# Technical Support Document

for the Revised Proposed Rulemaking Action

on the San Joaquin Valley 2008 PM 2.5 

## Plan and the San Joaquin Valley Portions of the Revised 2007 State Strategy

Air Division U.S. EPA Region 9 June 29, 2011For further information on this techni cal support document, please contact:

Frances Wicher Office of Air Planning (AIR-2) U.S. Environmental Protection Agency-Region 9 75 Hawthorne Street San Francisco, California 94105 (415) 972-3957 wicher.frances@epa.gov

Documents referenced in this technical suppor t document may be found in the docket for this rulemaking, docket no. EPA-R09-OAR-2010-0516, wh ich may be found at www.regulations.gov or at the address listed above.

## Table of Contents

i I. Introduction and Background A. The National Ambient Air Quality Standards for Fine Particulate (PM 2.5 ) 1

1. The PM 2.5 National Ambient Air Quality Standards 1 a. Level and Form of the Standard 1 b. Health Effects 2 c. Revisions to the 24-Hour PM 2.5 Standards 2 2. Implementing the PM 2.5 NAAQS 2 a. Designations 2 b. PM 2.5 Planning Requirements 3

B. PM 2.5 Air Quality in the San Joaquin Valley 5

1. PM 2.5 Levels in the SJV 6 2. Seasonality and Chemical Composition of PM 2.5 in the SJV 7 C. California’s Submittals Constituting the SJV PM 2.5 State Implementation Plan 11 D. Public Notice and Hearing Requirements for and Completeness of SIP Submittals 13 1. Public Notice and Hearing Requirements for SIP Submittals 13 2. Completeness Determinations on SIP Submittals 13

II. Evaluation of the San Joaquin Valley 2008 PM 2.5 SIP

A. Emissions Inventories 16 1. Requirements for Emissions Inventories 16

2. Emissions Inventories in the SJV PM 2.5 SIP 17 3. November 2010 Proposed Acti on on Emissions Inventory 18

4. Evaluation and Conclusions 18 B. Air Quality Modeling 22 1. Requirements for Air Quality Modeling 22 2. Air Quality Modeling in the SJV 2008 PM 2.5 Plan 22 a. Conceptual Description 24 b. Modeling Protocol 25 c. Air Quality Model Selection 27 d. Episode Selection 28 e. Domain, Domain Size, and Spatial Resolution 29 f. Initial and Boundary Conditions 31 g. Meteorological Model 31 h. Meteorological Model Performance 34 i. Emissions Inventory 36

## Table of Contents

ii j. Air Quality Model Performance 37 k. Modeled Attainment Test 40 l. Unmonitored Area Analysis 42 m. Weight of Evidence 43

3. Conclusions 45

4. Pollutant Ratios Used to Determine PM 2.5 Equivalency 46 5. Effect of Inventory Changes on the Air Quality Modeling and Attainment Demonstrations 47

C. PM 2.5 Attainment Plan Precursors 50 1. Requirements for the Control of PM 2.5 Precursors 50

2. Identification of PM 2.5 Attainment Plan Precursors in the SJV 2008 PM 2.5 Plan and EPA’s Evaluation 51

3. Conclusions 66 D. Reasonably Available Control Measures /Reasonably Available Control Technology 68 1. Requirements for RACM/RACT 68 2. RACM/RACT Analysis in the SJV PM 2.5 SIP 69 a. District RACM/RACT Analysis 70 b. Local Jurisdictions’ RACM Analysis 71 c. State’s RACM Analysis 73 3. November 2010 Proposed Action on the RACM/RACT Demonstration 76

4. Evaluation and Conclusions 76

E. Attainment Date Extension 78 1. Requirements for Attainment Date Extensions 78 2. Proposed Attainment Date in the SJV 2008 PM 2.5 Plan 78 3. November 2010 Proposed Action on th e Attainment Date Extension 81

4. Evaluation and Conclusions 82 F. Adopted Control Strategy and Enforceable Commitments 83 1. Requirements for Control Strategies and Enforceable Commitments 83 2. Control Strategy in the SJV 2008 PM 2.5 Plan and Revised 2007 State Strategy 84 a. District Control Strategy Measures and Commitments 84 b. CARB Measures and Commitment 94 3. November 2010 Proposed Action on the Control Strategy and Enforceable Commitments 97

