and Reissell, A. (1998) Biogenic 

hydrocarbon inventories for California: Generation of essential databases. Final Report, 

Air Resources Board Contract No. 95-309, University of California, Los Angeles, CA. 

Winer, A. M. and Karlik, J. F. (2001) Development and validation of databases for 

modeling biogenic hydrocarbon emissions in California’s airsheds. Final Report, Air 

Resources Board Contract No. 97-320, University of California, Los Angeles, CA. 
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D.10.8 Figures 

Figure D.8 

Blodgett Forest research site (triangle symbol). Site is near edge of two BEIGIS 

model GAP polygons and the nexus of four 1 x 1 km BEIGIS model grid cells 

(labeled A through D).
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Figure D.9 Measured vs. modeled MBO fluxes. 

-0.5

0

0.5

1

1.5

2

2.5

3

3.5

0 4 8 12 16 20 24

hour

MBO (mg C/m2/hr)

measured

BEIGIS grid A

BEIGIS grid B

BEIGIS grid C

BEIGIS grid D

Figure D.10 

MBO fluxes modeled with default BEIGIS vs. on-site Blodgett inputs, compared to 

measured fluxes.

-0.5

0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

0 4 8 12 16 20 24

hour

MBO (mg C/m2/hr)

measured

BEIGIS grid A

BEIGIS grid B

BEIGIS grid C

BEIGIS grid D

Blodgett low

Blodgett reference

Blodgett high
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Figure D.11 

Monoterpene fluxes modeled with default BEIGIS inputs, vs. measured 

monoterpene fluxes.

-0.1

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

0 4 8 12 16 20 24

hour

flux (mg C/m2/hr)

measured a-pinene

measured b-pinene

measured 3-carene

BEIGIS grid A

BEIGIS grid B

BEIGIS grid C

BEIGIS grid D

a&b-pinene+3-carene
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Table 1. BVOC emission and specific leaf weight (SLW) factors assigned to GAP vegetation species.

GAP specific leaf wt in-leaf season emission factor

species Common name Scientific name Vegetation g dry leaf/m2 leaf ug/g dry leaf wt/hr @ ref conditions

code Class SLW ISO MONO MBO

42034 Coulter pine Pinus coulteri 1 91 0 4 71

42044 Foothill pine Pinus sabiniana 1 91 0 1 67

41006 Oregon oak Quercus garryana 3 110 59 1 0

32433 Oregon oak (shrub form) Quercus garryana var. breweri 3 110 59 1 0

41001 Black oak Quercus kelloggii 3 103 54 1 0

41015 Willow Salix spp. 3 62 51 0 0

41009 Quaking aspen Populus tremuloides 3 89 50 0 0

41012 Fremont cottonwood Populus fremontii 3 85 36 0 0

41004 Coast live oak Quercus agrifolia 2 141 35 0 0

41010 Black cottonwood Populus balsamifera ssp. trichocarpa 3 85 33 0 0

41030 Eucalyptus Eucalyptus spp. 2 130 28 5 0

42059 Shore pine Pinus contorta var. contorta 1 149 0 4 25

42014 Lodgepole pine Pinus contorta var. murrayana 1 149 0 4 25

42015 Ponderosa pine Pinus ponderosa 1 91 0 4 25

41003 Canyon live oak Quercus chrysolepis 2 169 26 1 0

32065 Canyon live oak (Shrub form) Quercus chrysolepis 2 169 26 1 0

32428 Huckleberry oak Quercus vaccinifolia 5,2 110 26 1 0

41002 Blue oak Quercus douglasii 3 122 26 0 0

41027 Engelmann oak Quercus engelmannii 3 152 25 1 0

41055 Quercus alvordiana 2 110 25 1 0

32073 Desert scrub oak Quercus cornelius-mullerii 2 110 25 1 0

32061 Leather oak Quercus durata 5,2 110 25 1 0

32220 Tuckers Oak Quercus john-tuckeri 3 110 25 1 0

32455 Saddlers oak Quercus sadleriana 5,2 110 25 1 0

11400 Transportation and Utilities 7

32096 California broom Lotus scoparius 5,3-2 127 22 2 0

32229 Psorothamnus arborescens 5,2-3 127 22 2 0

32215 Psorothamnus emoryi 5,2-3 127 22 2 0

32230 Psorothamnus polydenius 5,2-3 127 22 2 0

41022 Smoke tree Psorothamnus spinosa 5,2-3 127 22 2 0

41013 Valley oak Quercus lobata 3 101 21 0 0

11100 Residential 7

11600 Mixed Urban 7

11700 Other Urban 7

41005 Interior live oak Quercus wislizenii 2 158 13 1 0

11200 Commercial and services 7

41060 Black locust Robinia pseudoacacia 3 50 12 2 0

32068 Interior live oak (Shrub form) Quercus wislizenii 2 158 13 1 0

32143 Desert lavender Hyptis emoryi 5,2 127 0 13 0

42043 Brewer spruce Picea breweriana 1 191 10 2 0

32000 Unidentified chaparral shrubs 6 100 8 4 0

32104 Low sagebrush Artemisia arbuscula 5,2-3 312 0 12 0

32302 California sagebrush Artemisia californica 5,2-3 312 0 12 0

32108 Silver sagebrush Artemisia cana 5,2-3 312 0 12 0

32109 Tarragon Artemisia dracunculus 5,2-3 312 0 12 0

32110 Black sagebrush Artemisia nova 5,2-3 312 0 12 0

32111 Rothrock sagebrush Artemisia rothrockii 5,2-3 312 0 12 0

32112 Bud sagebrush Artemisia spinescens 5,2-3 312 0 12 0

32103 Great basin sagebrush Artemisia tridentata 5,2-3 312 0 12 0

32151 Regeneration shrubs Artemisia tridentata, Chrysothamnus spp., etc. 5,2-3 312 0 12 0

32005 Coyote brush Baccharis pilularis 5,2 192 0 12 0

32102 Rabbitbrush Chrysothamnus nauseosus 5,2 168 0 12 0

32118 Rabbitbrush Chrysothamnus parryi 5,2 168 0 12 0

32119 Rabbitbrush Chrysothamnus viscidiflorus 5,2 168 0 12 0

32033 Mule fat Baccharis salicifolia 5,2 127 0 12 0

41029 Sycamore Platanus racemosa 3 52 11 0 0

41020 Fan palm Washingtonia filifera 4 152 10 0 0

42012 Jeffrey pine Pinus jeffreyi 1 91 0 4 5

42003 Coast redwood Sequoia sempervirens 1 106 0 9 0

42027 Giant sequoia Sequoiadendron giganteum 1 106 0 9 0

11500 Industrial and Commercial Complexes 7

32305 White sage Salvia apiana 5,2-3 250 0 8 0

32507 Desert sage Salvia dorrii 5,2-3 250 0 8 0

32306 Purple sage Salvia leucophylla 5,2-3 250 0 8 0

32307 Black sage Salvia mellifera 5,2-3 250 0 8 0

32318 Pitcher sage Salvia spathecea 5,2-3 250 0 8 0

42009 Sitka spruce Picea sitchensis 1 191 4 1 0

42017 Mountain hemlock Tsuga mertensiana 1 60 1 3 0

42005 Douglas fir Pseudotsuga menziesii 1 55 1 3 0

42058 Western hemlock Tsuga heterophylla 1 54 1 3 0
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GAP specific leaf wt in-leaf season emission factor

species Common name Scientific name Vegetation g dry leaf/m2 leaf ug/g dry leaf wt/hr @ ref conditions

code Class SLW ISO MONO MBO

42915 Mid-elevation plantations 8 100 0 4 0

42951 Upper-elevation plantations 6 100 0 4 0

42026 Whitebark pine Pinus albicaulis 1 91 0 4 0

42013 Knobcone pine Pinus attenuata 1 91 0 4 0

42011 Foxtail pine Pinus balfouriana 1 91 0 4 0

42029 Limber pine Pinus flexilis 1 91 0 4 0

42053 Sugar pine Pinus lambertiana 1 91 0 4 0

42028 Bristlecone pine Pinus longaeva 1 91 0 4 0

42030 Single leaf pinyon Pinus monophylla 1 91 0 4 0

42031 Western white pine Pinus monticola 1 91 0 4 0

42010 Bishop pine Pinus muricata 1 91 0 4 0

42040 Torrey pine Pinus torreyana 1 91 0 4 0

42057 Washoe Pine Pinus washoensis 1 91 0 4 0

11300 Industrial 7

42052 Subalpine fir Abies lasiocarpa 1 165 0 3 0

42045 Incense cedar Calocedrus decurrens 1 106 0 3 0

22104 Dryland grain crops 8

22200 Orchards, Vineyards, Nurseries 8

22201 Evergreen orchard 8

22202 Deciduous orchard 8

22400 Other Agricultural Land 8

22101 Irrigated row and field crops 8

22100 Cropland and Pasture 8

22203 Vineyard 8

42033 Bristlecone fir Abies bracteata 1 98 0 3 0

42022 White fir Abies concolor 1 98 0 3 0

42051 Red fir Abies magnifica 1 98 0 3 0

41033 Box elder Acer negundo 3 92 0 3 0

42006 Grand fir Abies grandis 1 72 0 3 0

41053 Mountain maple Acer glabrum 3 59 0 3 0

41050 Bigleaf maple Acer macrophyllum 3 59 0 3 0

42046 Noble fir Abies procera 1 58 0 3 0

41032 California walnut Juglans californica var. californica 3 57 0 3 0

41043 California black walnut Juglans californica var. hindsii 3 57 0 3 0

32450 Vine maple Acer circinatum 3 32 0 3 0

41016 Catclaw Acacia greggii 5,2 240 0 2 0

41019 Mesquite Prosopis glandulosa 3 215 0 2 0

41051 Screwbean Prosopis pubescens 3 215 0 2 0

41017 Desert ironwood Olneya tesota 3 145 0 2 0

32059 Chaparral Pea Pickeringia montana 5,2 127 0 2 0

32018 Mountain whitethorn Ceanothus cordulatus 5,2-3 127 0 2 0

32034 Hoaryleaf ceanothus Ceanothus crassifolius 5,2-3 127 0 2 0

32003 Buckbrush Ceanothus cuneatus 5,2-3 127 0 2 0

32421 Monterey ceanothus Ceanothus cuneatus var. rigidus 5,2-3 127 0 2 0

32416 Cropleaf ceanothus Ceanothus dentatus 5,2-3 127 0 2 0

32035 Desert ceanothus Ceanothus greggii 5,2-3 127 0 2 0

32087 Ceanothus impressus 5,2-3 127 0 2 0

32072 Ceanothus incanus 5,2-3 127 0 2 0

32017 Deerbrush Ceanothus integerrimus 5,2-3 127 0 2 0

32417 Muskbrush Ceanothus jepsonii 5,2-3 127 0 2 0

32036 Chaparral whitethorn Ceanothus leucodermis 5,2-3 127 0 2 0

32037 Bigpod ceanothus Ceanothus megacarpus 5,2-3 127 0 2 0

32038 Hairy ceanothus Ceanothus oliganthus 5,2-3 127 0 2 0

32042 Jimbrush Ceanothus oliganthus var. sorediatus 5,2-3 127 0 2 0

32039 Palmer ceanothus Ceanothus palmeri 5,2-3 127 0 2 0

32040 Wartleaf ceanothus Ceanothus papillosus 5,2-3 127 0 2 0

32420 Littleleaf ceanothus Ceanothus parvifolius 5,2-3 127 0 2 0

32041 Squaw carpet Ceanothus prostratus 5,2-3 127 0 2 0

32043 Greenbark ceanothus Ceanothus spinosus 5,2-3 127 0 2 0

32095 Ceanothus Ceanothus spp. 5,2-3 127 0 2 0

32422 Bluebrush, Wild lilac Ceanothus thyrsiflorus 5,2-3 127 0 2 0

32071 Woolyleaf ceanothus Ceanothus tomentosus 5,2-3 127 0 2 0

32002 Tobacco brush Ceanothus velutinus 5,2-3 127 0 2 0

32044 Wartystem ceanothus Ceanothus verrucosus 5,2-3 127 0 2 0

32016 Lupinus albicaulus 5,herb. 127 0 2 0

32013 Lupinus albifrons 5,herb. 127 0 2 0

32022 Yellow bush lupine Lupinus arboreus 5,herb. 127 0 2 0

32012 Bush lupine Lupinus chamissonis 5,herb. 127 0 2 0

32321 Grape soda lupine Lupinus excubitus 5,herb. 127 0 2 0

32323 Lupinus spp. 5,herb. 127 0 2 0

32216 Caesalpina virgata 5,3-2 91 0 2 0
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GAP specific leaf wt in-leaf season emission factor

species Common name Scientific name Vegetation g dry leaf/m2 leaf ug/g dry leaf wt/hr @ ref conditions

code Class SLW ISO MONO MBO

42039 Sargent cypress Cupressus sargentii 1 127 0 1 0

41044 Tanoak Lithocarpus densiflorus 2 127 0 1 0

42035 Monterey pine Pinus radiata 1 91 0 1 0

42019 California juniper Juniperus californica 1 86 0 1 0

42055 Western juniper Juniperus occidentalis 1 86 0 1 0

42063 Sierra juniper Juniperus occidentalis australis 1 86 0 1 0

42054 Utah juniper Juniperus osteosperma 1 86 0 1 0

42062 Western red cedar Thuja plicata 1 56 0 1 0

42007 Bigcone spruce Pseudotsuga macrocarpa 1 55 0 1 0

32322 Eriophyllum staechadifolium 5,2 herb 127 0 0 0

41056 California wax myrtle Myrica californica 5,2 345 0 0 0

32074 Sugarbush Rhus ovata 5,2 323 0 0 0

32117 Allscale saltbush Atriplex polycarpa 5,3 256 0 0 0

32454 Beargrass Xerophyllum tanex 6, grass 244 0 0 0

32452 Boxleaf silktassel Garrya buxifolia 5,2 223 0 0 0

32435 Silktassel Garrya elliptica 5,2 223 0 0 0

32050 Pale silktassel Garrya flavescens 5,2 223 0 0 0

32051 Fremont silktassel Garrya fremontii 5,2 223 0 0 0

32052 Veatch silktassel Garrya veatchii 5,2 223 0 0 0

32207 Shadscale Atriplex confertifolia 5,2-3 188 0 0 0

32114 Desert holly Atriplex hymenolytra 5,2-3 188 0 0 0

32115 Lenscale Atriplex lentiformis 5,2-3 188 0 0 0

32116 Saltbush Atriplex parryi 5,2-3 188 0 0 0

32144 Triangle leaf Atriplex phyllostegia 5,2-3 188 0 0 0

32105 Saltbush Atriplex spp. 5,2-3 188 0 0 0

32062 Lemonade berry Rhus integrifolia 5,2-3 183 0 0 0

32501 Skunkbrush Rhus trilobata 5,2-3 183 0 0 0

32094 Scrub oak Quercus berberidifolia, etc. 2 149 31 0 0

32444 Western azalea Rhododendron occidentalis 5,3 147 0 0 0

41011 California bay Umbellularia californica 2 145 0 0 0

41018 Joshua tree Yucca brevifolia 5,2 145 0 0 0

32136 Mohave yucca Yucca schidigera 5,2 145 0 0 0

32064 Our lords candle Yucca whipplei 5,2 145 0 0 0

32328 Hawthorn Craetaegus douglasii 3 133 0 0 0

32049 Fremontia or Flannel bush Fremontodendron californicum 5,3 127 0 0 0

32009 Monkshood Aconitum columbianum 5, 3 herb 127 0 0 0

31048 Arizona three-awn Aristida hamulosa 5, grass 127 0 0 0

31033 Balsam root Balsamorhiza sagittata 5, grass 127 0 0 0

32415 Barbarry Berberis nervosa 5,3 127 0 0 0

31029 Japanese brome (exotic) Bromus japonicus 5, grass 127 0 0 0

31026 Cheatgrass (exotic) Bromus tectorum 5, grass 127 0 0 0

32221 Crucifixion Thorn Castela emoryi 5 127 0 0 0

31052 Star thistle Centaurea spp. 5, 3 herb 127 0 0 0

32504 Fern bush, desert sweet Chamaebatiaria millefolium 5,2-3 127 0 0 0

32045 Virgins bower Clematis ligusticifolia 5, 3 herb 127 0 0 0

32083 Giant coreopsis Coreopsis gigantea 5, herb 127 0 0 0

32425 Scotchbroom Cytisus scoparius 5, 3 127 0 0 0

31031 One-spike oatgrass Danthonia unispicata 5, grass 127 0 0 0

31054 Pitcher plant bogs Darlingtonia bogs 5, 3 herb 127 0 0 0

31015 California poppy Eschscholtzia californica 5, 3 herb 127 0 0 0

32138 Forestiera neomexicana 5, 2-3 herb 127 0 0 0

31032 Wood strawberry Fragaria vesca 5, 3 herb 127 0 0 0

32091 Peak rush-rose Helianthemum scoparium 5, 3 herb 127 0 0 0

31023 Foxtail barley Hordeum jubatum 5, grass 127 0 0 0

32149 Bladderpod Isomeris arborea 5,3-2 127 0 0 0

31044 Desert dandelion Malacothrix glabrata 5, 3 herb 127 0 0 0

32145 Menodora spinescens 5, 2-3 herb 127 0 0 0

31024 Nitrophila occidentalis 5,herb 127 0 0 0

32228 Nolina parryi 5,herb 127 0 0 0

31027 Reed canary grass (exotic) Phalaris arundinacea 5, grass 127 0 0 0

31035 Sandbergs bluegrass Poa secunda 5, grass 127 0 0 0

31051 Water smartweed Polygonum amphibium 5, 3 herb 127 0 0 0

32432 Polygonum davisiae 5, 3 herb 127 0 0 0

32509 Ribes aureum 5,3 127 0 0 0

32431 Squaw or wax currant Ribes cereum 5,3 127 0 0 0

32442 Sierra gooseberry Ribes roezlii 5,3 127 0 0 0

32511 Ribes spp. 5,3 127 0 0 0

32010 Currant Ribes velutinum 5,3 127 0 0 0

32441 Sticky currant Ribes viscossimum 5,3 127 0 0 0

32503 Wood rose Rosa gymnocarpa 5,3 127 0 0 0

31021 Bulrush Scirpus robustus 5,herb 127 0 0 0
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GAP specific leaf wt in-leaf season emission factor

