### Resolution 07-28

September 27, 2007

Attachment B

Proposed Modifications to the Air Resources Board’s Proposed State Strategy for California’s 2007 State Implementation Plan that will Achieve 30 Tons Per Day of Additional Emi ssion Reductions in the South Coast by 2014 and 88 to 93 Tons Per Day of Em ission Reductions in the San Joaquin Valley by 2017Resolution 07-28 2

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(This page intentionally left blank.)Resolution 07-28 3

Attachment B

State Implementation Plan Commitments

This section sets forth the State’s SIP commitments for the 2007 State Strategy for two

of the areas that need the emission benefits from t he proposed, new State measures to demonstrate attainment – South Coast and San Joaqui n Valley. Specific commitments

for emission reductions as needed for attainment in other nonattainment areas, such as the Antelope Valley and Western Mojave Desert, Sacr amento, and Ventura County, will be developed later and brought for Board considerat ion with SIPs for these regions.

The State’s SIP commitments consist of three compon ents:

1. Commitment to achieve emission reductions by spe cific dates; 2. Commitment to propose defined new SIP measures; and 3. A long-term strategy commitment.

The total emission reductions and the obligation to propose specific measures for Board consideration would become federally enforceable up on approval by U.S. EPA of the State Strategy and each district’s attainment plan. The commitments for emission reductions are calculated using the planning invent ory described in Appendix A; progress will be tracked in the same inventory curr ency to assess compliance.

The total emission reductions from the new measures necessary to attain the federal
standards are an enforceable State commitment in th e SIP. While the proposed State Strategy includes estimates of the emission reducti ons from each of the individual new measures, it is important to note that the commitme nt of the State Strategy is to achieve the total emission reductions necessary to attain t he federal standards, which would be the aggregate of all existing and proposed new meas ures combined. Therefore, if a particular measure does not get its expected emissi on reductions, the State still commits to achieving the total aggregate emission r eductions, whether this is realized through additional reductions from the new measures or from alternative control measures or incentive programs. If actual emission decreases occur in any air basin for

which emission reduction commitments have been made that are greater than the projected emissions reductions from the adopted mea sures in the State Strategy, the actual emission decreases may be counted toward mee ting ARB’s total emission

reduction commitments.

Commitments to Reduce Emissions

The tables below describe the tons per day emission reduction commitment proposal for Board approval. ARB staff proposes to commit to ac hieve the emission reductions set forth in these tables, by the dates indicated in th e table on page 5 of this sectionResolution 07-28 4

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entitled, “Schedule for Board Consideration of Prop osed ARB Rulemaking.” The reductions may be achieved through a combination of actions, including regulations, incentives, and other enforceable mechanisms.

Summary of Emission Reduction Commitments – South C oast

Year NOx ROG Direct

PM2.5 SOx

2014 122 46 9 20

2020 1 144 52 -- --

2023 141 54 -- --

2023 CAA 182(e)(5)

measures 241 2 40 2

-- --

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

nonattainment areas.

2 The reductions of NOx and ROG from 182(e)(5) measu res will be reassessed as new SIPs are developed and revised.

Summary of Emission Reduction Commitments – South C oast
Additional NOx Reductions to Meet District’s PM2.5 Target

Year NOx

2014 30

Commitments to Secure Additional Emission Reduction s to Help Meet the South Coast District’s PM2.5 Emission Reduction Target

ARB commits to secure 30 tons per day (tpd) of NOx emission reductions in the South Coast Air Basin by 2014 (in addition to the 122 tpd NOx commitment in the table on page 18 of this document). In addition, ARB commit s to working with the South Coast Air Quality Management District (District) to secur e funding for the District to achieve 6 tpd of NOx emission reductions from port-related an d other sources and from Metrolink trains (see table on page 2, Section 1), and to bac kstop the District’s 6 tpd emission reduction commitment. “Backstop” means that ARB co mmits to secure some or all of the 6 tpd of the District’s emission reduction comm itment if the District fails to achieve

the emission reductions.