4. Evaluation and Conclusions 98

## Table of Contents

iii a. Baseline and Contro l Strategy Measures 98

i. Section 209 Wa iver Measures 100 ii. Non-waiver measures 103 b. Enforceable Commitments 103

i. The Commitment is a Limited Portion of Required Reductions 106 ii. The State is Capable of Fulfilling Its Commitment 107 iii. The Commitment is for a Reasonable and Appropriate Timeframe 107 iv. Summary of Proposed Finding on Enforceable Commitments in the SJV 2008 PM 2.5 SIP 108 v. Proposed Action on Enforceable Commit ments to Reduce Emissions and Adopt Specific Measures 108

G. Attainment Demonstrations 109 1. Requirement for Attainment Demonstrations 109

2. Attainment Demonstration in the SJV 2008 PM 2.5 Plan 109 3. November 2010 Proposed Action on the A ttainment Demonstration in the SJV 2008 PM 2.5 Plan 114

4. Evaluation and Conclusions 114 H. Reasonable Further Progress Demonstrations 116 1. Requirements for Reasonable Furt her Progress Demonstrations 116

2. RFP Demonstration in the SJV 2008 PM 2.5 Plan 117 3. November 2010 Proposed Action on the RFP Demonstration in the SJV 2008 PM 2.5 Plan 119

4. Evaluation and Conclusions 119 I. Contingency Measures 124 1. Requirements for Contingency Measures 124 2. Contingency Measures in the SJV 2008 PM 2.5 Plan and 2011 Progress Report 125 a. New Commitment 125 b. General Surplus Reductions in th e RFP Demonstration and Post-2014 125 c. Adopted or Scheduled for Adoption Rules/Incentive Funds 126 3. November 2010 Proposed Action on the C ontingency Measures in the SJV 008 PM 2.5 SIP 128

4. Evaluation and Conclusions 128 a. New Commitment 129 b. General Surplus Reductions in th e RFP Demonstration and Post-2014 129 c. Adopted or Scheduled for Adoption Rules 130 d. Conclusion 131

## Table of Contents

iv J. Adequacy of the Motor Vehicle Emissions Budgets in the SJV 2008 PM 2.5 SIP 135 1. Requirements for Motor Vehicle Emissions Budgets 135 2. Motor Vehicle Emissions Budgets in the SJV 2008 PM 2.5 SIP 136 a. MVEB Submitted in SJV 2008 PM 2.5 Plan (submitted June 2008) 136 b. Updated MVEB Submitted in 2011 Progress Report 136 3. Proposed Actions on the MVEB 142 a. April 23, 2010 Budget Adequacy/Inadequacy Finding 142 b. 2010 Proposed Action on the MVEBs in the SJV 2008 PM 2.5 SIP 142 c. Proposed Action on the Revised Update MVEB 143 4. Proposed Action on Trading Mechanism 148

Appendix A – CARB Rules and Measures A. Complete List of State Measures 1

B. State Rules that Do Not Address Direct PM 2.5 or PM 2.5 Attainment Plan Precursors in the San Joaquin Valley 20

C. State Fuel Measures 27

D. State On-Road Mobile Sources Measures 29

E. State Consumer Product Measures 39 F. State Vapor Recovery Measures 41

G. Other State Measures 43

Appendix B – SJVAPCD Rules

Appendix C - List of Document References

## Acronyms & Terms

v μ: micron (one millionth) AB: California Assembly Bill AERR: Air Emissions Report Ru le, 40 CFR part 51, subpart A ARB: California Air Resources Board (also CARB) APCD: air pollution control district AQMD: air quality management district BAR: California Bureau of Automotive Repair CAA: Federal Clean Air Act as amended in 1990 CARB: California Air Resources Board (also ARB) CCAQS: Central California Air Quality Study CCR: California Code of Regulations CEFS: California Emissions Forecasti ng and Planning Inventory System CEIDARS: California Emissions Invent ory Development and Reporting System CERR: Consolidated Emissions Repor ting Rule, 40 CFR part 51, subpart A CFR: Code of Federal Regulations CMAQ: Congestion Mitigation and Air Quality funds CMAQ: Community Multiscale Air Quality [model] CMB: chemical mass balance CO: carbon monoxide CPM: condensable particulate matter CRPAQS: California Regional Pa rticulate Air Quality Study District: San Joaquin Valley Air Pollution Control Agency DPR: California Department of Pesticide Regulation EC: elemental carbon EPA: United States Environmental Protection Agency FHWA: Federal Highway Administration Fine particulate: PM 2.5 FMVCP: Federal motor vehicle control program FR: Federal Register FRM: Federal Reference Method FTA: Federal Transit Administration HNO 3 : nitric acid I/C: internal combustion IMS95: 1995 Integrated Monitoring Study (in the San Joaquin Valley) km: kilometer
m: meter