species Common name Scientific name Vegetation g dry leaf/m2 leaf ug/g dry leaf wt/hr @ ref conditions

code Class SLW ISO MONO MBO

32001 Chamise Adenostoma fasciculatum 5,2 127 0 0 0

32026 Redshanks Adenostoma sparsifolium 5,2 127 0 0 0

32213 Agave deserti 5,herb 127 0 0 0

22600 Great Basin dry farmed grain/rural Agropyron desertorum, Elyrigia epens, etc. 5 127 0 0 0

41059 Tree of heaven Ailanthus altissima 3 127 0 0 0

32209 Iodine bush Allenrolfea occidentalis 5,3-2 127 0 0 0

32210 Burro-weed (a ragweed) Ambrosia dumosa 5, herb 127 0 0 0

31055 European beachgrass Ammophila arenaria 5, grass 127 0 0 0

41007 Madrone Arbutus menziesii 2 127 0 0 0

32402 Manzanita Arctostaphylos auriculata 5,2 127 0 0 0

32403 Hoary manzanita Arctostaphylos canescens 5,2 127 0 0 0

32456 Hairy manzanita Arctostaphylos columbiana 5,2 127 0 0 0

32027 Eastwood manzanita Arctostaphylos glandulosa 5,2 127 0 0 0

32028 Bigberry manzanita Arctostaphylos glauca 5,2 127 0 0 0

32404 Common manzanita Arctostaphylos manzanita 5,2 127 0 0 0

32406 Indian manzanita Arctostaphylos mewukka 5,2 127 0 0 0

32447 Morro manzanita Arctostaphylos morroensis 5,2 127 0 0 0

32089 Ione manzanita Arctostaphylos myrtifolia 5,2 127 0 0 0

32407 Pinemat manzanita Arctostaphylos nevadensis 5,2 127 0 0 0

32408 Eldorado manzanita Arctostaphylos nissenana 5,2 127 0 0 0

32409 Littleberry manzanita Arctostaphylos nummularia 5,2 127 0 0 0

32029 Serpentine manzanita Arctostaphylos obispoensis 5,2 127 0 0 0

32030 Parry manzanita Arctostaphylos parryana 5,2 127 0 0 0

32004 Greenleaf manzanita Arctostaphylos patula 5,2 127 0 0 0

32446 Pecho manzanita Arctostaphylos pechoensis 5,2 127 0 0 0

32410 La panza manzanita Arctostaphylos pilosula 5,2 127 0 0 0

32075 Pink-bracted manzanita Arctostaphylos pringlei 5,2 127 0 0 0

32069 Mexican manzanita Arctostaphylos pungens 5,2 127 0 0 0

32031 Purisima manzanita Arctostaphylos purissima 5,2 127 0 0 0

32055 Refugio manzanita Arctostaphylos refugioensis 5,2 127 0 0 0

32412 Shagbark manzanita Arctostaphylos rudis 5,2 127 0 0 0

32451 Manzanita spp. Arctostaphylos spp. 5,2 127 0 0 0

32032 Woollyleaf manzanita Arctostaphylos tomentosa 5,2 127 0 0 0

32405 Mariposa manzanita Arctostaphylos viscida var. mariposa 5,2 127 0 0 0

32414 Whiteleaf manzanita Arctostaphylos viscida var. viscida 5,2 127 0 0 0

32008 Santa Cruz manzanita Arctostaphylus andersonii 5,2 127 0 0 0

31011 Giant Reed Arundo donax 5, herb 127 0 0 0

31001 Non-native annual grassland Avena spp., Bromus spp., etc. 5, grass 39 0 0.02 0

31010 Wild Mustard Brassica ssp. 5, herb 127 0 0 0

31017 Great Basin bunchgrass vegetation Bromus tectorum, Festuca idahoensis, etc. 5, grass 39 0 0.02 0

31016 Great Basin annual grasses Bromus tectorum, Taeniantherum caput-medusae, 5, grass 39 0 0.02 0

31043 Carex nebrascensis 5, herb 127 0 0 0

31059 Great Basin wet meadow spp. Carex spp., Juncus spp.,etc. 5, herb 127 0 0 0

31007 Freshwater Sedge - Rush marsh Carex spp., Juncus, spp., 5, herb 127 0 0 0

32020 Mountain misery Chamaebatia foliolosa 5,2 127 0 0 0

32208 Blackbush Coleogyne ramosissima 5 127 0 0 0

31020 Pampas grass Cortaderia jubata 5, grass 127 0 0 0

32046 Bush poppy Dendromecon rigida 5, herb 127 0 0 0

31012 Saltgrass Distichlis spicata 5, grass 127 0 0 0

32303 California encelia Encelia californica 5,2-3 127 0 0 0

32120 Brittlebush Encelia farinosa 5,2-3 127 0 0 0

32140 California ephedra Ephedra californica 5, herb 127 0 0 0

32121 Mormon tea Ephedra nevadensis 5, herb 127 0 0 0

32122 Green ephedra Ephedra viridis 5, herb 127 0 0 0

31056 Erharta calycina 5 127 0 0 0

32434 Goldenfleece Ericameria arborescens 5,2-3 127 0 0 0

32502 Goldenbush Ericameria bloomeri 5,2-3 127 0 0 0

32311 Heather goldenbush Ericameria ericoides 5,2-3 127 0 0 0

32127 Narrowleaf goldenbush Ericameria linearifolius 5,2-3 127 0 0 0

32224 Coopers goldenbrush Ericamerica cooperi 5,2-3 127 0 0 0

32139 Ericamerica Ericamerica spp. 5,2-3 127 0 0 0

32047 Yerba santa Eriodictyon californicum 5,2 127 0 0 0

32090 Lompoc yerba santa Eriodictyon capitatum 5,2 127 0 0 0

32048 Thick leafed yerba santa Eriodictyon crassifolium 5,2 127 0 0 0

32025 Eriodictyon tomentosum 5,2 127 0 0 0

32084 Eriodictyon trichocalyx 5,2 127 0 0 0

32309 Ashyleaf buckwheat Eriogonum cinerium 5,herb 127 0 0 0

32438 Flat-topped buckwheat Eriogonum deflexum 5,herb 127 0 0 0

32301 California buckwheat Eriogonum fasciculatum 5,herb 127 0 0 0

32325 Eriogonum fasciculatum var. fasciculatum 5,herb 127 0 0 0

32324 Eriogonum fasciculatum var. polifolium 5,herb 127 0 0 0
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 Attainment Demonstrations 

D-118

GAP specific leaf wt in-leaf season emission factor

species Common name Scientific name Vegetation g dry leaf/m2 leaf ug/g dry leaf wt/hr @ ref conditions

code Class SLW ISO MONO MBO

32076 Toyon Heteromeles arbutifolia 5,2 127 0 0 0

32128 White burrobush Hymenoclea salsola 5 127 0 0 0

32326 Isocoma menziesii var. vernioides 5,2-3 127 0 0 0

31022 Rush Juncus balticus 5, herb 127 0 0 0

31005 Wet meadow Sedge - Rush Juncus spp., Eleocharis spp.,etc. 5, herb 127 0 0 0

32099 Keckiella cordifolia 5 127 0 0 0

32223 Winterfat Krascheninnikovia lanata 5,2-3 127 0 0 0

32201 Creosote Larrea tridentata 5,2 127 0 0 0

32131 Scalebroom Lepidospartum squamatum 5, herb 127 0 0 0

32098 Prickly flox Leptodactylon californicum 5, herb 127 0 0 0

32056 Granite gilia Leptodactylon pungens 5, herb 127 0 0 0

31018 Great Basin Alkali sink grasses Leymus cinereus, Distichlis spicata, etc. 5,herb 127 0 0 0

32063 Laurel sumac Malosma laurina 5,2 127 0 0 0

31057 Sphagnum bog species Menyanthes trifoliata, Sphagnum squarrosum, etc. 5, herb 127 0 0 0

31014 Ice plant Mesembryanthemum spp. 5, herb 127 0 0 0

32086 Mimulus aurantiacus 5, herb 127 0 0 0

32445 Alpine cushion plants Misc alpine shrubs 5, herb 127 0 0 0

31047 Purple needlegrass Nassella pulchra 5, grass 127 0 0 0

41045 Tree tobacco Nicotiana glauca 5, herb 127 0 0 0

32218 Buckhorn cholla Opuntia acanthocarpa 5, herb 127 0 0 0

32204 Jumping cholla Opuntia biglovii 5, herb 127 0 0 0

32217 Golden cholla Opuntia echinocarpa 5, herb 127 0 0 0

32079 Prickly pear Opuntia littoralis 5, herb 127 0 0 0

32212 Pencil cactus Opuntia ramosissima 5, herb 127 0 0 0

32226 Mixed succulents Opuntia spp., Ferocactus spp., Echinocereus sp 5, herb 127 0 0 0

31013 Galleta Pleuraphis rigida 5, grass 127 0 0 0

32202 Arrowweed Pluchea sericea 5,3 herb 127 0 0 0

22500 Great Basin pasture/grainfield Poa pratensis, Agropyron desertorum, etc. 5, grass 127 0 0 0

31046 Braken Pteridium aquilinum 5, herb 127 0 0 0

32101 Antelope bush Purshia tridentata 5,2-3 127 0 0 0

31003 Estuarine emergent wetland Salicornia virginica, Suaeda californica, etc. 5, herb 127 0 0 0

31038 Russian thistle or tumbleweed Salsola tragus 5, herb 127 0 0 0

32015 Blue elderberry Sambucus mexicana 5,3 127 0 0 0

32449 Red elderberry Sambucus racemosa 5,3 127 0 0 0

32448 Elderberry spp. Sambucus spp. 5,3 127 0 0 0

31045 Apricot mallow Sphaeralcea ambigua 5, herb 127 0 0 0

31042 Alkali sacaton Sporobolus airoides 5, grass 127 0 0 0

31002 Native perennial grassland Stipa spp., Elymus spp., etc. 5, grass 39 0 0.02 0

31028 Medusaehead (exotic) Taeniantherum caput-medusae 6 127 0 0 0

41023 Tamarisk Tamarix spp. 3,2,5 127 0 0 0

32021 Poison oak Toxicodendron diversilobum 5,3 127 0 0 0

31008 Freshwater Sedge-Cat-tail marsh Typha spp., Carex spp., etc. 5, herb 127 0 0 0

31025 Mules ears Wyethia mollis 5, herb 127 0 0 0

32070 Xylococcus bicolor 5,2-3 127 0 0 0

32011 Mountain mahogany Cercocarpus betuloides 5,2 123 0 0 0

32106 Mountain mahogany Cercocarpus ledifolius 5,2 123 0 0 0

32113 Four-wing saltbush Atriplex canescens 5,2-3 119 0 0 0

22300 Confined Feeding Operations 8

22102 Irrigated hayfield 8

22105 Rice fields 8

22106 Pasture 8 93 0 0 0

31049 Ruderal spp. 6 93 0 0 0

31060 Northern hardpan vernal pool spp. 6 93 0 0 0

31061 Northern claypan vernal pool spp. 6 93 0 0 0

32007 Rhododendron Rhododendron macrophyllum 5,2 93 0 0 0

32135 Greasewood Sarcobatus vermiculatus 5,2 93 0 0 0

22700 Reclaimed Lakebed/Waterfowl mgmt/ag Scirpus spp., Typha spp., and cultivated grain 5, herb 93 0 0 0

42049 Parry pinyon Pinus quadrifolia 1 91 0 0 0

32023 Salal Gaultheria shallon 5,3 herb 90 0 0 0

41026 Buckeye Aesculus californica 3 88 0 0 0

41014 White alder Alnus rhombifolia 3 86 0 0 0

32401 Seviceberry Amelanchier utahensis 3,5 81 0 0 0

32060 Western choke cherry Prunus virginiana 3 78 0 0 0

32423 Western redbud Cercis occidentalis 5,3 77 0 0 0

41037 Desert willow Chilopsis linearis 3 77 0 0 0

41054 Water Birch Betula occidentalis 3 76 0 0 0

32078 Flowering ash Fraxinus dipetala 3 72 0 0 0

41040 Oregon ash Fraxinus latifolia 3 72 0 0 0

32510 Desert peach Prunus andersonii 3 72 0 0 0

41049 Bitter cherry Prunus emarginata 3 72 0 0 0

32082 Bitter cherry (Shrub form) Prunus emarginata 3 72 0 0 0
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GAP specific leaf wt in-leaf season emission factor

species Common name Scientific name Vegetation g dry leaf/m2 leaf ug/g dry leaf wt/hr @ ref conditions

code Class SLW ISO MONO MBO

41057 Pacific dogwood Cornus nuttallii 3,5 57 0 0 0

32429 Snowberry Symphoricarpos rotundifolius 5,3 56 0 0 0

32058 Southern honeysuckle Lonicera subspicata 5,3 56 0 0 0

32077 Coffeeberry Rhamnus californica 5,3-2 56 0 0 0

32316 Redberry buckthorn Rhamnus crocea 5,3-2 56 0 0 0

32327 Cascara Rhamnus purshiana 5,3-2 56 0 0 0

32081 Snowberry Symphoricarpos mollis 5,3 56 0 0 0

32053 Ocean spray or Cream bush Holodiscus discolor 5,3 48 0 0 0

32054 Cream bush Holodiscus microphyllus 5,3 48 0 0 0

32430 Huckleberry Vaccinium ovatum 5,3 39 0 0 0

32457 Thimbleberry Rubus parviflorus 5,3 37 0 0 0

32014 California blackberry Rubus ursinus 5,3 37 0 0 0

31058 Northern basalt vernal pool spp. 6 0 0 0 0

31062 Misc. vernal pool spp. 6 0 00 0

78000 Mud Flats 6 0 00 0

99200 Glaciers 6 0 00 0

55400 Bays and estuaries 6 0 00 0

77100 Dry Salt Flats 6 0 00 0

77200 Beaches 6 0 00 0

77300 Sandy areas other than beaches 6 0 0 0 0

55300 Reservoirs 6 0 00 0

55210 Intermittent lake 6 0 00 0

77401 Bare exposed lava 6 0 00 0

77500 Quarries, and gravel pits 6 0 00 0

99100 Perennial snowfields 6 0 00 0

55310 Intermittent reservoir 6 0 00 0

77400 Bare exposed rock 6 0 00 0

77600 Transitional bare areas 6 0 00 0

77700 Mixed barren land 6 0 00 0

77701 Badlands 6 0 00 0

55200 Lakes 6 0 00 0

55100 Streams and canals 6 0 00 0

Vegetation class

1=conifer

2=broadleaf evergreen

3=broadleaf deciduous

4=palm

5=shrub; "5, 2" = shrub, broadleaf evergreen

5=shrub; "5, 2-3" = shrub, broadleaf evergreen to broadleaf deciduous if cold or water stressed

5=shrub; "5, 3-2" = shrub, basically deciduous but can be evergreen if conditions favorable

"5, herb"=herbaceous (rather than woody) shrub

"5, grass" = grass

6=unknown

7=urban land use

8=ag land use
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Table 2. Crop BVOC (isoprene, monoterpenes) emission factors (ug Carbon g-1 [dry leaf weight] hr-1) at standard conditions (30 C, 1000 umole PAR m-2 s-1) 