ARB’s emission reduction commitments may be achieve d through a combination of actions including but not limited to the implementa tion of control measures; theResolution 07-28 5

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expenditure of local, State or federal incentive fu nds; or through other enforceable measures. In addition, ARB may meet its emission r eduction commitments by securing ROG, SOx, or direct PM2.5 emission reductions inste ad of NOx reductions, if these reductions achieve the equivalent air quality benef it of reducing NOx as specified in Table V-2-14 of the District’s Air Quality Manageme nt Plan (AQMP) as replicated below. Finally, if actual emission decreases occur in the South Coast Air Basin that are greater than the projected emissions reductions from the ad opted measures in the State Strategy, the actual emission decreases may be coun ted toward meeting ARB’s total

emission reduction commitments.

If U.S. EPA makes a finding under section 179(c)(1) of the Clean Air Act that the South Coast Air Basin has attained the Annual Average PM2 .5 National Ambient Air Quality

Standard before the entire commitment has been achi eved, ARB commits to achieving the remaining emission reductions, but they may be achieved after 2014 but no later

than 2017.

Table V-2-14 of the South Coast AQMP

Relative Contributions of Precursor Emissions Reduc tions to Simulated

Controlled Future-Year PM2.5 Concentrations

Precursor (TPD) PM2.5 Component Standardized

Contribution to Mass VOC Organic Carbon Factor of 1

NOx Nitrate Factor of 3

PM2.5 Elemental Carbon & Others Factor of 5

SOx Sulfate Factor of 10Resolution 07-28 6

Attachment B

Summary of Emission Reduction Commitments – San Joa quin Valley

Year NOx ROG Direct

PM2.5 SOx

2014 76 23 5 0

2020 56 24 -- --

2023 46 25 -- --

2023 CAA 182(e)(5)

measures 81 1

-- 1

-- --

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

and revised.

Summary of Emission Reduction Commitments – San Joa quin Valley
NOx Reductions to Accelerate Ozone Standard Attainm ent

Year NOx

2017 88-93

Summary of Emission Reduction Commitments – Coachel la Valley

Year NOx ROG

2018 7 2Resolution 07-28 7

Attachment B

Commitment to Propose Defined New SIP Measures

In addition to the commitment to reduce emissions b y 2014, 2020 and 2023, ARB staff also proposes to commit to submit to the Board and propose for adoption the list of proposed new ARB control measures shown in the tabl e below. The Board shall take

action on or before the dates set forth in the foll owing table. Such action by the Board may include any action within its discretion.

Schedule for Board Consideration of Proposed ARB Ru lemaking

Proposed New SIP Measures Year Cleaner In-Use Off-Road Equipment
Modifications to Reformulated Gasoline Program
Cleaner Main Ship Fuel
Clean Up Existing Harbor Craft
Enhanced Vapor Recovery for Above Ground Storage Ta nks 2007

Cleaner In-Use Heavy-Duty Trucks

Port Truck Modernization
Ship Auxiliary Engines
Cleaner Line-Haul Locomotives (Enforceable Agreemen t)
Consumer Products Program I 2008

Cleaner In-Use Agricultural Equipment

New Emission Standards for Recreational Boats
Expanded Off-Road Recreational Vehicle Emission Sta ndards
Additional Evaporative Emission Standards 2009-2010

Consumer Products Program II 2010-2012Resolution 07-28 8

Attachment B

State Strategy Proposed New SIP Measures Implementing Agency – Expected Action – Expected Im plementation

Proposed New SIP Measures Implementing Agency Expected

Action Expected

Implementation Passenger Vehicles Smog Check Improvements BAR 2007-2008 By 2010
Expanded Vehicle Retirement ARB/BAR 2008-2014 2008-2014

Modifications to Reformulated Gasoline Program ARB 2007 Phase-in starting 2010

Trucks
Cleaner In-Use Heavy-Duty Trucks ARB 2008 2010-2015

Goods Movement Sources Auxiliary Ship Engine Cold Ironing and Other Clean Technology EPA/ARB/

Local 2007-2008 Phase-in starting 2010

Fuel: 2007 2007-2010 Cleaner Main Ship Engines and Fuel EPA/ARB

Local Engines:

2009 Phase-in

starting 2010

Port Truck Modernization ARB/Local 2007-2008 2008-2020

Accelerated Introduction of Cleaner

Line-Haul Locomotives EPA/ARB 2007-2008 Starting in 2012

Clean Up Existing Harbor Craft ARB 2007 2009-2018

Off-Road Equipment

Cleaner In-Use Off-Road Equipment ARB 2007 Phase-in starting 2008

Cleaner In-Use Agricultural Equipment ARB 2009 Phase-in starting 2014

Other Off-Road Sources

New Emission Standards for

Recreational Boats ARB 2009-2010 2012-2013

Expanded Off-Road Recreational

Vehicle Emission Standards ARB By 2010 2012-2015

Enhanced Vapor Recovery for Above Ground Storage Tanks ARB 2007 Phase-in starting 2008 Additional Evaporative Emission
Standards ARB By 2010 2010-2012

AREAWIDE SOURCES

2007-2008 By 2010 Consumer Products Program ARB 2010-2012 By 2012-2014 DPR Pesticide Regulation DPR 2008 2008

DPR = Department of Pesticide Regulation. BAR = Bu reau of Automotive RepairResolution 07-28 9

Attachment B

Cleaner In-Use Heavy-Duty Trucks (replaces 4/26/07 version)

Federal and State engine standards will ensure that by 2010 all new diesel heavy-duty trucks are 90 percent cleaner than new 2006 trucks. This tremendous progress is on top of a 65 percent reduction in NOx and an 85 perc ent reduction in particulate matter since 1990. Since trucks last a long time, we must bring newer trucks into the fleet at a faster pace, clean up older, dirtier trucks, and ke ep the clean trucks clean longer to help meet air quality goals.

Between now and 2014 existing programs reduce heavy -duty truck emissions by 50 percent. This proposed measure would reduce 2014 e missions another 60 percent. The measure would accomplish these new reductions t hrough a program to reduce emissions from the legacy fleet involving accelerat ing the turnover to new truck engines and retrofitting the remaining trucks with emission reduction devices, and through an excess emissions program.

Legacy Fleet Emission Reduction Program

Newer heavy-duty trucks are typically used in long- haul service. After seven or eight years, they are often sold and their service is typ ically shifted to shorter-haul work. These trucks may remain in service within a given r egion for another 20 years or more.

An in-use truck program would focus on overcoming t he slower rate of heavy-duty truck turnover to cleaner engines and retrofitting the re maining trucks with emission control devices such as particulate matter filters. The mo st comprehensive way to accomplish this would be through an “in-use” fleet rule that w ould require truck owners to meet specified emission levels. The proposed measure wo uld address fleets operating in California regardless of whether they are registere d out of state and would also address trucks serving California ports.

The emission reduction impact of the proposed measu re would be equivalent to having the entire model year 2006 and older heavy-duty tru ck fleet meet model year 2007 emission levels by 2014. While separate rulemaking efforts, along with other actions, will be used to address private truck fleets and po rt trucks, the relative emission reduction goals for both efforts are the same. The proposed measure would generate additional emission reductions beyond 2014, achievi ng reductions needed to meet the ozone air quality standard.

The proposed measure would provide an additional 27 tons per day of NOx reductions in the South Coast in 2014 over what was proposed i n the April 2007 proposed State Strategy in order to help meet the South Coast Dist rict’s PM2.5 target. The proposed measure would also provide an additional 17 tons pe r day of NOx reductions in the SanResolution 07-28 10

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Joaquin Valley in 2017 over the impact (45 tons per day) of what was proposed in the April 2007 proposed State Strategy in order to help accelerate ozone air quality

progress.

Rulemaking is currently in progress for a port truc k modernization rule. ARB staff has also recently begun informational workshops on a he avy-duty truck in-use fleet rule, and has started to identify and explore the many emissi ons inventory, technology, financial, and logistical issues involved in crafting the most effective rule possible. ARB staff will be studying and requesting feedback from stakeholde rs on many issues, including: the characteristics of trucks registered outside of Cal ifornia; cost implications, especially to truck owner-operators, and ways to avoid any compet itive disadvantage for various categories of truck owners; and the most efficient use of limited public incentive funds to

achieve maximum emission benefits and lessen financ ial burden on truck owners.

Excess Emissions Program

An estimate of deterioration of emission controls h as historically been built into ARB’s projections of future emissions. As new engine tec hnologies are introduced over the next few years, we need to ensure that the complex engine electronics and control

devices used to make trucks so much cleaner are not more prone to failure, tampering or malmaintenance, and that deterioration does not reduce the benefits of the new standards. As the 2010 new engine standards are im plemented, we will evaluate the inuse emissions and develop approaches to reduce exce ss emissions from trucks.