m 3 : cubic meter mb: millibars MCR: mid-course review MFB: mean fractional bias MFE: mean fractional error MM5: a mesoscale model MMPA: meteorological mode l performance analysis MOZART: Model for Ozone And Related Chemical Tracers MPO: metropolitan planning organization

## Acronyms & Terms

vi MVEB: motor vehicle emissions budget NAAQS: national ambient air quality standard NH 3 : ammonia NH 4 NO 3 : ammonium nitrate NO 2 : nitrogen dioxide NO x : oxides of nitrogen NSR: new source review NYQ: not yet quantified O 3 : ozone OC: organic carbon OH: hydroxyl radical OTAQ: EPA’s Office of Transportation and Air Quality PBL: planetary boundary layer PM: particulate matter PM 10 : particulate matter w ith a diameter of 10 μ m or less, includes PM 2.5 PM 2.5 : particulate matter w ith a diameter of 2.5 μ m or less PMC: coarse particulate matter PMF: positive matrix factorization RACM: reasonably available control measures RACT: reasonably available control technology RFP: reasonable further progress RMD: Receptor Modeling Documentation RMPA: Regional Modeling Performance Analysis RRF: relative response factor RTP: regional transportation plan SANDWICH: Sulfate, adjusted nitrate, derive d water, inferred carbonaceous material balance approach SC: South Coast SIP: state implementation plan SJV: San Joaquin Valley SJVAPCD/SJVUAPCD: San Joaquin Valley (U nified) Air Pollution Control District SMAT: Speciated Modeled Attainment Test SO 2 : sulfur dioxide SOA: secondary organic aerosol STN: Speciation Trends Network SO x : oxides of sulfur TCM: transportation control measures tpd: tons per day TIP: transportation improvement program TSD: technical support document VMT: vehicle miles traveled VOC: volatile organic compounds WOE: weight of evidenceEPA- Region 9 Page 1 

## Technical Support Document for the Revised Proposed Rulemaking Action on the San Joaquin Valley 2008 PM 2.5 

## Plan and San Joaquin Valley Portions of the Revised 2007 State Strategy

I. Introduction and Background

This document provides supporting information and analysis for EPA’s revised proposed rulemaking actions on the San Joaquin Va lley Air Pollution Control District’s 2008 PM 2.5 Plan (adopted April 30, 2008 and revised on June 17, 2010) and the related porti ons of the California Air Resources Board’s State Strategy for California ’s 2007 State Implementation Plan (adopted with amendments on September 27, 2007, revised and updated on April 24, 2009 and April 28, 2011). EPA initially proposed action on these plans on November 30, 2010 (75 FR 74518) and is now revising that proposal based on additional information provided by the State of California. This TSD identifies the Clean Air Act requirements for PM 2.5 plans and EPA’s regulations and policies interpreti ng these requirements. It also de scribes the elements of the SJV 2008 PM 2.5 Plan and 2007 State Strategy, as revised a nd supplemented, intended to address these requirements and EPA’s evaluation of whether the State’s submittals meet them. We also discuss how this revised proposal differs from our N ovember 30, 2010 proposed action and the rationale for these changes. This TSD updates the draft TSD prepared in support of the November 30, 2010 proposal. 1



### A. The National Ambient Air Quality Standards for Fine Particulate (PM 2.5 

### )

1. The PM 2.5 National Ambient Air Quality Standards

a. Level and Form of the Standard On July 18, 1997, EPA revised the primary a nd secondary national ambient air quality standards (NAAQS) for particulate matter (PM) to add new annual and 24-hour standards for PM 2.5 , particulate matter with a diameter of 2.5 microns or less. 62 FR 38652. 2 The annual

1 Air Division, U.S. EPA, Region 9, “Draft Technical Support Document for the Revised Proposed Action on the San Joaquin Valley 2008 PM 2.5 Plan and the San Joaquin Valley Portions of the Revised 2007 State Strategy,” November 8, 2010, referred to as the “2010 Draft TSD” in this document.