Emission factor assignment types: 1 (measured species); 2 (genus average); 3 (family average); 4 (crop class average); 5 (no emission factor assigned)

SLW: Specific Leaf Weight (g [dry leaf weight] m-2 leaf area)

BVOC

Crop assignment BVOC SLW

Code Class Subclass Species Family Isoprene Monoterpenes type reference SLW reference

 G 1 Grain & Hay Crops barley Elyhordeum sp. Poaceae 0.010 0.010 1 h 37.00 ee

 G 2 wheat Triticum sp. Poaceae 0.000 0.000 1 k 33.70 rr

 G 3 oats Avena sp. Poaceae 0.010 0.020 1 h 39.00 hh

 G 6 misc. & mixed grain and hay Poaceae 0.007 0.010 3 r 36.57 hh

 R Rice rice Oryza sp. Poaceae 0.000 0.000 1 k 37.00 ff

 F 1 Field Crops cotton Gossypium hirsutum Malvaceae 0.000 0.700 1 k 69.44 nn

 F 2 safflower Carthamus tinctorius Asteraceae 0.000 0.030 1 k 33.30 ee

 F 3 flax Linum usitatissimum Linaceae 5 33.30 ee

 F 4 hops Humulus lupulus Cannabaceae 0.000 0.000 1 i 77.00 oo

 F 5 sugar beets Beta vulgaris Chenopodiaceae 0.000 0.000 1 e 75.00 cc

 F 6 corn (field & sweet) Zea mays Poaceae 0.000 0.030 2 n 67.00 dd

 F 7 grain sorghum Sorghum bicolor Poaceae 0.000 0.030 1 k 67.00 dd

 F 8 sudan Sorghum bicolor Poaceae 0.000 0.030 2 n 67.00 dd

 F 9 castor beans Ricinus communis Euphorbiaceae 0.000 0.000 1 i 67.00 dd

 F10 beans (dry) Phaseolus vulgaris Fabaceae 0.000 0.000 2 p 28.25 bb, ss

 F11 misc. field 0.000 0.077 4 56.14 Field Crop average

 F12 sun flowers Helianthus sp. Asteraceae 0.000 0.030 3 m 33.30 ff

 P 1 Pasture alfalfa mix Medicago sativa Fabaceae 0.000 0.200 1 k 34.30 ss

 P 2 clover Trifolium repens Fabaceae 0.000 0.000 1 d 22.20 bb

 P 3 mixed pasture Poaceae 0.000 0.020 1 l 39.00 gg

 P 4 native pasture Poaceae 0.000 0.020 1 l 39.00 gg

 P 5 induced high water table native pasture Poaceae 0.000 0.020 1 l 39.00 gg

 P 6 misc. grasses Poaceae 0.000 0.020 1 l 39.00 gg

 P 7 turf farms Fescue sp Poaceae 0.000 0.000 1 e 39.00 gg

 T 1 Truck, Nursery artichokes Cynara scolymus Asteraceae 0.000 0.030 3 m 33.30 ee

 T 2 & Berry Crops asparagus Asparagus officinalis Liliaceae 0.000 0.000 1 i 123.30 ii

 T 3 green beans Phaseolus vulgaris Fabaceae 0.000 0.000 1 k 28.25 bb, ss

 T 4 colecrops Brassica sp. Cruciferae 0.000 0.000 1 e 144.30 ii

 T 6 carrots Daucus carota Umbelliferae 0.000 0.900 1 k 70.00 ii

 T 7 celery Apium graviolens Umbelliferae 0.000 0.900 3 q 70.00 kk

 T 8 lettuce Latuca sativa Asteraceae 0.000 0.000 1 j 49.30 ll

 T 9 melons, squash, cucumbers Cucurbitaceae 5 85.47 nn

 T10 onion, garlic Allium sp. Amaryllidaceae, Liliaceae 0.000 0.000 1 j 123.30 ii

 T11 peas Pisum sativum Fabaceae 0.000 0.000 3 p 28.25 bb, ss

 T12 potatoes Solanum tuberosum Solanaceae 0.000 0.010 1 g 35.00 aa

 T13 sweet potatoes Ipomoea batatas Convolvulaceae 5 35.00 aa

 T14 spinach Spinacia oleracea Chenopodiaceae 0.000 0.000 3 o 144.30 ii

 T15 tomatoes Lycopersicon esculentum Solanaceae 0.000 20.000 1 k 80.22 nn

 T16 flower, nursery, Christmas tree farm 5

 T17 mixed 0.004 1.447 4 83.08 Truck crop average

 T18 misc. truck 0.004 1.447 4 83.08 Truck crop average

 T19 bushberries Rubus ursinus Rosaceae 0.080 0.000 1 c 37.31 nn

 T20 strawberries Fragaria sp. Rosaceae 0.000 0.000 1 e 82.99 pp

 T21 peppers Capsicum sp. Solanaceae 0.000 10.000 3 80.20 qq

 T22 broccoli Brassica oleracia Cruciferae 0.000 0.000 1 e 144.30 jj

 T23 cabbage Brassica oleracia Cruciferae 0.000 0.000 1 e 144.30 ii

 T24 cauliflower Brassica oleracia Cruciferae 0.000 0.000 1 e 144.30 jj

 T25 brusselsprouts Brassica oleracia Cruciferae 0.000 0.000 1 e 144.30 jj

 D 1 Deciduous Fruits apples Malus sp. Rosaceae 0.000 0.100 3 a 86.21 nn

 D 2 and Nuts apricots Prunus armeniaca Rosaceae 0.000 0.100 1 a 71.94 nn

 D 3 cherries Prunus avium Rosaceae 0.000 0.100 1 a 71.94 nn

 D 5 peach, nectarine Prunus persica Rosaceae 0.000 0.100 1 a 71.94 nn

 D 6 pears Pyrus sp. Rosaceae 0.000 0.000 2 a 71.94 nn

 D 7 plums Prunus domestica Rosaceae 0.000 0.030 1 k 71.94 nn

 D 8 prunes Prunus domestica Rosaceae 0.000 0.030 1 k 71.94 nn

 D 9 figs Ficus carica Moraceae 27.000 0.200 2 a 81.92 nn

 D10 misc. decid. fruit 2.455 0.992 3 81.23 Tree crop average

 D12 almonds Prunus dulcis Rosaceae 0.000 0.050 1 k 99.50 nn

 D13 walnuts Juglans regia Juglandaceae 0.000 1.800 1 k 40.20 nn

 D14 pistacios Pistacia vera Anacardiaceae 0.000 8.400 1 k 154.06 nn
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix D - Modeling and 

 Attainment Demonstrations 

D-121

 C 1 Citrus grapefruit Citrus paradisi Rutaceae 0.000 1.500 2 a 140.74 nn

 C 2 and Subtropical lemons Citrus limonia Rutaceae 0.000 1.500 2 a 140.74 nn

 C 3 oranges Citrus sinensis Rutaceae 0.000 0.900 2 a 140.74 nn

 C 4 dates Phoenix dactylifera Arecaceae 15.800 0.000 1 a 290.00 mm

 C 5 avocados Persea americana Lauraceae 0.000 0.000 1 a 73.39 nn

 C 6 olives Olea europea Oleaceae 0.000 0.300 1 a 78.34 nn

 C 7 misc. subtropical 8.089 1.489 4 143.95 Subtropical average

 C 8 kiwis Actinidia deliciosa Actinidiaceae 5 77.00 oo

 C 9 jojoba Simmondsia chinensis Buxacea 0.000 0.000 1 i 225.00 tt

 C10 eucalyptus Eucalyptus sp. Myrtaceae 57.000 9.200 2 b 129.60 nn

 V 1 Vineyards table grape Vitis vinifera Vitaceae 0.000 0.000 1 k 66.18 nn

 V 2 wine grape Vitis vinifera Vitaceae 0.002 0.002 1 f 66.18 nn

 V 3 raisin grape Vitis vinifera Vitaceae 0.000 0.000 1 k 66.18 nn

 I Idle idle Poaceae 0.000 0.020 3 l 39.00 gg

 I 2 idle Poaceae 0.000 0.020 3 k 39.00 gg

BVOC emission factor reference Specific Leaf Weight (SLW) factor reference

a Benjamin et al. 1996 aa Cao and Tibbitts 1997

b Benjamin et al. 1996 (E. globus) bb Clark et al. 1997

c Drewitt et al. 1998 cc Cole 1974

d Flyckt et al. 1980 dd Danalatos et al. 1994

e Hewett and Street 1992 ee de la Rosa et al. 2000, sunflower surrogate

f Koenig et al. 1995 ff de la Rosa et al. 2000

g Lamb et al. 1993 gg Garnier et al. 1997

h Lamb et al. 1993 and Pierce et al. 1998 hh Garnier et al. 1997, grass surrogate 

i Rassmussen 1978 ii Jovanovic et al. 1999

j Winer et al. 1989 jj Jovanovic et al. 1999, cabbage surrogate

k Winer et al. 1992 kk Jovanovic et al. 1999, carrot surrogate

l Winer et al. 1992 ("grasslands, annual") ll Jovanovic et al. 1999, lettuce surrogate

m Winer et al 1992 (safflower) mm Miller and Winer 1984

n Winer et al 1992 (sorghum) nn Nowak 1998

o Winer et al. 1989 (beet); Hewitt and Street 1992 oo Nowak 1998, structural class

p Winer et al. 1992 (bean) pp Nowak 1998, Rosaceae average

q Winer et al. 1992 (carrot) qq Nowak 1998, tomato surrogate

r Winer et al. 1992 (wheat) rr Rebetzke and Richards 1999

ss Robinson et al. 1992.

tt Wardlaw et al. 1983

Table 3. GAP regional urban land use reference BVOC emission rates.

GAP Urban land use reference BVOC emission rates

urban land use Description Isoprene (mg/m2/hr) Monoterpene (mg/m2/hr)

code Oakland Sacramento Fresno Oakland Sacramento Fresno

11100 residential 1.91 1.28 0.31 0.27 0.76 0.16

11200 commercial + services 0.23 0.00 0.05 0.04 0.29 0.01

11300 industrial 0.23 0.00 0.05 0.04 0.29 0.01

11400 transportation + utilities 1.34 0.01 0.05 0.22 0.00 0.01

11500 industrial and commercial complexes 0.23 0.00 0.05 0.04 0.29 0.01

11600 mixed urban 2.00 1.04 0.11 0.28 0.67 0.05

11700 other urban 2.00 1.04 0.11 0.28 0.67 0.05
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix D Modeling and Attainment 

Demonstrations 

D-122 

Table 4. Canopy-scale reference BVOC emission rates for BEIGIS grid cells A and C, derived from emission factor, specific leaf weight, GAP land cover and satellite LAI inputs

GAP polygon ID 6658

Primary assemblage

Emission Factor2 Primary Assemblage Co-species Satellite LAI3 Leafmass Density4 Emission Rate5

: cell A Emission Rate5: cell C

Species SLW1 MON MBO ISO Fractional Cover Weighting cell A cell C cell A cell C MON MBO ISO MON MBO ISO

Pinus ponderosa 91 4 25 0 0.45 0.333 1.4 1.4 19 19 0.08 0.48 0 0.08 0.48 0

Abies concolor 98 3 0 0 0.45 0.333 1.4 1.4 21 21 0.06 0 0 0.06 0 0

Quercus kelloggii 103 1 0 54 0.45 0.333 1.4 1.4 22 22 0.02 0 1.17 0.02 0 1.17

Secondary assemblage Emission Factor Secondary Assemblage Co-species Satellite LAI Leafmass Density Emission Rate: cell A Emission Rate: cell C

Species SLW MON MBO ISO Fractional Cover Weighting cell A cell C cell A cell C MON MBO ISO MON MBO ISO

Pinus lambertiana 91 4 0 0 0.25 0.333 1.4 1.4 11 11 0.04 0 0 0.04 0 0

Pinus ponderosa 91 4 25 0 0.25 0.333 1.4 1.4 11 11 0.04 0.27 0 0.04 0.27 0

Pseudotsuga menziesii. 55 3 0 1 0.25 0.333 1.4 1.4 6 6 0.02 0 0.01 0.02 0 0.01

Tertiary assemblage Emission Factor Secondary Assemblage Co-species Satellite LAI Leafmass Density Emission Rate: cell A Emission Rate: cell C

Species SLW MON MBO ISO Fractional Cover Weighting cell A cell C cell A cell C MON MBO ISO MON MBO ISO

Ceanothus integerrimus 127 2 0 0 0.35 0.5 1.4 1.4 31 31 0.06 0 0 0.06 0 0

Arctostaphylos viscida 127 0 0 0 0.35 0.5 1.4 1.4 31 31 0 0 0 0 0 0

NA NA NA NA NA NA NA

1

 Specific Leaf Weight, g dry leaf weight/m2 leaf Total LMD Total Emission Rate: cell A Total Emission Rate: cell C 2

 MON: ug monoterpene/g dry leaf weight/hr, MBO: ug Carbon/g dry leaf weight/hr, ISO: ug isoprene/g dry leaf weight/ cell A cell C MON MBO ISO MON MBO ISO

at reference conditions 30 C and 1000 micromoles/m2/s PAR 151 151 0.33 0.74 1.17 0.33 0.74 1.17 3

 Leaf Area Index, m2 leaf area/m2 land area 4

 LMD, g dry leaf weight/m2 land area 5

 MON: mg monoterpene/m2 land/hr, MBO: mg Carbon/m2 land/hr, ISO: mg isoprene/m2 land/hr, at reference conditions.

Table 5. Canopy-scale reference BVOC emission rates for BEIGIS grid cells B and D, derived from emission factor, specific leaf weight, GAP land cover and satellite LAI inputs

GAP polygon ID 6658

Primary assemblage

Emission Factor2 Primary Assemblage Co-species Satellite LAI3 Leafmass Density4 Emission Rate5

: cell B Emission Rate5: cell D

Species SLW1 MON MBO ISO Fractional Cover Weighting cell B cell D cell B cell D MON MBO ISO MON MBO ISO

Pinus ponderosa 91 4 25 0 0.55 0.333 6.6 3.8 110 63 0.44 2.75 0 0.25 1.58 0

Abies concolor 98 3 0 0 0.55 0.333 6.6 3.8 118 68 0.36 0 0 0.20 0 0

Quercus kelloggii 103 1 0 54 0.55 0.333 6.6 3.8 125 72 0.12 0 6.72 0.07 0 3.87

Secondary assemblage Emission Factor Secondary Assemblage Co-species Satellite LAI Leafmass Density Emission Rate: cell B Emission Rate: cell D

Species SLW MON MBO ISO Fractional Cover Weighting cell B cell D cell B cell D MON MBO ISO MON MBO ISO

Pinus ponderosa 91 4 25 0 0.35 0.333 6.6 3.8 70 40 0.28 1.75 0 0.16 1.01 0

Abies concolor 98 3 0 0 0.35 0.333 6.6 3.8 75 43 0.23 0 0 0.13 0.00 0

Arctostaphylus patula 127 0 0 0 0.35 0.333 6.6 3.8 98 56 0 0 0 0 0 0

Tertiary assemblage Emission Factor Secondary Assemblage Co-species Satellite LAI Leafmass Density Emission Rate: cell B Emission Rate: cell D

Species SLW MON MBO ISO Fractional Cover Weighting cell B cell D cell B cell D MON MBO ISO MON MBO ISO

Arctostaphylus patula 127 0 0 0 0.15 0.5 6.6 3.8 63 36 0 0 0 0 0 0

Ceanothus cordulatus 127 2 0 0 0.15 0.5 6.6 3.8 63 36 0.13 0 0 0.07 0 0

NA NA NA NA NA

1

 Specific Leaf Weight, g dry leaf weight/m2 leaf Total LMD Total Emission Rate: cell B Total Emission Rate: cell D 2

 MON: ug monoterpene/g dry leaf weight/hr, MBO: ug Carbon/g dry leaf weight/hr, ISO: ug isoprene/g dry leaf weight/ cell B cell D MON MBO ISO MON MBO ISO

at reference conditions 30 C and 1000 micromoles/m2

/s PAR 722 416 1.55 4.50 6.72 0.89 2.59 3.87 3

 Leaf Area Index, m2 leaf area/m2 land area 4

 LMD, g dry leaf weight/m2 land area 5

 MON: mg monoterpene/m2 land/hr, MBO: mg Carbon/m2 land/hr, ISO: mg isoprene/m2 land/hr, at reference conditions.
Cap on Stationary Source 

Growth By Pollutant 

APPENDIX E 
❖
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix E - Cap on Stationary Source 

 Growth by Pollutant 

E-1 

Cap on Stationary Source Growth by Pollutant 

 

NOX 

 2000 2003 2006 2010

Total Stationary Source 

NOX Emissions (Grown) 156.58 164.20 170.00 172.34

NOX Growth from 2000 7.6 13.4 15.8

NOX Growth per period 7.6 5.8 2.3

 

ROG 

 2000 2003 2006 2010

Total Stationary Source 

ROG Emissions (Grown) 95.25 98.37 102.53 104.98

ROG Growth from 2000 3.1 7.3 9.7

ROG Growth per period 3.1 4.2 2.5
❖
APPENDIX F Suggested Control Measures
❖
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix F- Suggested Control Measures 

F-1

SUMMARY OF PUBLIC SUGGESTIONS FOR EMISSION CONTROL MEASURES 

 TO BE CONSIDERED FOR IMPROVING OZONE AIR QUALITY 

Control Measure 

Suggestion 

Source Ozone 

Precursor 

District 

Authority? 