Under an existing program, heavy-duty trucks are in spected at random roadside locations for excessive smoke, and are inspected fo r tampered emission control systems. Owners of vehicles that do not pass these inspections are issued citations that require prompt repairs and carry civil penalti es. This measure could include an expansion of this program.

While the design and evaluation of the specific pro gram features has yet to be determined, ARB staff estimates that this concept h as the potential to reduce NOx deterioration emissions by approximately 50 percent

.Resolution 07-28 11

Attachment B

Estimated Emission Reductions

South Coast

(tons per day) 2006 2014 2020 2023

Baseline emissions 16 10 7 6 ROG Potential reductions -- 7.5 2.6 1.7

Baseline emissions 238 131 79 65 NOx Potential reductions -- 76.0 34.9 25.3

Baseline emissions 10.2 5.3 3.3 2.8 PM2.5 Potential reductions -- 4.3 1.8 1.3

San Joaquin Valley

(tons per day) 2006 2014 2020 2023

Baseline emissions 20 13 9 8 ROG Potential reductions 6.4 3.3 2.3

Baseline emissions 277 150 88 72 NOx Potential reductions 61.4 30.2 21.2

Baseline emissions 11.4 5.5 3.2 2.6 PM2.5 Potential reductions 3.6 1.6 1.2

Baseline emissions represent emissions from diesel- fueled medium- and heavy heavyduty trucks. (Note: Baseline emissions reflect ad justments not included in the SIP Emission Inventory Projections on ARB’s website. T he adjustments include sleeper truck idling restrictions, diesel engine software u pgrade, and emission reductions from the Carl Moyer Program.)

Timing

Action: 2008 Expected Implementation: 2010-2015

Staff Proposed SIP Commitment

ARB staff proposes to commit to bring this measure to the Board by 2008. ARB staff will initiate a rule development process designed t o achieve the reductions shown for the South Coast and San Joaquin Valley in 2014, 202 0, and 2023, plus the benefits referenced in the text for 2017 in the San Joaquin Valley. The measure as proposed by staff to the Board or adopted by the Board may prov ide more or less emission

reductions than the amount shown.Resolution 07-28 12

Attachment B

Cleaner In-Use Off-Road Equipment (replaces 4/26/07 version)

Adopted emission standards for new off-road diesel engines are becoming increasingly more stringent, ensuring that new construction, min ing, industrial, oil drilling and airport ground support equipment become progressively clean er. The cleanest standards for NOx emissions in these categories will phase in fro m 2013-2015. However, large diesel off-road equipment with more than 25 horsepower rem ain in use for long periods of time, often 25 years or more. This long life means that new, lower emitting engines are introduced into fleets relatively slowly with the r esult that the emission reductions and associated health benefits from these cleaner engin es will also be slow to materialize. Accelerating the introduction of cleaner engines an d emissions control technologies into the statewide fleet is necessary to meet air qualit y standards.

This proposed measure is based on the regulation ad opted by the Air Resources Board in July 2007. The adopted regulation requires owne rs of equipment larger than 25 horsepower to meet a stringent average emissions le vel across all of their equipment. The fleet average approach provides equipment owner s flexibility in how they will comply, including: swapping older, dirtier engines with newer, cleaner engines; purchasing newer equipment (with cleaner engines); and, adding emission control devices to older engines. It also allows fleet own ers to maintain a fleet with some engines which are cleaner than the fleet average an d others which are dirtier, so that, on average, the fleet meets the target. The regula tion also includes idling limits similar to those the Board has adopted for heavy duty truck s.

Staff began work on the rule in 2004 as part of the Diesel Risk Reduction Program. During early SIP development work in 2006, staff id entified the necessity for large NOx emission reductions from off-road equipment and oth er diesel sources to meet the health-based federal air quality standards. Conseq uently, staff revised the control concept extensively to meet California’s clean air needs relative to diesel particulates, ozone, and PM2.5.

This measure would reduce NOx emissions from large diesel off-road equipment in the South Coast Air Basin by approximately 10 percent i n 2014 and by about 30 percent in

2023.