2 The original annual and daily standards for particulate matter generally less than or equal to 10 micrometers in diameter (referred to as PM 10 ) were established in 1987. 52 FR 24663 (July 1, 1987). In the 1997 PM NAAQS revision, EPA also revised the standards for PM 10 but these revised PM 10 standards were later vacated by the courts and the 1987 PM 10 standards remained in effect. In the 2006 NAAQS revision, the 24-hour PM 10 standards were retained but the annual standards were revoked. See 71 FR 61144 (October 17, 2006). The San Joaquin Valley is designated as attainment for the PM 10 NAAQS. See 73 FR 66759 (November 12, 2009).TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 2 standards are set at a level of 15 micrograms per cubic meter (μ/m 3 ), as determined by the 3-year average of annual mean PM 2.5 concentrations. The 24-hour sta ndards were set at a level of 65 μ/m 3 , as determined by the 3-year average of th e 98th percentile of 24-hour concentrations. 40 CFR § 50.7.

b. Health Effects EPA established primary air quality standards for PM 2.5 based on substa ntial evidence from numerous health studies demonstrating that serious health effect s are associated with exposures to elevated levels of the pollutant. Epidemiological studies ha ve shown statistically significant correlations between elevated PM 2.5 levels and premature mo rtality. Other important health effects associated with PM 2.5 exposure include aggrava tion of respiratory and cardiovascular disease (as indicated by increa sed hospital admissions, emergency room visits, absences from school or work, and restricted activity days), change s in lung function and increased respiratory symptoms, as well as ne w evidence for more subtle indicators of cardiovascular health. Individuals particularly sensitive to PM 2.5 exposure include older adults, people with heart and lung dis ease, and children. See, EPA, Air Quality Criteria for Particulate Matter , No. EPA/600/P–99/002aF and EPA/600/P–99/002bF, October 2004.

Attainment of the 1997 PM 2.5 standards is estimated to lead to reductions in health impacts, including tens of thousands fewer premat ure deaths each year, thousands fewer hospital admissions and emergency room visits each ye ar, hundreds of thousands fewer absences from work and school, and hundreds of thousands fewe r respiratory illnesses in children annually. See 72 FR 20586, 20587 (April 25, 2007).

c. Revisions to the 24-Hour PM 2.5 Standards In October 2006, EPA completed another review of the NAAQS for PM. With regard to the primary standards, the 24-hour PM 2.5 standards are strengthened to a level of 35 μ/m 3 , based on the 3-year average of the 98th percentile of 24-hour concentrations. The annual standards remain unchanged. 71 FR 61144 (October 17, 2006). Attainme nt of the 2006 PM 2.5 standards is estimated to lead to additional reductions in health impacts over th e 1997 standard, including approximately 1,200 to 13,000 fewer prematur e deaths each year, 1,630 fewer hospital admissions and 1,200 fewer emergency room visits for asthma each year, 350,000 fewer absences from work and school, and 155,300 fewe r respiratory illnesses in children annually. 72 FR 20586, 20587.