District Response 

Stringent requirements 

such as low emissions 

thresholds would help us 

improve air quality as it 

has done in the South 

Coast Air Basin. The 

District should seek every 

possible means to reduce 

air emissions; selfclassifying as extreme 

would help us implement 

more stringent measures, 

which would in turn help 

meet the federal 8-hr 

ozone standard. 

July 2003 

Workshop 

VOC and 

NOx 

Yes The current plan is directed towards 

demonstrating attainment of the 

federal 1-hour ozone standard. 

California thresholds applicable to 

the District are already as stringent 

as federal extreme thresholds except 

for the offset ratio, which would go 

from 1.3 to 1 to 1.5 to 1. A change in 

threshold is also affected by the final 

rule implementing the 8-hour ozone 

standard. 

How are emissions from 

landscaping equipment 

addressed? 

July 2003 

Workshop 

VOC and 

NOx 

Limited Staff responded that most of the 

reductions result from equipment 

change-out. The ARB has 

significantly reduced emissions from 

lawn equipment engines. Using allelectric equipment is an option, but it 

may not be feasible for commercial 

landscaping operations. The District 

is planning to look at emissions from 

leaf blowers. 

Does the ozone plan 

consider emission 

sources such as trucks 

that are allowed to enter 

the United States from 

Mexico? Does the plan 

also account for any 

federal relaxation of 

emissions standards? 

January 2004 

Workshop 

VOC and 

NOx 

No Any emission estimates that change 

during plan development will be 

incorporated to the extent possible 

(at some point in time the inventory is 

locked and no further changes are 

considered—see Chapter 3). These 

changes can include new sources 

such as international trucks or 

changes in federal or state laws that 

increase or decrease estimated 

emissions from affected sources. 

Seventeen percent of 

volatile organic 

compound (VOC) 

emissions come from 

animal manure; could 

you address control 

measures such as 

anaerobic digestion to 

reduce these emissions? 

July 2003 

Workshop 

VOC Yes The District is looking at anaerobic 

digestion as one of the control 

measures for confined animal feeding 

operations. Results from studies 

underway will allow the District to better 

estimate emissions and to develop 

viable control measures. This Extreme 

OADP discusses control measures for 

this source category in Chapter 4. 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix F- Suggested Control Measures 

F-2

SUMMARY OF PUBLIC SUGGESTIONS FOR EMISSION CONTROL MEASURES 

 TO BE CONSIDERED FOR IMPROVING OZONE AIR QUALITY 

Control Measure 

Suggestion 

Source Ozone 

Precursor 

District 

Authority? 

District Response 

The Ozone Plan should 

include an emissions rule 

for new micropower 

(electric generators used 

as an alternative to or 

supplement of the state 

power grid and located 

near or at the end point 

of electricity use), or 

distributed generation 

units located in the San 

Joaquin Valley. 

January 2004 

Workshop 

VOC and 

NOx 

Yes A rule addressing this request has 

been included in the Extreme OADP. 

See Table 4-1 in Chapter 4. 

Expanding transit 

services between the Bay 

Area, Sacramento and 

the Valley is a long term 

and laudable goal. In the 

short tem, coordination of 

the existing rideshare 

programs in the Bay 

Area, Sacramento, and 

the San Joaquin regions 

can reduce air pollution 

and congestion. 

Letter to 

District 

VOC and 

NOx 

No Suggestion noted and will be 

forwarded to agencies with authority 

to implement. 

Voluntary removal of 

long-haul trucks from 

Highway 99 and 

Interstate 5 through the 

SJVAB by constructing 

and operating travel 

centers on these 

corridors that give time of 

day discounts for 

stopping at the travel 

centers 

Letter to 

District 

VOC and 

NOx 

Yes Through its incentive programs, the 

District is working on truck stop 

electrification to reduce emissions 

from idling trucks. However, these 

projects use existing locations of 

travel centers and do not address the 

part of the suggestion that calls for 

more strategically located travel 

centers to reduce truck traffic during 

commute hours. 

Rather than moving 

truckloads of goods in the 

usual manner on 

highways, the District 

should look at the 

emission reduction 

benefits of using smaller 

day-cab tractors to load 

and unload trailers at 

customer facilities in 

preparation for 

transportation across 

states. 

Letter to 

District 

NOx and 

VOC 

No Suggestion noted and will be 

forwarded to agencies with authority 

to implement. 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix F- Suggested Control Measures 

F-3

SUMMARY OF PUBLIC SUGGESTIONS FOR EMISSION CONTROL MEASURES 

 TO BE CONSIDERED FOR IMPROVING OZONE AIR QUALITY 

Control Measure 

Suggestion 

Source Ozone 

Precursor 

District 

Authority? 

District Response 

The District should create 

a rule that controls 

emissions from drivethrus. 

July 2003 

Workshop; 

Verbal 

comment to 

District Staff 

NOx and 

VOC 

No Emissions from drive-throughs could 

be controlled by land use decisions 

on drive-through restaurants (e.g., 

banning them in certain areas), 

restricting operating times of the 

drive-through component, or 

reducing emissions from vehicles 

using drive-through features. The 

first two types of controls listed are 

primarily under the purview of local 

government land use decisions, and 

the third is under the authority of the 

California Air Resources Board. 

Suggestion noted and will be 

forwarded to appropriate agencies. 

SB700 requires us to 

modify our burn rules by 

July 2005. The District 

needs to include this in 

the rules being studied 

for the ozone plan. 

January 2004 

Workshop 

VOC and 

NOx 

Yes Open burning rules are included in 

this Extreme OADP (Chapter 4). 

If the state would give a 

fuel tax cut on a fuel 

incentive to companies 

and truck owners coming 

and going to Los Angeles 

traveling on Highway 395 

it would eliminate a lot of 

pollution in the central 

valley due to trucks. 

Letter to 

District 

VOC and 

NOx 

No This general concept is included in 

Chapter 4 as an idea to study in the 

future to determine if a viable control 

measure could be developed. 

All sources contributing 

to air pollution should pay 

to clean up the air, not 

just industry or 

agriculture. Perhaps a 

fee could be charged to 

new residents who move 

to the area or who drive 

long distances, the 

collected funds used for 

air quality improvement 

programs. 

December 

2003 

Workshop on 

Extreme 

Nonattainment 

VOC and 

NOx 

Yes This concept is being addressed in 

the Indirect Source Rules (ISR) now 

being developed by the District. 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix F- Suggested Control Measures 

F-4

SUMMARY OF PUBLIC SUGGESTIONS FOR EMISSION CONTROL MEASURES 

 TO BE CONSIDERED FOR IMPROVING OZONE AIR QUALITY 

Control Measure 

Suggestion 

Source Ozone 

Precursor 

District 

Authority? 

District Response 

Buses are driving around 

half full and the 

schedules are 

inadequate; we need to 

work on a commuter 

friendly transportation 

system to where it is the 

first choice over cars for 

commuting. 

December 

2003 

Workshop on 

Extreme 

Nonattainment 

VOC and 

NOx 

Limited Operation Clean Air has started work 

addressing non-regulatory air quality 

improvements such as these. The 

Regional Transportation Planning 

Agencies evaluate and implement 

measures to improve transit ridership. In addition, the District is 

getting involved in ISR & fleet rules to 

help reduce other mobile source 

emissions. 

Regarding the issue of 

increased truck traffic in 

the SJVAB, the District 

should investigate other 

avenues for moving 

goods, such as small 

barges on our system of 

irrigation canals. This 

would represent a low- or 

no-emission process for 

moving goods. 

December 

2003 

Workshop on 

Extreme 

Nonattainment 

VOC and 

NOx 

No Suggestion noted. 

The District should 

consider using natural 

sources as buffer zones 

to capture some of these 

ozone emissions after 

they have been released. 

The uses of buffer zones 

have already been 

examined by cities and 

industry. The District 

should look at planting 

extremely fast growing 

trees with deep root 

systems of hardwood that 

will improve air quality. 

August 2004 

Workshop on 

Extreme 

Ozone 

Attainment 

Demonstration 

Plan 

No No The District will add a future study 

measure regarding the role of urban 

landscape management in improving 

air quality. 

The District should 

include Alternative 

Emission Reduction 

Programs as a viable and 

proactive approach to 

future air quality 

planning. 

Written 

comments, 

submitted 

August 25, 

2004 

Yes Yes The District will investigate 

alternative approaches and will add 

some text to the section. 

 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

 

SJVUAPCD Appendix F- Suggested Control Measures 

F-5

SUMMARY OF PUBLIC SUGGESTIONS FOR EMISSION CONTROL MEASURES 

 TO BE CONSIDERED FOR IMPROVING OZONE AIR QUALITY 

Control Measure 

Suggestion 

Source Ozone 

Precursor 

District 

Authority? 

District Response 

The District should 

consider creating urban 

tree planting guidelines to 

facilitate the urban 

landscape’s role in 

improving air quality. 

August 2004 

Workshop on 

Extreme 

Ozone 

Attainment 

Demonstration 

Plan 

VOC Limited, but 

suggestion is 

for guidelines 

The District will add text to the plan 

regarding a measure for future study 

in the area of research, education 

and outreach regarding the role of 

urban landscapes and agricultural 

land use on ozone air quality. 
❖
APPENDIX G Clean Air Act Requirements 
❖
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix G - Clean Air Act Requirements

G-1 

G.1 Federal Clean Air Act – Plan Requirements 

The reclassification of the San Joaquin Valley Air Basin SJVAB) to extreme 

requires the submittal of an Extreme Ozone Attainment Demonstration Plan 

(OADP). Under the Federal Clean Air Act (CAA) extreme area plans are 

required to meet all the requirements for severe area plans plus the requirements 

for extreme areas, including but not limited to: (1) A 10 ton per year major source 

definition; (2) Additional reasonably available control technology (RACT) rules for 

sources subject to the new lower major source cutoff; (3) A new source review 

offset requirement of at least 1.5 to 1; (4) A rate of progress demonstration of 

emission reductions of ozone precursors of at least 3 percent per year from 2005 

until the attainment date; (5) Clean fuels for boilers as required for at CAA 

section 182(e)(3); and contingency measures. In addition, the plan must address 

the general nonattainment plan requirements in CAA section 172(c). The 

Extreme OADP for the SJVAB must also contain adopted regulations and may 

also contain enforceable commitments to the extent consistent EPA guidance, 

sufficient to make the required rate of progress and to attain the 1-hour ozone 

national ambient air quality standards (NAAQS) as expeditiously as practicable, 

but no later than November 15, 2010. 

For the Extreme Ozone Attainment Demonstration Plan (OADP) these 

requirements are listed and very briefly described in Tables G-1 and G-2, as well 

as where the elements can be found in the plan. 

G.2 California Clean Air Act Requirements 

The California Clean Air Act was signed into law in 1988 and, for the first time, 

clearly spelled out in statute California's air quality goals, planning mechanisms, 

regulatory strategies, and standards of progress. The California Clean Air Act 

provides the State with a comprehensive framework for air quality planning 

regulation. 

Section 40910 of the California Health and Safety Code (CH&SC) requires air 

pollution control districts in the state to achieve and maintain state ambient air 

quality standards for ozone, carbon monoxide, sulfur dioxide and nitrogen dioxide 

at the earliest practicable date. Section 40911 of the CH&SC requires all districts 

designated as nonattainment for the state standards for ozone, carbon 

monoxide, sulfur dioxide, or nitrogen dioxide to prepare and submit a plan for 

attaining and maintaining the standards to the California Air Resources Board 

(ARB). Section 40924 (b) of the CH&SC requires districts to prepare a report 

every three years summarizing progress in meeting the schedules for 

developing, adopting, and implementing the air pollution control measures 

contained in each district’s plan for attaining the California air quality standards. 

Section 40925(a) of the CH&SC requires districts to review and revise their 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix G - Clean Air Act Requirements

G-2 

original 1991 Air Quality Attainment Plan (AQAP) to correct for deficiencies in 

meeting the interim measures of progress incorporated into the plan pursuant 

Section 40914 [emission reductions], and to incorporate new data or projections 

into the Plan. This requirement, termed a Triennial AQAP Revision, is on the 

same reporting schedule as the Triennial Progress Report, and is usually 

combined with the progress report. 

Chapter 8 of the Extreme OADP represents the third Triennial Progress Report 

and Plan Revision for the District; as such, it covers the period 2000-2002, and 

its original due date was December 31, 2003. However, for Districts preparing 

State Implementation Plan (SIP) submittals in 2004, ARB revised the due date to 

be the time of the 2004 SIP submittal. Table G-3 briefly describes the various 

elements required in State Plans and their location in the Extreme OADP. 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix G - Clean Air 

G-3 

Table G-1: General Nonattainment Plan Requirements 

Required Plan Element Description Loc

Reasonably Available Control Technologies (RACT) [Section 172(c)(1) 

The plan should provide for the implementation of all reasonably available control measures as expeditiously as possible, including reduction in emissions from existing sources through the adoption of reasonably available control technology. 

Chapter 4, 

Reasonable Further Progress [Section 172(c)(2)] 

The plan requires reasonable further progress in emission reduction. 

Chapter 4 – measure emChapter 7- pollutants o

Inventory [Section 172(c)(3)] 

The plan should include a comprehensive, accurate, current inventory of actual emissions from all sources of the relevant pollutant or pollutants in such area, including periodic revisions as the Administrator may determine necessary to assure that the requirements of this part are met. 

Chapter 3 

Identification and Quantification [Section 172(c)(4)] 

The plan should identify and quantify the emissions, if any, of any such pollutant or pollutants, which will be allowed, in accordance with section 173(a)(1)(B), from the construction and operation of major new or modified stationary sources in each such area. The plan shall demonstrate to the satisfaction of the EPA that the emissions quantified for this purpose will be consistent with the achievement of reasonable further progress and will not interfere with attainment of the applicable national ambient air quality standard by the applicable attainment date. 

Chapter 3, 

Permits for new and modified stationary sources [Section 172(c)(5)] 

Such plan provisions shall require permits for the construction and operation of new or modified major stationary sources anywhere in the nonattainment area, in accordance with section 173. 

Chapter 3, 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix G - Clean Air 

G-4 

Table G-1: General Nonattainment Plan Requirements-cont. 

Required Plan Element Description Loc

Other Measures [Section 172(c)(6)] 

Such plan provisions shall include enforceable emission limitations, and such other control measures, means or techniques (including economic incentives such as fees, marketable permits, and auctions of emission rights), as well as schedules and timetables for compliance, as may be necessary or appropriate to provide for attainment by the applicable date. 

Chapter 4, 

Compliance with Section 110(a)(2) [Section 172(c)(7)] 

Compliance with section 110(a)(2).- Such plan provisions shall also meet the applicable provisions of section 110(a)(2). 

Chapter 4 Chapter 2, Chapter 3, 

Equivalent Techniques [Section 172(c)(8)] 

Upon application by any State, the EPA may allow the use of equivalent modeling, emission inventory, and planning procedures, unless the EPA determines that the proposed techniques are, in the aggregate, less effective than the methods specified by the EPA. 

Chapter 5, 

Contingency Measures [Section 172(c)(9)] 

The plan should include specific measures to be undertaken if the area fails to make reasonable further progress, or to attain the national primary ambient air quality standard by the applicable attainment. Such measures shall be included in the plan revision as contingency measures to take effect in any such case without further action by the State or the EPA 

Chapter 4, 
EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN 

SJVUAPCD Appendix G - Clean Air 

G-5 

Table G-2: Extreme Area Plan Requirements for Ozone Nonattainment Areas 

Required Plan Element Description Loc

Inventory [Section 182(a)(1)] Submit a comprehensive, accurate, current inventory of actual emissions from all sources Chapter 3, Periodic Inventory [Section 182(a)(3)(A)] 

Submission of a revised inventory no later than the end of a three-year period after submission of the inventory. 