In addition to the statewide provisions of the new off-road diesel vehicle rule, the Board also approved an opt-in provision for a regional in centive program to achieve additional NOx reductions. The Surplus Off-road Opt-in for NO x (SOON) program gives air districts the option of requiring older, larger fle ets to meet a higher level of control when incentive funds are available to help offset the co st of control. A SOON program funding commitment from the South Coast air distric t is estimated to achieve additional NOx emission reductions of 12 tons per day in the S outh Coast in 2014. If the San Joaquin Valley air district opts in to the SOON pro gram it is estimated thatResolution 07-28 13

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approximately 4 tons per day of additional NOx redu ctions could be realized in the San Joaquin Valley in 2014. Since the SOON program ref lects a local air district commitment that would enhance what the regulation w ould achieve, estimated SOON program emission reductions are not reflected in th e tables below.

Estimated Emission Reductions

South Coast

(tons per day ) 2006 2014 2020 2023

Baseline Emissions 20.2 13.3 9.3 8.1 ROG
Potential Reductions 2.7 2.9 1.9

Baseline Emissions 143.2 96.1 59.0 46.5 NOx
Potential Reductions 10.5 18.7 13.9

Baseline Emissions 8.1 4.9 2.6 1.8 PM2.5
Potential Reductions 2.6 1.8 1.3

San Joaquin Valley

(tons per day ) 2006 2014 2020 2023

Baseline Emissions 6.1 4.2 3.1 2.7 ROG Potential Reductions 0.9 1.0 0.6

Baseline Emissions 47.6 32.8 21.6 17.7 NOx Potential Reductions 3.7 7.0 5.4

Baseline Emissions 2.3 1.5 0.8 0.6 PM2.5 Potential Reductions 0.8 0.6 0.4

Baseline emissions are from the OffRoad2007 model.

Emission reduction estimates are based on expected emission reductions from ARB’s adopted In-Use Off-Road Diesel Vehicle rule.

The rule applies declining fleet averages for large fleets beginning in 2010. For NOx, the fleet averages for 2014 for most engine sizes a re more stringent than Tier 1 emission levels. The corresponding PM fleet averag es for 2014 are cleaner than Tier 2 emission levels. In 2020, fleet averages for NOx a nd PM are more stringent than Tier 3

emission levels. The means to reach these fleet ave rages are left to the equipment owners to decide. However, if a fleet cannot meet the NOx averages, it must turn over 8 percent of its total horsepower per year to clean er engines (minimum Tier 2 engine) in the initial years and 10 percent per year in years after 2015. A fleet must retrofit 20 percent of its total horsepower with diesel particu late filters if it cannot meet the PM average. The rule would also restrict unnecessary idling. If an air district opts in to the SOON program, then fleets with more than 40 percent Tier 0 and Tier 1 vehicles and maximum power greater than 20,000 horsepower must a pply for incentive funding ifResolution 07-28 14

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their fleet operating in the air district exceeds N Ox targets, and must use the incentive funding for retrofits, repowers, or replacements to meet the NOx targets. Fleets with maximum power less than or equal to 20,000 horsepow er are not required to apply for funding, but may choose to do so on a voluntary bas is if they exceed NOx targets.

Timing

Action: 2007 Expected Implementation: Phase-in starting 2008

Staff Proposed SIP Commitment

The Air Resources Board adopted the In-Use Off-Road Diesel Vehicle rule at its July 2007 meeting.Resolution 07-28 15

Attachment B

Co-Benefits from Greenhouse Gas Reduction Measures (new measure)

The California Global Warming Solutions Act of 2006 (AB 32) establishes a comprehensive program to curb greenhouse gases. Th e law requires ARB to implement a statewide strategy to reduce greenhouse gas emissions by roughly 25 percent by 2020. As engines, equipment and manufac turing processes are made more efficient to reduce greenhouse gases, some criteria pollutant emissions are reduced as well. This measure would include the criteria poll utant emission reduction co-benefits of
ARB’s actions and other actions within the State to mitigate climate change as mandated by AB 32.

Early action measures to help meet AB 32’s goal hav e already been adopted by ARB and more have been proposed. Governor Schwarzenegg er has initiated programs (such as the Green Buildings Initiative and Califor nia Solar Initiative) to reduce energy use and greenhouse gases. AB 32 includes an aggres sive timeline for ARB action that includes adopting regulations by January 2011 to ac hieve the maximum technologically feasible and cost-effective reductions in greenhous e gases.