2. Implementing the PM 2.5 NAAQS

a. Designations The process for designating areas either atta ining or not attaini ng following promulgation of a new or revised NAAQS is found in CAA s ection 107(d). Under this section, each state governor or tribal leader has an opportunity to recommend air quality designations, including the appropriate boundaries for areas, to EPA. Under CAA section 107, state and tribal recommendations are due within one year of promulgation of a new or revised NAAQS, and EPA has up to 3 years after the promulgation of a new or revised NAAQS to designated areas forTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 3 that NAAQS. In the case of the 1997 PM 2.5 standards, however, Congress amended section 107 to extend the schedule for EPA to initiate the de signations process until th ree calendar years of air quality data, measured at Federal Refe rence Method monitors, were gathered. See section 6102(c)(1)(d) of the Transportation Equity Act fo r the 21st Century. EPA and state air quality agencies initiated the monitoring process for the PM 2.5 NAAQS in 1999 and deployed all air quality monitors by Janua ry 2001. As a result, the designation process for the 1997 PM 2.5 NAAQS did not begin until 2004. By no later than 120 days prior to promulga ting designations, EPA is required to notify states or tribes of any intended modifications to their boundaries that EPA deems necessary. States and tribes then have an opportunity to provide a demonstration as to why the proposed modifications suggested by EPA are inappropriate. CAA section 107(d(1)(B)(ii). Whether or not a state or tribe provides a reco mmendation, EPA must promulgate the designation that it deems appropriate. In April 2003, EPA requested that Califor nia submit its designation recommendations, based on ambient air quality data from 2001 to 2003, and supporting documentation by February 15, 2004. California submitted its re commendations on February 11, 2004. See Letter, Catherine Witherspoon, CARB, to Wayne Na stri, EPA-Region 9, February 11, 2004. On December 17, 2004, EPA issued final PM 2.5 designations for areas vi olating the 1997 standards, including the San Joaquin Valley air basin. They were published in the Federal Register on January 5, 2005 (70 FR 944) and became eff ective on April 5, 2005. The designations are codified at 40 CF R part 81, subpart C. 3
The designation of an area as nonattainment st arts the process whereby a state or tribe must develop an implementation plan that includes, among other things, a demonstration showing how it will attain the ambient standards by the attainment dates required in the CAA. Under section 172(b) for PM 2.5 , states have up to three years after final designations to submit their SIPs to EPA. The SIPs for the 1997 PM 2.5 SIP were due on April 5, 2008, three years after the effective date of the designations.

b. PM 2.5 Planning Requirements

In order to assist states in developing effective plans to address their PM 2.5 nonattainment problem, EPA issued the Clean Air Fine Partic ulate Implementation Rule, also known as the PM 2.5 implementation rule. 72 FR 20586 (April 25, 2007) , codified at 40 CFR part 51, subpart Z. We proposed this rule on November 1, 2005 at 70 FR 65984. We issued this rule in accordance with the statutory requirements of the CAA set forth in subpart 1 of Part D of Title 1, i.e.
, sections 171–179B.

The PM 2.5 implementation rule covers most CAA requirements for PM 2.5 state implementation plans. A list of these CAA requi rements, the corresponding provision in the PM 2.5 implementation rule and preamble are given in Table IA-1 below.

3 On November 13, 2009, EPA designated the SJ V, along with other areas in the Country, as nonattainment for the 2006 24-hour PM 2.5 standards. 74 FR 58688. California is now required to submit a plan demonstrating attainment of the 35 μg/m 3 24-hour standards by December 14, 2012. 74 FR 58688 , 58689. The 2008 PM 2.5 Plan we are reviewing in this TS D addresses only the 1997 24-hour PM 2.5 standards of 65 μg/m 3 and annual standards of 15 μg/m 3

.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 4 Table IA-1 

### CAA Requirements for PM 2.5 

### Attainment State Implementation Plans

CAA Section PM 2.5 Implementation Rule Description TSD Rule Preamble

172(a)(2)(A) § 51.1 004 20600-20602 Attainment date and attainment date extensions II.E.

172(b) § 51.1002(a) 20599-50600 SIP submittal date I.B.3.

172(c)(1) § 51.1010 20609-20633 Reasonably available control measures (including reasonably available control technology) II.D.

172(c)(1) § 51.1007(a) 20601-20602 Demonstration of expeditious attainment II.F.

172(c)(2) § 51.1009 20633-20640 Reasonable further progress II.H. 172(c)(3) § 51.1008 20647-20651 Emissions inventory II.A.

172(c)(6) § 51.1007(b) § 51.1010(b) 20601-20602 20658-20660 Enforceable limitation limits, other control measures, means or techniques and schedules and timetables for compliance as necessary for attainment II.D. & F.

172(c)(7) § 51.1002(b) 20600 CAA section 110(a)(2) requirements N/A

172(c)(9) § 51.1012 20642-20645 Contingency measures for failure to attain or make reasonable further
progress II.J.

302(g) § 51.1002(c) 20589-20597 PM 2.5 precursors to be evaluated for control II.C.

172(c)(1) § 51.1007(b) 20629 Timing of emissions reductions for attainment II.D. & F. 176(c) § 93.118(e)(4) 20645-20646 Motor vehicle emissions budgets I.D. 172(c)(2) & (6) § 51.1011 20640 Mid-course review II.I.