Chapter 3, Chapter 7, 

General Offset requirements [Section 182(e)(1)] 

The ratio of total emission reductions of volatile organic compounds (VOCs) to total increased emissions of such air pollutant shall be at least 1.5 to 1, except that if the State plan requires all existing major sources in a nonattainment area to use best available control technology for the control of VOCs, the ratio shall be at least 1.2 to 1. 

Chapter 1, Chapter 3, 

Plan provisions for Reasonable Further Progress (Requires: determination of baseline emissions, new source review provisions, and credibility of reductions) [Section 182(b)(1)] 

The plan should provide for specific annual reductions in emissions of volatile organic compounds and oxides of nitrogen as necessary to attain the national primary ambient air quality standard for ozone by the attainment date applicable under this Act. 

Chapter 7 Section 7.4 

Reasonably available control technology [Section 182(b)(2)] 

Implementation of control technologies for VOC sources covered by control technique guidelines (CTG) documents and all other major stationary sources of VOCs that are located in the area 

Chapter 4 
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G-6 

Table G-2: Extreme Area Plan Requirements for Ozone Nonattainment Areas- co

Required Plan Element Description Loc

Enhanced Monitoring [Section 182(c)(1)] 

Follow Federal guidelines for monitoring of concentrations of ozone Chapter 2, 

Attainment demonstration [Section 182(c)(2)(A)] 

A demonstration that the plan will provide for attainment of the national ambient air quality standard by the applicable attainment date. The demonstration must be based on photochemical grid modeling. 

Chapter 5, 

Reasonable Further Progress (RFP) demonstration [Section 182(c)(2)(B)] 

A demonstration that the plan will result in VOC emissions reductions from the baseline emissions of at least three percent. Chapter 7 

Enhanced vehicle inspection and maintenance program [Section 182(c)(3)] 

The State shall provide for an enhanced program to reduce hydrocarbon emissions and NOx emissions from in-use motor vehicles registered in each urbanized area 

Chapter 4, Chapter 4, 

Contingency Provisions [Section 182(c)(9)] 

The plan shall provide for the implementation of specific measures to be undertaken if the area fails to meet any applicable milestone. Such measures shall take effect without further action by the State or the EPA upon a failure to meet the applicable milestone. 

Chapter 4, 

Vehicle Miles Traveled [Section 182(d)(1)] 

Transportation control strategies/Transportation Control measures Chapter 4, 
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G-7 

Table G-2: Extreme Area Plan Requirements for Ozone Nonattainment Areas- co

Required Plan Element Description Loc

Modifications at a Major Source [Section 182(e)(2)] 

Any change (as described in Section 111(a)(4) of the CAA) at a major stationary source which results in any increase in emissions from any discrete operation, unit, or other pollutant emitting activity at the source shall be considered a modification for purposes of Section 172(c)(5) and Section 173(a) of the CAA, except that for purposes of complying with the offset requirement pursuant to Section 173(a)(1), any such increase shall not be considered a modification if the owner or operator of the source elects to offset the increase by a greater reduction in emissions of the air pollutant concerned from other discrete operations, units, or activities within the source at an internal offset ratio of at least 1.3 to 1. The offset requirements of this part shall not be applicable in Extreme Areas to a modification of an existing source if such modification consists of installation of equipment required to comply with the applicable implementation plan, permit, or this act. 

Chapter 1, 

Use of clean fuels or advanced control technology [Section 182(e)(3)] 

Each new, modified, and existing electric utility and industrial and commercial boiler which emits more than 25 tons per year of oxides of nitrogen, shall (a) burn as its primary fuel natural gas, methanol, or ethanol  (or a comparably low polluting fuel), or (b) use advanced control technology or other comparably  effective control methods) for reduction of emissions of  oxides of nitrogen 

Chapter 4, 

Traffic Control Measures [Section 182(e)(4)] 

For extreme areas, each plan may contain provisions establishing traffic control measures applicable during heavy traffic hours to reduce the use of high polluting vehicles or heavy-duty vehicles, notwithstanding any other provision of law. 

Chapter 4, reasonably measures fof which manot required 
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G-8 

Table G-2: Extreme Area Plan Requirements for Ozone Nonattainment Areas- co

Required Plan Element Description Loc

New Technologies (Undefined Future Control Measures) [Section 182(e)(5)] 

An Extreme Area Plan may include provisions anticipating the development of new control techniques or improvement of existing control technologies. These contingency measures must be defined no later than three years before proposed implementation of the plan provisions. 

Chapter 4, Chapter 5, (This eleme

Milestones [Section 182(g)] 

Provide a report every three years after the designation to determine whether the nonattainment area has achieved a reduction in emissions during the preceding interval equivalent to the total emission reductions required to be achieved by the attainment date given in the plan. 

Chapter 7, 

Failure to Attain Fee -Enforcement under Section 185 

If area fails to attain the standard by November 15, 2010, major stationary source of VOCs in the area shall pay a fee to the state of $5000/ton of VOC emissions per calendar year in excess of 80% of a baseline defined as the actual or allowable emissions. 

Chapter 1, 
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G-9 

Table G-3: California Clean Air Act Planning Requirements 

Required California 

Plan Element 

Description Loc

Indirect and area source controls An indirect and area source control program 

[H&SC 40918(a)(4)] 

Chapter 8 Section 8.5 

Best available retrofit control technology Best available retrofit control technology (BARCT) for existing sources of specified sizes 

[H&SC 40918(a)(2)] 

Chapter 8, Table 8-2 

New Source Review A program to mitigate all emissions from new and modified permitted sources 

[H&SC 40918(a)(1)] 

Chapter 3 Section 3.4 Section 3.4

Transportation control measures Transportation control measures as needed to meet California plan requirements 

[H&SC 40918(a)(3)] 

Chapter 8 Section 8.5 

Clean fleet vehicle programs Significant use of low-emission vehicles by fleet operators 

[H&SC 40918(a)(4)] 

Chapter 8 Section 8.5 

Rate of Progress 

Reducing pollutants contributing to nonattainment by five percent per year for all feasible control measures and an expeditious adoption schedule. [H&SC 40914] 

Not applica

Public education programs Public education programs 

[H&SC 40918(a)(6)] 

Chapter 6 

Per-capita exposure Reducing per-capita population exposure to severe nonattainment pollutants according to a prescribed schedule 

[H&SC 40920(c)] 

Chapter 8 Section 8.3 Figure 8-10 
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Table G-3: California Clean Air Act Planning Requirements-cont. 

Required California 

Plan Element 

Description Loc

Any other feasible controls 

Any of the feasible controls that can be implemented or for which implementation can begin, within 10 years of adoption date of the most recent air quality plan [H&SC 40920.5 (c)] 

Chapter 8 Section 8.5 

Control measure ranking Ranking control measures by cost-effectiveness and implementation priority 

[H&SC 40922] 

Chapter 8 Section 8.6 
APPENDIX H Comments and Responses 
❖
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SJVUAPCD Appendix H - Comments and Responses 

H-1

SUMMARY OF COMMENTS AND RESPONSES 

MADE OR SUBMITTED DURING PUBLIC REVIEW OF THE 

DRAFT EXTREME OZONE ATTAINMENT DEMONSTRATION PLAN FOR 

THE SAN JOAQUIN VALLEY AIR BASIN 

September 7, 2004 

The San Joaquin Valley Unified Air Pollution Control District (District) released 

the Draft Extreme Ozone Attainment Demonstration Plan (OADP) for public 

review on July 30, 2004. In conjunction with releasing the plan, the District 

announced a series of three workshops to be held on the Draft Extreme OADP

on August 12 and 13, 2004. The District mailed about 1200 notices to the 

ozone plan mailing list announcing plan availability and workshop dates, and 

also used the notice as a legal advertisement that appeared in the eight major 

San Joaquin Valley newspapers. District staff conducted the workshops in 

person in the Central Region (Fresno), and via video-teleconference links to 

Bakersfield and Modesto. About 27 people attended the first day of workshops 

(August 12, 2004) and about 20 attended the second day workshop (August 13, 

2004). The August 12 workshops were held at 1:00 pm and 6:30 pm, and the 

August 13th workshop was held at 10:00 am. The evening workshop on August 

12th was a community meeting geared toward simplified presentations and 

discussions of the topics. The comment period for the Draft EOADP ended on 

August 27, 2004. Participants at the three workshops made over fifty verbal 

comments, and several other stakeholders submitted written comments. 

The District has paraphrased most comments for the sake of brevity, and has 

consolidated comments when participants raised similar concerns, questions, 

issues, and suggestions. The comments received (in their entirety) are 

available upon request at the District’s Central Office. The following is a 

summary of the comments received, and responses prepared by District staff. 

To facilitate finding a particular comment or idea expressed in a comment, 

Verbal Comments are organized by Draft Extreme OADP chapter title. 

Comments that did not fit cleanly within a particular chapter are noted at the 

end of “Verbal Comments” as “Miscellaneous Comments.” The section entitled 

“Verbal Comments” includes comments made at the workshops as well as 

comments made during stakeholder meetings after the workshops. Written 

comments are organized by the name of the organization submitting the 

comments. Comments appear only once in this Summary and are not repeated 

under the major headings of “Verbal Comments” and “Written Comments.” 

Also, if a commenter provided the same comment verbally and in writing, the 

written version is used for the response. No formal written comments were 

received from the U.S. Environmental Protection Agency (EPA), the California 

Air Resources Board (ARB), or the San Joaquin Valley Air Basin (SJVAB) 

Transportation Planning Agencies. 
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H-2 

VERBAL COMMENTS 

Chapter 1 Purpose of the Plan and Plan Development

1. Comment: Will the plan only be used for the next 12 months or so? 

Response: The Plan itself may have a limited life due to EPA’s planned 

revocation of the federal 1-hour ozone standards, but the control measures in 

the Extreme OADP will be used to help demonstrate attainment for the federal 

8-hour ozone standards, and thus will continue to be viable air quality 

improvement tools in the future. 

2. Comment: How does this program mesh with the 8 hour standard? 

Response: The Draft Extreme OADP addresses only the federal 1-hour 

ozone standards. In collaboration with ARB and the other north-central 

California air districts, the District has begun work on developing the 8-hour 

ozone attainment demonstration plan. This plan is due to EPA on June 15, 

2007. 

3. Comment: This plan does not focus on sub-regional modeling and is focusing 

on stationary sources of air pollution. Since stationary sources are more 

heavily located in the Southern Valley, the District controls are mainly in the 

South Valley, which may not help improve air quality in the North Valley. Also, 

this approach may not be the most efficient way of controlling air pollution. 

Response: In this plan the District control measures primarily address the 

source categories for which the District has authority to control, which is 

stationary sources. Emissions reductions from ARB control measures 

supplement those of the District, and do address source categories outside 

District’s authority. In addition, the District has listed areas of future study that 

primarily target sources outside of the District’s authority to control (mobile 

sources). As the District noted in the responses to comments for the January 

2004 workshops, sub-regional modeling was not conducted for the 1-hour 

ozone modeling conducted for plans in 2003 and 2004. The focus for the 1-

hour ozone modeling conducted during 2003 and 2004 was on model 

selection, episode selection, model performance evaluation, incorporation of 

data from the Central California Ozone Study, and running the model to 

produce results in time for regulatory deadlines and air quality plan submittals. 

This baseline level of technical work has to be accomplished before more 

advanced topics such as sub-regional modeling can be studied and 

conducted. For the SJVAB, the time available to do modeling for the Extreme 

OADP was consumed by developing a working episode for the plan, such that 

no time was available for investigating the more advanced topics. Subregional modeling will be explored for the 8-hour ozone attainment 

demonstration plans due in 2007. The District and the ARB believe that the 

modeling that was done for this plan does meet all EPA requirements for 

modeling. Also see the Addendum to these comments. 

Chapter 2 San Joaquin Valley Air Quality

4. Comment: In the rule development process there are steps the District takes 

in determining if a rule is feasible, such as a socioeconomic analysis; the 

District needs to include a health impact assessment to determine feasibility.
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H-3 

Response: Because most District activities are directed towards attaining 

health-based air quality standards in the SJVAB, protection of public health is 

the driver for District activities. Therefore, the rule development process does 

not ignore human health. If a particular rule is determined to be not feasible 

for reasons including socioeconomic factors, then the emissions reductions 

from that rule are obtained using controls on other sources, such that human 

health is protected in accordance with the overall emissions reductions 

identified in the plan triggering the rule. On the other hand, socioeconomic 

factors drive many public and private development projects, which is why 

many states and the federal government have passed laws such as the 

California Environmental Quality Act and the National Environmental Policy 

Act to ensure that human health is considered in decisions involving these 

types of projects.

Chapter 3 Emissions Inventory

5. Comment: California legislation signed into law in 2003 that regulates 

agricultural sources of air pollution eliminates agricultural burning in 2010 yet 

does not eliminate controlled or prescribed burning by federal and state land 

management and forestry agencies. Yet information from the District shows 

that emissions from prescribed burning can be a large part of the inventory. 

How does the District handle this in the inventory? 

Response: Future inventories will reflect control measures implemented to 

comply with state law, such as the phase out of agricultural burning, because 

the District must pass rules to reduce emissions when so directed by state 

law. The amount of emissions for prescribed burning in the inventory 

represents the amount that the land management agencies have told the 

District that they would like to accomplish on an average day in the SJVAB. 

The District does control prescribed burns on a case-by-case basis, and 

prohibits them from taking place on days of marginal or poor air quality. 

Because of this District’s control and other complicating factors that the land 

management agencies must consider, the land management agencies have 

not been able to burn as much acreage as they have told the District that they 

would like to accomplish. Land management agencies assert that prescribed 

burning and mechanical thinning to maintain fuel loadings in forests at 

desirable levels offer air quality benefits over no or limited prescribed burning 

that lets biomass accumulate and makes forested lands susceptible to large 

wildfires that can have significant air quality impacts.

6. Comment: In the table on page 3-7 of the Draft Ozone Attainment 

Demonstration Plan, for the years 2000, 2008 and 2010, the District has 1.5 

tpd of NOx coming from petroleum refineries. Did the District factor in the 

closing of the Shell refinery, which would cut those numbers in half? Will there 

be any consideration of this closure because it is very significant, and if so 

does the District plan to do this before locking in these numbers? Shell is 

scheduled to close this refinery before the end of this year.

Response: For the plan the District used a version of the Air Resources Board 

(ARB) emission inventory (CCOS, Version 2.11) that did not reflect the 

anticipated closure of the Shell refinery. If the Shell refinery is closed, then 

future inventories developed after this plan will capture the emissions 

reductions from this closure. The District and ARB must submit the Extreme 

OADP to EPA by November 15, 2004, and thus the inventory in this Extreme 

OADP will not show the effects from the closure of the Shell refinery. 
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H-4 

However, the 2006 PM10 Plan, the 2007 8-hour Ozone Attainment 

Demonstration Plan, and the 2008 PM2.5/Regional Haze Plan will all use 

updated inventories, so if the Shell refinery does indeed close at some future 

date, then the emissions reductions from this closure will likely be reflected in 

inventories used in one or more of these plans. 

7. Comment: Table 3-2 on page 3-15 shows a positive number for the growth 

factor for refineries. Since the refinery industry is in a downturn, how did the 

District get a positive growth factor? For example, since 1980 there have 

been about 30 refineries shut down statewide, including two in the Valley, and 

the Shell refinery is due to close this year. 

Response: District staff researched the Table 3-2 growth rate information for 

refineries and confirmed that it is reported correctly in Table 3.2 as a growth 

factor of 0.1% for stationary source combustion. This information comes from 

the California Air Resources Board’s California Emission Forecasting System. 

It should be noted that Table 3-2 only compares NOx emissions for the year 

2000 with the year 2010, such that the growth rate reflects projected growth 

for this decade for fuel combustion at refineries. Any refinery downturn in the 

1980 to 2000 time period would already have been reflected in the 2000 

baseline. 

8. Comment: On pages 3-25 of the plan, it indicates that the plan is based on 

two types of inventories: a planning inventory and a modeling inventory. 

When a control measure is built into the plan and enters the rule development 

process, the District’s practice has been to send out a survey and request 

information from stakeholders. This allows the District to refine emissions 

inventory for a particular rule. How does that information get incorporated into 

the planning and modeling inventories? 

Response: The District sends new information on emissions from particular 

source categories to ARB, and the ARB evaluates the information for possible 

inclusion in future emissions inventories. The modeling inventory used in the 

attainment demonstration is a day-specific inventory, so and new information 

would be incorporated into this inventory as appropriate for the affected source 

category and the day of interest. To go from the planning inventory to the 

modeling inventory, District and ARB staff also spatially allocate the emissions 

for the day of interest and also subdivide the volatile organic compound 

emissions into reactivity class for use by the photochemical model. 