ARB staff estimates that greenhouse gas reduction m easures would reduce roughly 3 tons per day of NOx in the South Coast by 2014.Resolution 07-28 16

Attachment B

Cleaner In-Use Agricultural Equipment (replaces 4/26/07 version)

New engines used in agricultural equipment, primari ly tractors, must meet the same standards as other off-road engines, ensuring that new equipment becomes progressively cleaner. Just as in other off-road a pplications, diesel agricultural equipment can remain in use for long periods of tim e. This long life means that equipment with new, lower emitting engines are intr oduced into fleets relatively slowly with a direct impact on the pace that emission redu ctions materialize.

The cleanup of agricultural in-use equipment is pri marily an issue in the San Joaquin Valley with its large agricultural economy. Natura l turnover of the agricultural fleet will reduce emissions significantly, but not sufficientl y to meet the region’s clean air needs.

Therefore, the goal of this measure is to accelerat e fleet turnover to equipment with engines meeting cleaner new engine NOx standards as quickly as possible. Conversion to the cleanest Tier 4 engines is linked to timing of U.S. EPA’s standards for off-road diesel engines. The cleanest standards fo r small engines, 25 hp and below, already apply. Unfortunately, the cleanest standar ds for larger engines do not come on line until 2013, 2014, or 2015 depending on the eng ine size. ARB estimates that about three-quarters of all NOx emission from agricultura l equipment come from equipment with diesel engines in the midsize range, 50 to 175 hp.

The advantage of setting a goal of full conversion to Tier 4 equipment is that it ultimately

results in the cleanest fleet. While this is the s tarting point for staff’s proposal we recognize that significant reductions can be achiev ed sooner by upgrading the dirtiest, old equipment to Tier 3. To that end we are suppor ting efforts to secure federal funds

and other mechanisms to achieve near-term reduction s that can be credited to the SIP.

Given the timing of the federal NOx standards and i mportance of the clean-up of equipment in the midsize ranges, ARB staff proposes to begin full implementation of the fleet clean-up measure in 2014 taking into account early upgrades to Tier 3 equipment. During detailed rulemaking, ARB staff will also eva luate the opportunity and benefit of beginning earlier for equipment in the narrow size ranges where clean equipment are available before 2014. The availability of incenti ves will be the critical factor along with equipment availability governing how fast the equip ment can be done.

Emission reduction estimates are based on ARB’s OFF ROAD2007 emissions model. That model is based on equipment population data fr om the U.S. Department of Agriculture’s Census of Agriculture (1992) and gene ral assumptions about the useful life of the equipment and their operating hours. During rule development for ARB’s recently adopted construction equipment rule, ARB staff coll ected detailed population, use, and age data from the construction industry that was us ed to refine emission estimates. The same effort must be done for farm equipment. Staff expects that it will result inResolution 07-28 17

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substantially different estimates from the emission s and the measure benefits presented

below.

While staff expects to start rule development begin ning with a fleet average approach like that used in the construction equipment clean- up rule, the economics of the agricultural industry will factor heavily into the design of the final rule. Farmers face a unique market structure that affects their ability to pass costs on to their buyers. For some operations, especially the largest with the ad vantage of economic scale, an equipment replacement schedule will already be part of their business plan. But for smaller operations with just one or two pieces of e quipment, the current business plan may be to retain existing equipment for as long as possible. Maximizing reductions in light of factors such as these will require careful rule design and the optimum use of

incentives.

San Joaquin Valley

(tons per day ) 2006 2017*

Baseline Emissions 13 4 ROG Potential Reductions -- 0.6-1.3

Baseline Emissions 62 25 NOx Potential Reductions -- 5-10

Baseline Emissions 3.5 1.3 PM2.5 Potential Reductions -- TBD

* Does not represent final implementation date

Timing

Action: 2009 Expected Implementation: Beginning in 2014

Staff Proposed SIP Commitment

ARB staff proposes to commit to bring this measure to the Board by 2009. ARB staff will initiate a rule development process designed t o achieve the reductions shown for the San Joaquin Valley nonattainment areas. The ru le will be phased in beginning in 2014. The final implementation date will be determ ined in the rulemaking process. The measure as proposed by staff to the Board or adopte d by the Board may provide more

or less than the amount shown based additional info rmation including but not limited to emission inventory updates.