110(a)(2)(K) § 51.1007(a), § 51.112, and Appendix W 20605-20609 Air Quality Modeling II.F.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 5 In June 2007, a petition to the EPA Administ rator was filed on beha lf of several public health and environmental groups requesting r econsideration of four provisions in the PM 2.5 implementation rule. See Earthjustice, “Petition fo r Reconsideration in the Matter of the Final Clean Air Fine Particulate Implementa tion Rule, EPA Docket No. OAR-2003-0062,” June 25, 2007. These provisions are:

1. Presuming that compliance with the (now remanded) Clean Air Interstate Rule satisfies the NO x and SO 2 RACT requirements for electric ge nerating units (EGUs). 72 FR 20586 at 20623-20628. EPA granted the petition for this provision on April 25, 2011. Letter, Gina McCarthy, Assistant Administrator for Ai r and Radiation, EPA, to David Baron and Paul Cort, Earthjustice, April 25, 2011.

2. Allowing states to defer establishing emissions limits for condensable PM until January 1, 2011. 72 FR 20586 at 20652 (codifi ed at 40 CFR § 51.1002(c)). EPA denied the petition for this provision on April 25, 2011because the deferral period had already lapsed.

3. Revising the criteria for anal yzing the economic feasibility of RACT from a presumption that a given source must bear a cost similar to other sources to a consideration of whether the cost of a measure is reasonable for the regul ated entity to bear, in light of benefits. 72 FR 20586 at 20619-20620. EPA granted the pe tition for this provision on April 25, 2011.

4. Allowing states to use emissions reductions from outside of the nonattainment area to demonstration RFP. 72 FR 20586 at 20636. EPA gr anted the petition for this provision on May 13, 2010. Letter, Gina McCarthy, Assistan t Administrator for Air and Radiation, EPA, to David Baron and Paul Cort, Earthjustice, May 13, 2010.

The disputed provisions of the PM 2.5 implementation rule are, for the most part, not relevant to today’s proposal because California did not rely on them in developing the PM 2.5 plan for the San Joaquin Valley. We address each of thes e provisions later in this TSD: the first three in section II.D. (RACM/RACT) and th e fourth in section II.H. (RFP).



### B. PM 2.5 

### Air Quality in the San Joaquin Valley

The San Joaquin Valley PM 2.5 nonattainment area is located in the southern part of California’s Central Valley. It is home to almo st 4 million people and is the nation’s leading agricultural area. Stretching over 250 miles from north to south and averaging 80 miles wide, it is partially enclosed by the Co ast Mountain range to the west, the Tehachapi Mountains to the south, and the Sierra Nevada range to the east. In total, the SJV PM 2.5 nonattainment area encompasses over 23,000 square miles and includes all or part of eight counties: San Joaquin, Stanislaus, Merced, Madera, Fresno, Tulare, Kings, and the valley portion of Kern. See Figure IB-3. The local air district is the Sa n Joaquin Valley (Unified) Air Pollution Control District (SJVAPCD, SJVUA PCD, or District).TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 6 1. PM 2.5 Levels in the SJV

Annual and 24-hour PM 2.5 levels in the urban Bakersfiel d area in the southern SJV are the highest recorded in the United States at 21.2 μg/m 3 and 65 μg/m 3 for the 2008-2010 period. 4 Since comprehensive monitoring began for PM 2.5 in the SJV in the late 1990, the area has seen a significant decline in am bient levels, especially in the 2000-2005 time period. See Figures IB-1 and IB-2. Between 2005 and 2008, PM 2.5 concentrations increased at many monitoring sites in the Valley but began to decline again in th e 2008-2010 period. Figure IB-3 is a map of the current monitoring system in the SJV.



### Figure IB-1

Source: EPA’s Air Quality Systems Data base, June 2011. The level of 1997 annual PM 2.5 NAAQS is 15 μg/m 3

4 See EPA, Air Quality Subsystem, Design Value Report, June 1, 2011. These values are the highest design values in the SJV. A design value is an ambien t concentration calculated usin g a specific methodology from monitored air quality data and is used to compare an area’s air quality to a NAAQS. The methodologies for calculating design values for the annual and 24-hour PM 2.5 NAAQS are found in 40 CFR 50, Appendix N, Sections 1(c)(1) and 1( c)(2), respectively.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 7 

### Figure IB-2

Source: EPA’s Air Quality Systems Database, June 2011. The level of 1997 24-hour PM 2.5 NAAQS is 65 μg/m 3

.