9. Comment: Are the ARB reductions given in the control measure workshop 

presentation of 90 tons per day of reactive organic gases and 140 tons per 

day of nitrogen oxides the total reductions from the state, or are the new ARB 

reductions for the Extreme OADP in addition to these totals? 

Response: The 90 tons per day of ROG and 140 tons per day of NOx are 

reductions from measures that have long since been adopted; the 15 tons per 

day of ROG and 20 tons per day NOx are from new ARB measures to be 

adopted by 2010. 

10. Comment: What is the proportion of the problem caused by stationary 

sources versus mobile sources? 

Response: Emissions from mobile sources account for about 60% of the 

ozone precursor emissions; the other 40% is accounted for by area and 

stationary sources. That’s why an integrated solution is needed. The District 

only controls 40% of emission sources and ARB and the U.S. Environmental 

Protection Agency have authority over mobile sources. 
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H-5 

11. Comment: The rapid decrease in the on-road motor vehicle emission source 

category shown in Table 3-1 for 2000, 2008 and 2010 appears optimistic and 

undoubtedly is based on an assumed rate of vehicle turnover (these numbers 

did correlate with independent runs of CARB’s EMFAC 2002 model, though). 

How do these data account for significant on-road life and limited vehicle 

population turnover? 

Response: This is based on fleet turnover assuming people will buy new 

vehicles and the fleet and engines will turn over (i.e., new, cleaner burning 

engines will replace older engines that emit more air pollutants). The benefits 

of cleaner burning engines are assumed to phase in over time after a new 

standard becomes effective. Vehicle buy back programs and alternative 

vehicle registration programs that are discussed in Chapter 4 of the Extreme 

OADP help encourage fleet turnover. The buy-back program provides funds 

for people to scrap older, high emitting vehicles in lieu of newer cleaner 

burning vehicles. The alternative registration programs either prohibit 

registration of older vehicles (as Phoenix, Arizona has done through 

legislation) or increase the cost of registering higher polluting vehicles relative 

to the cost of registering low emitting vehicles. 

12. Comment: Table 3-2, page 3-15 shows that the source category of Food and 

Agricultural Processing has a large inventory yet only has a control factor of 

10.1%. It seems like the District could obtain large emissions reductions from 

this source category that would help improve air quality. 

Response: It is important to note that Table 3-2 only reflects emissions 

changes relevant to ERC calculations for NOx for the years 2000 and 2010. 

Thus the 10.1% control factor reflects only additional controls for this time 

period; all of the emissions controls already placed on this source category 

prior to the year 2000 do not show up in the 10.1% because they are already 

reflected in the year 2000 emissions that for the baseline for computing the 

additional controls in the 2000—2010 time frame. 

Chapter 4 Control Strategies

13. Comment: What percentage of the emissions reductions needed for 

attainment address mobile source emissions and what percentage addresses 

stationary source emissions? 

Response: The State of California has authority to regulate mobile sources, 

and most of the reductions in the plan that address mobile sources come from 

the state (ARB) measures. As noted in the workshop presentation on state 

control measures, the state has already achieved large emissions reductions 

in the SJVAB (see Comment Number 9 above). About 40% of the new 

additional emissions controls identified in this plan as needed for attainment 

can be attributed to ARB (see Chapter 5).

14. Comment: As far as Smart Growth and transportation, what is happening with 

the Indirect Source Rules (ISR)? 

Response: The District continues to work on revising the internal draft rule 

based on comments provided during the spring 2004 public meetings; more 

information will be available within the next two months. 
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H-6 

15. Comment: How is the District going to deal with the North American Fair 

Trade Agreement (NAFTA)? The large amount of trucks coming into our air 

basin per day will slow traffic down and cause air pollution to go up. 

Response: Research is being done by ARB on how much pollution is caused 

by trucks coming into California due to NAFTA, especially trucks based in 

Mexico. The ARB is developing this information, and plans to have it available 

for the 8-hour ozone attainment demonstration plans that are due to EPA in 

2007. The air quality impacts from NAFTA trucks are not considered in this 

Plan because the Supreme Court decision allowing trucks to enter California 

happened too late in the Plan development process, and because very little 

information is available regarding emissions from NAFTA trucks in California. 

16. Comment: What is the District currently doing with Smart Growth? 

Response: Elements of smart growth are currently considered in the District’s 

programs related to land use, including the development of Indirect Source 

Rules, the District’s review of development projects under the California 

Environmental Quality Act, and the District’s guidance documents such as 

Guidelines for General Plans currently under revision. 

 

17. Comment: There are air impact fees in some communities now, which are 

pretty hefty on each home being built; where do these fees go, and are they 

used to reduce pollution? 

Response: The District is working on an Indirect Source Rule, which has not 

been adopted yet, so the District is not collecting any fees at present to 

account for the air quality impacts from new homes. The City of Bakersfield is 

assessing fees on new homes, and the process for deciding how this money 

gets spent is still being set up. The District is working with parties involved in 

the Bakersfield new housing impact fee to ensure that the money is spent on 

projects that actually generate emission reductions; however the District does 

not have authority over funds are spent, and can only provide advice and 

information. 

18. Comment: Is the District required to control emissions from mobile sources? 

If mobiles sources are 60% of the cause, how does your plan line up with 

sources? 

Response: See Comment Number 13 above. The District has only limited 

regulatory authority over mobile sources, whereas ARB does have authority 

and consequently most of the responsibility for mobile sources. Two control 

measures shown in Table 4-1 reflect the District’s rules for reducing mobile 

source emissions: school bus fleets and indirect source rules (combined 

reductions of 4.1 tons per day of NOx in 2010). Because the District has 

limited regulatory authority to reduce emissions from mobile sources, it uses 

incentive programs to assist in providing emissions reductions (see Section 

4.4 in the Draft Extreme OADP). For example, the District has provided 

incentive funds for the purchase of light duty vehicles that use hybrid 

technology to reduce emissions, and it provides funds for reducing emissions 

from heavy-duty engines currently in use. In addition, Section 4.3.1 of this 

plan presents ideas for controlling mobile source emissions in the future; the 

District and others will examine these for viability as future measures to reduce 

mobile source emissions. 
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H-7 

19. Comment: For the record, language should be included in this plan stating 

that the SJVAB’s attainment of the federal 1-hour ozone standard is contingent 

upon implementation of EPA and ARB emission control measures, especially 

for mobile sources. 

Response: Chapter 5 of the Draft Extreme OADP clearly shows that ARB 

emissions controls are needed to demonstrate attainment of the federal 1-hour 

ozone standard in the SJVAB. Typically the type of wording referenced in the 

comment is included in the resolution adopting a plan. For example, the 

District Governing Board resolution requesting EPA to reclassify the SJVAB as 

extreme nonattainment for the federal 1-hour ozone standard (Resolution 

Number 03-12-10) contains the following language: “The Governing Board 

expects the ARB and EPA to continue to actively pursue mobile source 

emissions reductions in the SJVAB.” Similar language will be considered for 

the resolution adopting the Extreme OADP. 

20. Comment: The District should consider using natural sources as buffer zones 

to capture some of these ozone emissions after they have been released. The 

uses of buffer zones have already been examined by cities and industry. The 

District should look at planting extremely fast growing trees with deep root 

systems of hardwood that will improve air quality. 

Response: See similar comment under Written Comments. The District will 

add a future study measure regarding the role of urban landscape 

management in improving air quality. 

21. Comment: On page 4-3 of the plan there is no column with total reductions. 

The reductions in Table 4-1 do not add up to the 300 tons per day that the 

District has previously identified as being needed to attain the federal 1-hour 

ozone standard. Where will the additional reductions come from? 

Response: The 300 tons per day emissions reduction target was derived from 

an old inventory in an old plan, and was based on a different modeling 

process and a different model. The information that is presented to the public 

today is better. It uses the Central California Ozone Study (CCOS) information 

that was gathered through the year 2000, as well as updated and more 

sophisticated meteorological and photochemical models. So the District is 

moving away form the old number and replacing it with the new information 

and analyses that are in this extreme plan. The prior estimate of 300 tons per 

day was developed around 2001/2002. Using the information in this Draft 

Extreme OADP to compare 2002 emissions (Chapter 7) with the 2010 

emissions needed to demonstrate attainment (Chapter 5) shows that the 

reductions needed are still about 300 tons per day. 

22. Comment: In Table 4-2 (Potential Control Measures Requiring Further Study) 

the District is looking at future measures and their feasibility. If a control 

measure is determined not feasible, the District may decide to drop it. What is 

the time frame for these decisions, between now and when the plan goes to 

the Governing board, or is this between now and 2007? 

Response: For some of the control measures the District is already looking at 

the emissions inventory and what the feasibility is, for others it may be a year 

or two, but it will not be something the District will be deciding between now 

and the Governing Board hearing on October 8, 2004. The District may 

commit to these measures in a future plan, such as the reassessment of the 

PM10 Plan in 2006 or the 8-hour Ozone Plan in 2007 . 
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H-8 

23. Comment: In regards to integrated solutions to air quality, the School Bus 

Fleet Rule is a very specific way to reduce emissions. What is the status of the 

rule currently? 

Response: The District held workshops on August 25th and 26th, 2004, to 

present, discuss, and receive comments on draft rule 9310. This rule is listed 

in Table 4.1 and is estimated to result in a NOx reduction of 0.1 tons per day in 

2010. 

24. Comment: In looking at the Carrying Capacity chart (Figure 5-5), the line is 

drawn at 125 ppm for VOC. How do these levels compare with limits 

established in District permits for NOx? 

Response: The limits that are shown in the graph are ambient air quality 

limits, and represent concentrations of ozone in the ambient air. Ozone is 

formed in the air by chemical reactions between volatile organic compounds 

and nitrogen oxides, and the District’s permit conditions address limits of 

nitrogen oxides or VOCs. Concentrations given in permits usually refer to the 

level of the pollutant in the exhaust gas, and the concentrations referred to in 

Figure 5-5 refer to the ambient air. 

25. Comment: Control strategies are still across the board, yet there are different 

inventory mixes in the regions. The District may find you need more NOx 

reduction one area and more VOC in another. The District may find subregional control is a big leap from the way it has been doing things. When the 

District writes plans, sub-regionalization is not in there as anything more than 

an idea. How can the Valley get a plan that does this, and if the 1-hour is a 

placeholder how does sub-regionalization get into the 8-hour plan? 

Response: The District is working to get the modeling done early to drive the 

plans, and then staff can run different types of scenarios before the District 

completes a draft plan. As indicated in the response to Comment Number 3 

above, insufficient time was available in the Extreme OADP schedule for this 

type of work once the episode used was finally ready. 

26. Comment: Has the District examined emissions from dairies and crops? 

 Response: Rule development is underway for dairies and for open burning, 

as indicated by Table 4-1. Also, emissions from plants are included in the 

biogenic inventory used in the modeling inventory. 

27. Comment: Was there any numerical credit taken for emissions reductions for 

all of the “Integrated Solutions” presented at the workshop? Did the District 

take numerical credit for the mobile source incentives? 

Response: The District did not take emissions reductions credit for all of the 

“Integrated Solutions” listed in the workshop presentation; most of the 

reductions in the Draft Extreme OADP come from stationary and mobile 

source control measures, and some from fleets and land use policies 

(principally indirect source rules). 

28. Comment: How do you determine the impact of a specific rule? How do you 

determine the impact on ozone? 

Response: The impact of a rule shows up in the planning inventory by an 

emission reduction, but even there the magnitude of the reduction and the 

number of significant figures used in the inventory play key roles in whether 

the reductions from the rule will show up. For example, if the inventory is 

expressed to the nearest 0.1 tons per day, and a rule achieves a reduction of 

0.04 tons per day, it may not show up from one inventory to another. Typically 
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H-9 

only large emissions reductions of tens of tons per day show up in ozone 

levels predicted by a gridded photochemical model. The ultimate judges are 

the monitors at that future date saying whether or not you made it. 

29. Comment: There appears to be less VOC/NOx control in District Control 

Measure Schedule (Table 4-1) than are claimed for new District measures in 

SJVAB Federal 1-hour Ozone Attainment Concept (Table 5-1, p 5-11). What 

is the source of the difference? 

Response: As noted in the footnotes to Table 5-1, a variety of data sources 

are used to demonstrate attainment, one of which is the post-PM10 Plan 

measures presented in Table 4-1. Table 4-1 only reflects reductions from 

control measures under District Control. Reductions from District incentives 

and from ARB control measures are also used to demonstrate attainment, but 

are not shown in Table 4-1. Also, the reductions from PM10 Plan measures 

are used as given in the Amended PM10 Plan, which was approved by EPA 

effective June 25, 2004. The footnotes in Table 5-1 clearly identify all data 

sources used in the attainment demonstration. The District will add additional 

text cautioning against the comparison of Table 4-1 with Table 5-1. 

Chapter 5 Future Ozone Air Quality

30. Comment: The way the modeling is set up, when data is given to District staff 

developing the control strategies, could the District do sub-regionalization to 

link the sources to impacts of control measures on ozone levels?

Response: In the model, staff can remove emissions in any portion of the 

region and take a look at the model sensitivity. The District has done some 

exploratory work on this and has seen some changes in predicted ozone 

levels. This can be done, but is not required. Sub-regionalization is one of our 

goals, but as noted above in Comment Number 3, it was not pursued for this 

particular Extreme OADP. Most of the modeling was done by ARB. For the 8-

hour Ozone Attainment Demonstration Plan, the District is planning to and 

encouraging its partners to look at doing different things, such as more 

expansive modeling of different episodes, and looking at regional variations. 

Since the information necessary to do this type of modeling was not available 

in the Draft Extreme OADP’s timeframe, the District decided to direct this effort 

to the 8-hour plan and not pursue it for the 1-hour plan due to the limited time 

available. 

31. Comment: Is there a modeling inventory in the Appendices and is it broken 

down into source categories. 

Response: As noted on page 3-6 of the Draft Extreme OADP, the modeling 

inventory is not included with the plan because of its complexity and volume. 

It is not suited to presentation in either tabular or text form. 

32. Comment: Referring to the photochemical modeling presentation, the slide 

entitled Model Performance Zones shows numbers on a map; what do the 

numbers in the grid represent? 

Response: They represent individual areas with source receptor relationships 

that were set up to evaluate model performance. 
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33. Comment: Did the District take biogenic emissions out of the inventory to 

show attainment? 

Response: No, they were removed to test the model, biogenic emissions are 

hard to quantify, so staff wanted to see if uncertainty in biogenics emissions 

had a large effect on predicted ozone levels. Biogenic emissions are included 

in the modeling inventory used as input to the production of the carrying 

capacity diagram. 

34. Comment: In the carrying capacity diagrams, do any sources of NOx come 

from natural sources? 

Response: Yes, there are some natural sources of NOx that are included in 

the modeling inventory that is used to ultimately produce the diagrams. 

35. Comment: Do the biogenics stay the same for the model in the future? 

Response: When staff runs the model, they keep the biogenics the same for 

the Base case and for future cases, so that it is consistent. 

36. Comment: What do the ozone monitors record in the atmosphere after 

control measures are implemented? 

Response: District and state control measures reduce emissions, and 

emission reductions improve air quality. Chapter 2 presents a number of 

graphs that show improving ozone air quality in the SJVAB due to emissions 

reductions and other factors. The weather and geography of the SJVAB can 

combine to sometimes mask the effects of these emission reduction programs, 

or to sometimes show significant improvements in air quality. It is important to 

remember that the relationship between ozone precursor emissions reductions 

and ozone formation in the atmosphere is not one to one. A given reduction in 

emissions can produce drastically different ozone responses in different air 

basins or in the same air basin at different times. 

Chapter 6 Outreach 

37. Comment: The District doesn’t have anything in the plan about partnering with 

other agencies, such as the USDA being able to cost share diesel engines, 

possibility of cost sharing mobile diesel engines and the other cost-share 

programs that are available to facilitate cleaner air? 

Response: Yes, the district does have incentive programs for heavy-duty 

diesel engines. The District has tried to partner in the past with the USDA and 

others on cost sharing the replacement of older dirtier engines with cleaner 

engines, and will continue to do so in the future where possible. With the 

changes to agricultural operations and regulations the legislature has passed 

legislation to allow those funds to still be available for those sources, and other 

sources, such as school buses, but the bill has not yet been signed. The 

District is looking at replacing a lot of the older school buses with cleaner 

buses that have fewer emissions. The District is looking for funding 

opportunities for those sources. 

38. Comment: This plan is so important for the Valley and the comment deadline 

is only ten days. Why wasn’t more time allowed for the public to participate in 

this plan? What will happen if the plan is not submitted on time? 