2. Seasonality and Chemical Composition of PM 2.5 in the SJV

PM 2.5 in the air is a complex mixture of components. Common components include: nitrate (NO 3 ); sulfate (SO 4 ); ammonium; elemental carbon; a great variety of organic compounds; and inorganic material (including meta ls, dust, sea salt, and other trace elements) generally referred to as crustal material, alt hough it may contain material from other sources. Primary particles are emitted dire ctly into the air as a solid or liquid particle (e.g., elemental carbon from diesel engines or fi re activities, or condensable organic particles from gasoline engines). Secondary particles (e.g., nitrate and sulfate) form in the atmosphere as a result of chemical reactions between precursor pollutants such as NO x , SO 2 , VOC, and ammonia. Understanding the compounds that make up an area’s PM 2.5 problem is necessary in order to develop control strategies th at are effective for attain ing the NAAQS. 72 FR 20586 at 20589. In the SJV, the levels and nature of PM 2.5 in the ambient air vary by season. See Figures IB-4 to IB-7; see also SJV 2008 PM 2.5 Plan Progress Report, Figure A-7. Higher PM 2.5 concentrations occur during the winter, between late November and February, when ambient PM 2.5 is dominated by ammonium nitrate, formed from NO x and ammonia emissions, and directly-emitted particulates, such as wood smoke. During th e winter, the SJV experiencesTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 8 extended periods of stagnant w eather with cold, da mp, foggy conditions; conditions that are conducive to the formation of secondary ammoni um nitrate particulates and encourage wood burning. During the summer, PM 2.5 levels generally remain below 15 μg/m 3 , the level of the annual standards



### Figure IB-3 – Ambient Monitoring Locations In the San Joaquin Valley

Source: SJVAPCD, Annual Report to the Community, 2010 , p. 35.

.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 9 

### Figures IB-4

Source: 2008 PM 2.5 Plan, Appendix H, Figure H-5.



### Figure IB-5

Source: 2008 PM 2.5 Plan, Appendix H, Figure H-4.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 10 

### Figure IB-7

Source: 2008 PM 2.5 Plan, Appendix H, Figure H-6

.



### Figure IB-8

Source: 2008 PM 2.5 Plan, Appendix H, Figure H-7.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 11 

### C. California’s Submittals Constituting the SJV PM 2.5 

### State Implementation Plan

Five submittals or parts of submittals comprise the SJV PM 2.5 attainment state implementation plan. We will refer to these five submittals or parts of submittals collectively as the SJV PM 2.5 [attainment] SIP:

1. 2008 PM 2.5 Plan, adopted on April 30, 2008 by the SJVUAPCD and on May 22, 2008 by CARB, submitted with the adopting resoluti ons and other supporting documentation by CARB on June 30, 2008. See San Joaquin Valley Unified Air Pollution Control District Governing Board Resolution: In the Matter of Adopting the San Jo aquin Valley Unified Air Pollution Control District 2008 PM 2.5 Plan, April 30, 2008; CARB Resolution No. 08-28, May 22, 2008; and letter, James N. Goldstene, Executive Officer, CARB to Wayne Nastri, Regional Admini strator, EPA Region 9, June 30, 2008 with enclosures. This document will be referenced in this TSD and the Federal Register proposal as the 2008 PM 2.5 Plan, the SJV 2008 PM 2.5 Plan, or simply the Plan.

2. Proposed State Strategy for Califo rnia’s 2007 State Implementation Plan , as amended and adopted on September 27, 2007 by CARB, submitted with the adopting resolution and other supporting documentation by CARB on November 16, 2007. See CARB Resolution No. 07-28, September 27, 2007 and letter, James N. Goldstene, Executive Officer, CARB, to Wayne Nastri, Regi onal Administrator, EPA Region 9, November 16, 2007, with enclosures. This docum ent will be referenced in this TSD and the Federal Register proposal as the 2007 State Strategy.