Response: The District held the first workshop for this plan on July 23, 2003, 

so the total time for the public to be involved in plan development is about 18 

months. The Draft Extreme OADP was released for public review on July 30, 
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2004, and the comment period closed on August 27, 2004. The approximately 

30-day public review period is consistent with prior District actions of this type, 

especially since much of the plan’s contents has been available for 6-18 

months. For example, the control measures consist of PM10 Plan measures 

that have been available since March 2003, and new District and State 

measures that have been available since January 2004 (and many of the 

District measures have been developed in a very public process in response 

to state legislation passed last year). Modeling results were first shared in 

January 2004. The process of incorporating voluminous CCOS data into a 

multi-agency, highly technical SIP modeling process has been extremely 

involved, and consumed a large part of the project schedule. EPA staff has 

indicated to District staff that EPA would issue a “Finding of Failure to Submit” 

if the Extreme OADP is not submitted to EPA by November 15, 2004. 

Furthermore, this finding is also likely to trigger sanction clocks and a federal 

implementation plan clock, both of which the District, ARB, and stakeholders 

are trying to avoid. 

39. Comment: The overall plan development schedule may not allow enough time 

for the District to provide meaningful responses to comments and to make 

corresponding plan revisions. Even though most of the control measures in 

the Plan have been available for public review for some time, members of the 

public may want to suggest new control measures or other things they want 

added to the plan; will there be time to add these? 

Response: The District’s schedule allows time for responding to the 

comments and for making necessary plan revisions. Appropriate new ideas 

for control measures will be considered for inclusion in the Plan, most likely as 

areas for future study that will lead to control measures for the next ozone 

plan. 

40. Comment: Do you have anything in the plan that works toward educating the 

public to get their buy-in? 

Response: The District has an active Public Education program to outreach 

to the public, to do community events, and to provide clean air materials in 

multiple languages. Examples are the Spare the Air Day, and lawn mower 

exchanges and billboard and radio advertisements. See Chapter 6 of the 

Draft Extreme OADP as well as Section 4.4. 

41. Comment: Is there a way to adequately inform the public of upcoming 

workshops? 

Response: The District currently publishes workshop notices in eight major 

newspapers throughout the San Joaquin Valley. The notices are located in 

the Public Notice sections of the Classified Advertisements. The District’s 

website (www.valleyair.org) that offers a listing of upcoming workshop notices 

and materials. The website also offers materials and handouts from past 

workshops. The website is frequently publicized in the District’s radio and 

television advertisements. 

Chapter 7 Rate of Progress

42. Comment: What is the total emissions inventory that will support attainment of 

the federal 1-hour ozone standard in the SJVAB? 

Response: As shown in Table 5-1, the emissions inventory that 

demonstrates attainment of the federal 1-hour ozone standard is about 85% of 
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the 2010 VOC inventory (or about 312 tons per day of VOC), and about 86% 

of the NOx inventory (or about 346 tons per day). 

Chapter 8 California Clean Air Act

43. Comment: Will the state requirements change with the Federal 1-hour 

standard going away? 

Response: No, the state will keep its 1-hour ozone standard of 0.09 ppm and 

will also implement an 8-hour standard, currently proposed at 0.07 ppm. 

Miscellaneous Comments

44. Comment: Certification may be an alternative to permitting; there may be 

other options available. 

Response: The District always considers alternatives to the typical command 

and control. Certification or registration is worth considering for large numbers 

of sources for which the administrative costs of permitting, source testing, 

and/or inspecting would be prohibitively expensive. 

45. Comment: Are Brandy producers aware that a control measure has been 

proposed? 

Response: The district has been working with the Wine Institute and has 

consulted with all the major brandy producers. 

46. Comment: Why would Brandy Production be considered as a new Control 

measure? 

Response: Brandy production is a significant source of VOC emissions, 

perhaps even higher than wineries. New control measures could be designed 

to reduce VOC emissions created during the production of brandy, including 

distillation, aging and bottling. 

47. Comment: Will portable stationary IC (agriculture) engines be listed under 

potential Control Measures Requiring Further Study? 

Response: The District is waiting for ARB to finalize Air Toxic Control 

Measures (ATCM’S), and then the District will look at measures in this area for 

all portable engines. 

48. Comment: What does Control measure N (Water heaters, 0.075-2.0 

MMBtu/hr) include? 

Response: This rule could include new commercial, industrial or institutional 

units. Emissions will be reduced mostly by new units, based on furnace 

incentives for replacement of unit (see page 4-21 of the Draft Extreme OADP). 

This will be a one for one replacement; the facility will not be required to 

change all units over at the time of the first replacement. 
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WRITTEN COMMENTS

Comments submitted by Western State Petroleum Association (WSPA), 

August 25, 2004.

49. Comment: In regards to the potential Control Measures Requiring further 

study (Table 4-2) WSPA believes all of the future control measured identified 

be subject to an open review during the consultation, development, and review 

phase. Since the list of future control measures was based on other districts’ 

measures that may have potential application in the SJVAPCD planning 

process, it is important to note that because these measures work in one 

district they may not work in another. Each of the future measures must 

undergo rigorous scrutiny as to applicability and effectiveness given the 

uniqueness of each air district. 

Response: The process described above is consistent with what happens 

during the District’s rule and plan development process. The District does not 

merely adopt another district’s rules. 

50. Comment: Section 5.6 indicates that the additional 5 tons per day of NOX and 

5 tons per day of VOC’s will be obtained through an unknown control measure 

(i.e., ‘Black Box”), which will be identified in 2007 and implemented by 2010. 

Will the black box be effective since the modeling will be basin-wide, with no 

sub-regional analysis? Sub-regional control measures may get a bigger 

reduction. WSPA understands that nothing can be done for this OADP. It is 

crucial that such modeling be included in the 8-hour Plan. WSPA intends to 

hold the District to this commitment. 

Response: See responses to verbal comments regarding sub-regional 

analyses. The District will relay these points to ARB, who will be primarily 

responsible for conducting the modeling for the 8-hour ozone plans. 

51. Comment: Section 4.3.2 discussed the consideration of new concepts in air 

quality planning under the title of Sustainable incentives. WSPA believes the 

District should go even further in this section of the OADP and include 

Alternative Emission Reduction Programs as a viable and proactive approach 

to future air quality planning. WSPA feels this is the key to future air quality 

planning and strongly recommend that Section 4.3.2 be amended to include 

this approach. 

Response: The District will investigate alternative approaches and will add 

some text to the section. 

52. Comment: WSPA is concerned that there may be a potential for a double cap 

on ERC credits. The baseline has been moved to Year 2000. However, 

ERC’s are already massively discounted. WSPA believes the combination of 

discounts and Federal limits essentially caps the ERC’s. The addition of a cap 

in the OADP further restricts an already heavily discounted program. 

Response: The District agrees with WSPA that emission reduction credits 

(ERCs) are discounted as they are generated and used in the District’s 

permitting program, but we do not agree that discounting can be considered to 

be a cap on allowed ERC-use, even when coupled with the comparison to 

time-of-use federal discounting requirements. 
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If the District fails to demonstrate that the existing District offsetting program is 

equivalent to the federal time-of-use requirements, there is a specific end 

result (the “hammer”) already contained in the District’s New and Modified 

Source Review (NSR) rule - the District must require that new major sources 

and major modifications use only federally acceptable offsets (those that are 

surplus at the time of their use). There is no cap, in the current NSR rule, on 

the quantity of federally acceptable offsets that can be used for new major 

sources and major modifications, and in fact, there are no limits at all on ERCs 

that can be used to offset non-major projects. 

Therefore the District does not agree that the OADP’s cap on pre-baseline 

ERC usage is a “double cap”. 

53. Comment: WSPA hopes that the 8-hour Ozone Plan will incorporate the 

comments made here with regard to detail and accuracy. The 8-hour should 

provide more accurate emissions inventories, refined air quality modeling 

(including sub-regional modeling), reliable traditional emission control 

measures and alternative emission reduction programs (including sub-regional 

measures and programs). 

Response: Planning is underway with ARB (who develops modeling 

emissions inventories and conducts the photochemical modeling for the 8-hour 

plans) and with adjacent districts to develop the framework for producing all of 

the north-central California 8-hour ozone SIPs that are due to EPA by June 15, 

2007. All of the above points have been conveyed to the working group that is 

developing this framework, and every effort within the resources available will 

be made to make sure the 8-hour plan development process is an 

improvement over the process used to develop the 1-hour plan. See also 

response to comment number 3 and the addendum to these comments. 

Comments submitted by The California Building Industry Association 

(CBIA)

54. Comment: The letter summarized CBIA’s previous comments on the draft 

rules presented earlier this year and includes the following statements: There 

was lack of balance in the District’s proposed rules, citing the scant emission 

reductions that are out of proportion with the cost and administrative burden 

needed to implement the regulations. Comments also cited the 

incompleteness of the District’s proposed program, identifying the inadequate 

modeling capability to estimate project emissions as well as reductions in 

emissions attributable to control measures accurately. Finally, CBIA’s 

comments called to the District’s attention its failure to recognize and take into 

account the shrinking emission reductions over time as cars become cleaner.

Response: It should first be recognized that the indirect source control 

measure has already been approved in the 2003 PM10 Plan and rule 

development have been started. In addition, plan control measures are 

general, and rules cover specifics. The previous comments listed above were 

on a first draft rule that in no way should be considered complete. The draft 

provided an opportunity to identify areas of the program that needed more 

support and documentation. The District has been working over the last 

several months to gather information needed to respond to previous 

comments and to revise the rule to address issues. 

The District has a history of adopting rules that minimize administrative burden 

and maximize efficiency. The emission reductions expected from the indirect 
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source program are relatively large compared to rules adopted by the District 

on other emission sources and are needed to attain the ozone and PM10 air 

quality standards by 2010. The District disagrees that the modeling capability 

is inadequate and the proposed model is currently being upgraded to increase 

its accuracy. Although tailpipe emissions per vehicle are declining, growth in 

travel related to new development is projected to cause an additional 25 

tons/day of NOx emissions that would not be emitted if the growth did not 

occur. This means that the mobile source program is inadequate to do the job 

by the mandated 2010 attainment date and that additional reductions are 

needed. The indirect source program can provide some of the emission 

reductions to offset growth 

55. Comment: ISR fails to establish a nexus between development and the 

emissions that homebuilders and homebuyers the Plan proposes to tax. 

Response: The indirect source program is being designed to account for all 

air mitigation activities that affect a development project and to provide 

flexibility and efficiency for developers in meeting their obligation to implement 

all feasible measures to reduce air quality impacts. Any mitigation fee 

collected will be used for projects that reduce the air quality impacts of the 

development project in keeping with nexus requirements, and is in no way a 

tax. The plan control measure is consistent with EPA requirements and any 

rule submitted to EPA to implement the indirect source control measure will 

meet all federal Clean Air Act requirements. 

56. Comment: ISR has no direct connection between payer and emitter. 

Response: Many precedents exist for using mitigation fees. When used to 

mitigate other impacts, mitigation fees have been found to be a good public 

policy solution for problems that cannot be solved by the individual developer 

who is creating an impact. For example, regional transportation impact fees 

enable a jurisdiction to collect funds from all new development that is 

contributing to impacts on the regional transportation system just as an indirect 

source mitigation fee would fund projects that mitigate regional air quality 

impacts.

57. Comment: ISR has exaggerated, speculative emission benefits. In the 

purported benefits of the Plan’s indirect source program are based on a rough 

estimate of how much money the District could amass if all future projects paid 

an indirect source fee to avoid mitigation requirements. Since no fee amount 

has yet been proposed, this calculation is speculative at best. 

Response: The emission reductions are based on reasonable estimates of 

the potential reductions achievable from the program. The reduction 

estimates are based on emission reductions and cost-effectiveness of projects 

that the District has successfully completed through its grant and incentive 

programs. Details will be provided during the next phase of the rule 

development process.

58. Comment: While the District is on record that it prefers on-site mitigation of all 

future development, the emission reduction estimate in the Plan is not based 

on actual emission reductions that could be reasonably expected from on-site 

mitigation. 

Response: On-site measures will be credited toward reducing the mitigation 

fee on a proposed project. The combination of on-site mitigation and off-site 

mitigation will be equivalent to a project that mitigated emissions solely 

through paying the mitigation fee. Therefore, the actual reductions will be the 
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same whether developers include on-site measures in their project or pay the 

mitigation fee.

59. Comment: Due to the speculative manner in which potential emission 

reductions are calculated, it is doubtful that the measure in the Plan can 

achieve the emission reductions claimed, leading to an emission reduction 

shortfall. The potential emissions reduction shortfall can lead to transportation 

conformity problems and the inability to program federal transportation 

funding. 

Response: The reductions are based on over a decade of experience in 

quantifying air quality projects funded by District grant and incentive programs 

and provide a reasonable estimate of the program’s potential benefit. Air 

quality plans contain estimates of reductions that are expected from each 

control measure. Control measures are necessarily less detailed than rules 

that implement the control measures. The District commits to the total 

emission reductions in the plan. If a shortfall in any one measure occurs this 

can be made up with other rules that achieve higher emission reductions than 

were anticipated in the plan or by adopting other measures to achieve the 

needed reductions. The District works closely with the Transportation 

Planning Agencies to ensure that any needed changes are made in a timely 

manner that prevent transportation conformity problems and sanctions from 

occurring.

60. Comment: ISR fails to meet Federal Clean Air Act requirements. The 

measure described in the Draft Extreme Ozone Attainment Plan does not 

meet the Federal Clean Air Act test for surplus, quantifiable, enforceable, 

permanent and adequately supported reductions in air emission, as set forth in 

42 U.S.C. Section 7410 (a)(2)(F). 

Response: The commenter appears to have quoted an incorrect code 

section. The section referred to relates to stationary source monitoring and 

reporting requirements. The rules being developed for the indirect source 

program will meet all federal requirements.

61. Comment: The expected emissions benefits are not quantified. There is no 

documentation of assumptions and calculations. 

Response: Air quality plans do not typically provide emission calculation 

documentation in the plan text. The District submits supporting documentation 

as needed to EPA for their review. Detailed calculations will be accomplished 

during the rule development process based on the content of the rule. The 

District will provide the calculation methods used to estimate the plan 

reductions with the plan submittal.

62. Comment: There is no discussion of whether the emissions are surplus. 

URBEMIS is not able to identify new trips only associated with development. 

Response: The indirect source program will not overlap with existing rules. It 

will dovetail and compliment other rules such as Regulation VIII and with TPA 

commitments. Projects committed to as TCM RACM for the ozone plan will 

not be eligible for indirect source funds. The District is designing the program 

to only address new trips that would not otherwise occur and will demonstrate 

this during rule development.
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63. Comment: The proposed Indirect Source Mitigation Program does not contain 

an enforceable commitment. No legal nexus between the proposed mitigation 

requirements and fee and individual development projects has been 

established. 

Response: The District has committed that the indirect source program will 

provide a clear nexus between the project’s impacts and any fees collected by 

the program to reduce the impact. The nexus analysis cannot be completed 

until more program specifics have been developed. However, the impact of 

new development on air quality is well documented and the air quality benefits 

of projects being proposed to mitigate the impacts are well accepted.

64. Comment: There is no finding that the benefits of the proposed measures will 

be permanent. 

Response: The proposed measures used for indirect source program will 

comply with all applicable federal regulations. Specific findings are not 

required for plan control measures.

65. Comment: The proposed Indirect Source Mitigation Program is not 

adequately supported. The Plan provides no information on the commitments 

from other agencies that are necessary to implement the various measures. 

There is no discussion regarding the availability of funding to implement the 

land-use activities. Likewise, there is no information that other government 

agencies with jurisdiction to pursue these strategies will cooperate. Finally, 

there is no indication that the proposed requirements have been or will be 

integrated into local development plans. 

Response: No commitments from local agencies are needed to implement the 

indirect source program since the District has authority under the Health and 

Safety Code. Although the District encourages local agencies to participate in 

the indirect source program, the program is being designed to operate 

independently if needed. The District disagrees that there is no indication that 

local agencies are interested in land use changes that improve air quality. The 

Landscape of Choice that was prepared with the participation of the Building 

Industry Association and adopted by all cities in Fresno County is an excellent 

example of the desire to plan and build projects to minimize air emissions 

consistent with the goals of the indirect source program. 

The August 27, 2004 comment letter also included copies of comment letters 

on draft rule 9510 and 3180 that were submitted in April 2004. The District is 

in the process of addressing all concerns voiced over the initial draft rules. 

The next version of the rules will incorporate suggested changes and will 

include a response to all comments received in writing and during the 

workshop process. The District has been doing the necessary research to 

provide a complete response and has delayed the release of the next draft to 

ensure that all issues are addressed before continuing the rule development 

process.

Comments submitted by the Kern Oil and Refining Co., August 27, 2004. 

66. Comment: Table 3-1 indicates refinery emission levels have remained 

constant and are projected to do so. These levels should be changed to 

reflect the recently adopted NOx controls on refinery equipment and the 

pending Bakersfield Shell Refinery closure. 

Response Forecasted inventories for this category and others do need to be 

updated for future use and this is acknowledged in this plan in our discussion 

of what is included in the planning and modeling emission inventories that 
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were used. Controls adopted and implemented by early 2002 were already 

included in the inventory and no additional reductions in the inventory would 

appear due to those controls in the period 2002-2010. Controls adopted in the 

latter part of 2002 or later were not in the inventory, and would not show up in 

the 2010 inventories for planning or modeling. These reductions that were not 

yet part of the inventory were taken as part of the “after-model” adjustments as 

described in the plan. Most of the refinery controls were effective either by 

2000 and included in the inventory or were after 2002 and were taken as 

adjustments to the model. Therefore, the earlier reductions were accounted 

for in the planning and modeling inventories, and since the inventory did not 

include the reductions after 2002 in Table 3-1, it appears that we did not give 

credit for the additional controls. They were credited as “after-model” 

adjustments. 

67. Comment: Table 4-1 and 4-2 Control Measures are too focused on stationary 

source controls. The District should acknowledge that the traditional 

command-and-control strategy of controlling the same stationary sources, in 

particular oil refineries, will not lead to attainment of the federal ambient air 

standards. Such facilities should be deemed Adequately Controlled and efforts 

must be made to look beyond the District's traditional span of control to 

uncontrolled stationary sources and mobile sources. 

Response: The District is responsible for controlling emissions from stationary 

and areawide sources, so effective, economically feasible control measures on 

those facilities will remain one of the areas we must continue to focus on, but 

we have expanded controls to non-traditional types of sources in the last two 

plans. Staff welcomes suggestions, however, for measures that would 

generate emission reductions via non-traditional methods. 

68. Comment: Table 4-1 does not list amendments to Rule 4623. During the 

public workshop, District staff indicated that the rule was not significant. 

Industry states that the changes are significant to industry. 

Response: Rule 4623 is not included in Table 4-1 because the amendments 

are not proposed to generate significant emission reductions. Any significant 

impacts to industry will be examined during the rule development process. 

69. Comment: Table 4-1 indicates the estimated emission reductions from the 

stationary sources. Industry comments that the total is far less than the 

amount required to reach attainment. They suggest that language be added 

to indicate that attainment cannot be reached without the mobile source 

reduction commitments of the USEPA and CARB. 

Response: There are numerous references throughout the plan to the 

significant commitments that USEPA and CARB are making to mobile source 

emissions. 

70. Comment: Section 4.3 lists Further Study Measures outside the typical 

stationary source measures pursued by the District. Industry suggests other 

measures could be added including: 

• Gross Polluting Vehicles: More aggressive steps should be taken to 

identify, repair, and remove gross polluters. Make it a priority to fund the 

vehicle scrapping program. 

• Emissions from fires: Jointly develop forest management controls with 

state and federal agencies. Provide funds to fire departments to 

decrease response time and diminish loss of life and property. 
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• Ultra-Low Sulfur Diesel (ULSD): Lobby CARB and EPA to require the 

train locomotives transiting the Valley use ULSD. 

• Marine Vessels: Adopt rules similar to the SCAQMD for Marine Tank 

Vessels and Lightering Vessel Operations. Apply Carl Moyer Program 

funding to retrofit tugboat engines. 

Energy Efficiency in new construction: Work with planning agencies to 

mandate renewable energy features and greater energy efficiency in new 

construction. 

Response: The District is already involved with many of the suggested 

issues: 

• Gross Polluting Vehicles: The District agrees with this suggestion and 

the plan already addresses further steps such as those suggested. 

• Emissions from fires: The District currently works closely with forest 

management agencies to minimize impacts from proscribed and wildlife 

fires. Emissions from structural fires are small compared to other 

sources. Our understanding is that fire departments currently try to 

arrive at the fire as quickly as possible. 

• Ultra-Low Sulfur Diesel (ULSD): The District, CARB, and others have 

urged the EPA to apply the ULSD standards to off-road. USEPA has 

already developed a schedule for those requirements. 

• Marine Vessels: The Valley does not have the large marine tanker and 

lightering fleets common to the SCAQMD so similar rules would have 

minimal or no benefit. Staff is a member of the ARB cargo handling 

equipment regulatory working group. That group will examine intermodal transfer sites such as ports. A tugboat at the Port of Stockton is 

eligible to apply under the Moyer Program for engine replacement. 

• Energy Efficiency in new construction: District staff work with the 

various Valley planning agencies as part of the CEQA review process 

and recommend emission reduction possibilities for new construction 

projects. Building construction for energy efficiency, however, is 

outside the District's authority and expertise and is best left to the state 

and local building agencies, which currently promote green 

technologies such as solar cells. 

Comments submitted by Dennis C. Tristao, Kings County City 

Representative on the Citizen’s Advisory Committee, August 27, 2004.

71. Comment: The District should consider creating urban tree planting 

guidelines to facilitate the urban landscape’s role in improving air quality. 

Response: The District will add text to the plan regarding a measure for 

future study in the area of research, education and outreach regarding the role 

of urban landscapes and agricultural land use on ozone air quality. 

72. Comment: The District should consider developing a horticultural biogenic 

emissions education program. 

Response: See Number 71. 

73. Comment: The District should consider opening up grant programs to fund 

programs that make landscape changes that improve air quality. 

Response: See Number 71 
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74. Comment: The District should consider an outreach program that encourages 

and promotes the beneficial effects of vegetation on air quality. 

Response: See Number 71. 

75. Comment: The District should consider funding additional research through 

CCOS on the air quality benefits of trees. 

Response: See Number 71. 

Comments submitted by Environment California, August 30, 2004 

76. Comment: Can you accelerate the timeline for Rule 4702 by one year (from 

2008 to 2007)? 

Response: The current Rule 4702 amendment is governed by Section 40724 

of the California Health and Safety Code, which calls for adoption no later than 

July 1, 2005. Given that this deadline is less than one year away, and that 

rule development is underway, accelerating the schedule for any significant 

time savings is not feasible. Furthermore, the compliance schedule for 

engines already covered by Rule 4702 is not affected by these amendments. 

Workshops for this rule began on August 30, 2004 (see www.valleyair.org). 

77. Comment: The District should adopt a technology-neutral treatment for 

engines and turbines, with one pollution limit for both technologies that would 

help drive the market toward the cleanest forms of micropower. 

Response: District rules address specific, existing inventories such as 

turbines, and not specific applications, such as micro-power generation. The 

District's New Source Review process, however, does consider Alternate 

Basic Equipment for new power generation projects and is a technology 

neutral review. 

78. Comment: The Draft Extreme OADP references treatment for agricultural 

engines, something we strongly support. The turbine section refers to the 

CARB rule; however, the engine section does not. 

Response: CARB has not adopted guidelines or rules for either agricultural 

engines or for compression ignition engines. 
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SJVUAPCD Appendix H - Comments and Responses 

H-21 

ADDENDUM 

Inclusion of Prior Comments and Responses on 

Photochemical Modeling 

Chevron-Texaco submitted written comments on January 19, 2004 regarding preliminary 

photochemical modeling results shared at the January 6-7, 2004 workshops. Chevron-Texaco 

requested that those prior comments and responses be included with this package of 

comments and responses on the Draft Extreme OADP. Note that the photochemical modeling 

presented at the January 6-7, 2004 workshop is preliminary and is not the same as that used in 

the Draft Extreme OADP. Any reference to “current modeling” in these comments refer to an 

earlier version of the modeling. 

WRITTEN COMMENTS 

Chevron Texaco, January 19, 2004

 1. Comment: The District should use modeling to examine strategy alternatives 

for not only the one-hour standard but also the 8-hour ozone standards. 

Assuming revocation of the one-hour standard in the next year or two, it is 

important that any strategy be effective for both. 

Response: The District is focused on meeting regulatory requirements related 

to the 1-hour ozone attainment demonstration plan, but remains open to 

conducting appropriate analyses of the effects of emissions reductions on the 

8-hour ozone standard where resources allow. 

2. Comment: Due to the very real sub-regional nature of the ozone problem, the 

District should develop an overall strategy that takes into account sub-region 

differences rather than “one size fits all” approach in their plan. 

Response: The District has conducted sub-regional analyses in the past. 

See response to Verbal Comment # 20. [This refers to Comment #20 from the 

January 2004 Workshop Comments and Status Report Public Review. The 

response to #20 is as follows: “As specified in the District’s authorizing 

legislation, we will continue to implement control measures on a basin-wide 

basis. While some logic exists for implementing sub-regional control 

measures (as suggested above), their implementation could lead to possible 

disadvantages such as creation of “pollution pockets” with possible resulting 

environmental justice consequences.” The District will investigate the issues 

associated with sub-regional modeling in the 8-hour SIP development effort. 

3. Comment: If the District feels compelled to submit a plan based on modeling 

that demonstrates only minimally acceptable performance, the District should 

formally commit to revising the plan as better modeling becomes available, 

including revision of control measures if justified by the modeling. This would 

not be a mid-course correction, but a continuation of the ongoing effort.

Response: The District is focused on meeting regulatory requirements 

related to the federal 1-hour ozone standard, which in part call for the District 

to submit an ozone attainment demonstration plan to EPA no later than 

November 15, 2004. The best available information will be used to develop 

this plan; however, as better information is developed over time, it will be 

incorporated in future plan revisions. The District is committed to revisiting the 
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SJVUAPCD Appendix H - Comments and Responses 

H-22 

federal 1-hour ozone attainment demonstration plan in 2007 (unless the 

standard is revoked as planned, in which case the District would focus on 8-hr 

ozone attainment), at which time the modeling will be repeated with new 

information, the emissions inventory updated, and long-term control measures 

identified. 

4. Comment: As has been made clear in statements by District staff and others, 

the July-August 2000 episode is not a particularly good episode for planning 

purposes. The need for relative reduction factors to help predicted ozone 

levels agree with measured ozone levels, and the presence of large wildfires, 

create uncertainties in the viability of this episode for control program 

development. The District should only use the July-August 2000 episode as a 

fall back (and only then if the model performance can be improved), and 

should seriously consider other episodes such as September 2000 or July 

1999. 

Response: The District will base the federal 1-hour ozone attainment 

demonstration plan on the best available information. Data gathered during 

CCOS, which includes the July/August 2000 episode, will be used where 

possible. Due to issues such as disagreement between actual vs. predicted 

ozone levels and the presence of large fires in the episode, the District is 

examining other episodes for use in modeling to supplement the July/August 

2000 episode. These alternative episodes under study include September 

2000 and July 1999. 

5. Comment: Performance of the CAMx model for the July/August 2000 

episode is also of concern because the meteorology has been modified to 

improve results, and because even then the performance of the model is 

spotty in predicting ozone levels (modeling results meet EPA criteria in some 

subregions and do not in others). It should also be noted that the EPA 

performance metrics are not very stringent, and there are prior examples of 

modeling simulations that pass those metrics but still had identifiable and 

significant problems. 

Response: The District strongly supports the need to analyze the results of 

the current modeling and identify the problems. The Technical Committee, 

districts and ARB are identifying and correcting issues associated with the 

modeling. The Technical Committee, districts and ARB are developing an 

overall schedule for modeling improvements and implementation. Modeling 

will be needed for the 8-hour SIP and the 1-hour update SIP (if needed) by 

September 2006. 

6. Comment: Another modeling issue is the significant difference in shapes of 

the carrying capacity diagrams for Bakersfield/Edison vs. Fresno/Arvin, even 

though these areas are not far apart. The shapes of the Fresno/Arvin 

diagrams are similar to what was observed in previous SJVAB modeling 

exercises, and show that reductions in either VOC or NOx emissions will lead 

to attainment. However, the diagrams for Bakersfield and Edison show that 

VOC is limiting in these areas, and the vertical pattern of the curves is 

substantially different that what would be expected, and also suggests that no 

ozone air quality improvements would result from NOx controls in the 

Bakersfield area. A related issue is that the carrying capacity diagrams for 

Bakersfield/Edison contradict the findings of most of the previous ozone air 

quality data analysis for this area. This discrepancy raises a red flag with 

regard to model performance. 
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H-23 

Response: The District agrees that geographic differences in carrying 

capacity diagrams, as well as the departure of these new results from previous 

findings, warrant further study before the results are used in planning. See 

response to previous comment. 

7. Comment: The carrying capacity diagrams presented at the workshop reflect 

the application of a relative reduction factor. When EPA developed the 

concept of the relative reduction factor, they assumed that application of the 

factor dealt with the non-linear nature of ozone formation over a small 

concentration range, and that this was acceptable. However, the current 

application is done over a much larger concentration range, and it is not clear 

whether the assumptions hold when doing this type of scaling. Based on 

some of the work done by Blanchard and Reynolds (JAWMA, Vol.53, 195 

(2003)) to look at attainability of the 8-hour ozone standard in Central 

California, the efficiency of ozone production increases with reductions of NOx 

at the lower concentrations currently predicted by the model, as compared to 

the higher observed concentrations. Thus, real thought should go into use of 

the relative reduction factor. 

Response: Relative reduction factors were included in the preliminary 

modeling results presented at the workshop. The District and ARB continue to 

evaluate the appropriateness of using relative reduction factors for the SJVAB 

ozone modeling, and may decide to abandon the concept of relative reduction 

factors for the SJVAB ozone modeling. 

8. Comment: Significant improvements have been made in the emissions 

inventory over the decade; however the recent top down analysis of the mobile 

source inventory for the Fresno sub-region of the modeling domain suggests 

that heavy-duty diesel NOx emissions are underestimated by 60%. While top 

down analyses have uncertainties, an underestimate of this magnitude 

suggests a need to reexamine the inventory from the bottom up. 

Response: The District and ARB recognize that a variety of uncertainties 

exist with respect to the emissions inventory, including the one mentioned 

above. The 1-hour ozone attainment demonstration plan will be developed 

using the best inventory available at the time. The District and ARB will work 

towards identifying and resolving these inventory issues in time for the 2007 

update to the 1-hour ozone plan (if needed) as well as for the 8-hour plan to 

be developed in the same general time frame. 

9. Comment: While the 1-hour plan is important, the District should also start 

looking at emissions reductions needed to attain the 8-hour standard. The 

work done by Reynolds and Blanchard indicates that while either VOC or NOx 

might lead to reductions of the one-hour standard, NOx reductions were much 

more effective in reducing 8-hour ozone (and the state one-hour ozone) 

standard. VOC reductions became ineffective below 100 ppb (8-hour 

average). Thus, the District needs to formulate a strategy that addresses both 

standards in an optimal fashion. To do so, it must look at the impacts on the 8-

hour standard as part of this SIP. 

Response: The District and ARB are focused on completing the 1-hour 

ozone attainment demonstration plan and submitting it to EPA by the deadline. 

Where possible, the modeling analyses will also look at the relationships 

between emissions rates and 8-hour ozone levels. 
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H-24 

10. Comment: The San Joaquin Valley may be a single air basin, but evidence 

exists of physical sub-regions within the district boundaries. At times these 

sub-regions may exhibit different emissions characteristics (e.g., the VOC 

emissions inventory fraction represented by mobile sources in Fresno vs. 

Bakersfield). Thus, “a one-size fits all” strategy may not always be 

appropriate. To prepare an effective one-hour (and 8-hour) emissions 

reduction strategy, the District should determine if different mixes of emissions 

reductions are the most effective means to address ozone concentrations in 

the north, central and southern sub-regions. 

Response: As the CCOS data analyses that are now ongoing provide 

additional insights into ozone production and behavior in the SJVAB, the 

District and ARB will have an improved technical basis for identifying the 

existence of “sub-regions” and understanding their sources and fate of ozone 

pollution. At present, merely correlating emissions profiles with measured 

ozone levels at a particular location gives little attention to pollutant transport, 

which can be an important contributor; consequently, the District is reluctant to 

explore sub-regional controls at this time. However, the appropriate technical 

base may exist for the 2007 extreme plan revision and/or the 8-hour plan. 

11. Comment: Based on currently available data, the District should minimize 

future rules controlling VOC emissions and instead focus on reducing NOx 

emissions (unless the VOC reductions are needed for attainment with the 

PM2.5 standard or for air toxics considerations). Otherwise, additional VOC 

reductions may satisfy the bookkeeping requirements for Rate of Progress 

plans, but be ineffective in an optimal ozone strategy that results in attainment 

of the 1-hour and 8-hour standards. 

Response: Modeling results presented at the workshop, while preliminary in 

nature, do show that both NOx and VOC emission reductions reduce ozone 

levels in the SJVAB. The District will continue to pursue both VOC and NOx 

reductions for the 1-hour ozone plan.