3. Status Report on the State Strategy for California’s 2007 State Implementation Plan (SIP) and Proposed Revisions to the SIP Re flecting Implementation of the 2007 State Strategy , adopted on April 24, 2009 by CARB, submitted with the adopting resolution and other supporting documenta tion by CARB on August 12, 2009. 5 See CARB Resolution No. 09-34, April 24, 2009 and letter, James N. Goldstene, Executive Officer, CARB, to Laura Yoshii, Acting Regional Ad ministrator, EPA Region 9, August 12, 2009 with enclosures. This document will be referenced in this TSD and the Federal Register proposal as the 2009 State Strategy Status Report.

4. 2008 PM 2.5 Plan Amendment to Extend th e Rule 4905 Amendment Schedule , adopted on June 17, 2010 by the SJVUAPCD, submitted with adopting resolution and other supporting documentation by CARB on Se ptember 15, 2010. See SJVUAPCD Governing Board Resolution No. 10-06-18, June 17, 2010 and letter, James N. Goldstene, Executive Officer, CARB to Jared Blumenfeld, Re gional Administrator, EPA Region 9, September 15, 2010, with enclosures.

5. Progress Report on Implementation of PM 2.5 State Implementation Plans (SIP) for the South Coast and San Joaquin Valley Air Ba sins and Proposed SIP Revisions , adopted on April 28, 2011 by CARB, submitted with the adopting resolution and other supporting

5 Only pages 11-27 of the 2009 State Strategy Status Report are submitted as a SIP revision. The balance of the report is for informational purposes only. See Attachment A to the CARB Resolution, No. 09-34.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 12 documentation by CARB on May 18, 2011. 6 See CARB Resolution No. 11-24, April 28, 2009 and letter, James N. Goldst ene, Executive Officer, CARB, to Jared Blumenfeld, Regional Administrator, EPA Re gion 9, May 18, 2011 with enclosures. This document will be referenced in this TSD and the Federal Register proposal as the 2011 Progress Report.

Future references in this TSD and the Federal Register notice to the 2007 State Strategy and the 2008 PM 2.5 Plan will be to the Strategy as re vised in 2009 and 2011 and the Plan as revised in 2010 and 2011, respectively, unl ess explicitly stated otherwise. In addition to these plan submittals, the Dist rict and CARB have provided information on the implementation status of the SJV 2008 PM 2.5 SIP’s control strategy. CARB also provided supplemental documentation of the air quality mode ling and further analysis of the effectiveness of VOC controls for reducing PM 2.5 levels in the Valley as well as further information supporting the 2011 Progress Report. This additional information is

1. Letter, John DaMassa, Chief Modeling a nd Meteorology Branch, CARB to Frances Wicher, Office of Air Planning, EPA Region 9, January 28, 2011 providing supplemental air quality modeling documentati on (CARB modeling supplement).

2. Letter, James N. Goldstene, Executive Officer, CARB, to Frances Wicher, Office of Air Planning, EPA Region 9, January 28, 2011, A ttachment 4, “Air Resources Board comments on U.S. EPA’s November 30, 2010 proposal that VOC be considered a significant PM 2.5 Precursor for the San Joaquin Valley 2008 PM 2.5 State Implementation Plan (SIP).” (CARB VOC supplement)

3. SJVAPCD, 2008 PM 2.5 Plan Progress Report , Draft March 2011 (SJV PM 2.5 Progress Report).

4. Letter, Lynn Terry, Deputy Executive Offi ce, CARB, to Elizabeth Adams, Deputy Director, Air Division, EPA–Region 9, May 18, 2011. (CARB Progress Report supplement).

Finally, both CARB and the Di strict have adopted and s ubmitted numerous rules that reduce emissions in the San Joaquin Valley a nd contribute to progr ess in meeting the PM 2.5 NAAQS in the area. See Appendi ces A and B of this TSD.

6 Only Appendices B, C and D of the 2011 Progress Re port are submitted as a SIP revision. The balance of the report is for informational purposes only. See May 18, 2011 Goldstene Letter.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 13 

### D. Public Notice and Hearing Requirem ents for and Completeness of SIP Submittals

1. Public Notice and Hearing Requirements for SIP Submittals CAA sections 110(a) and (l) require a state to provide reasonable public notice and hearing prior to the adoption and submittal of a SIP or SIP revision. To meet this requirement, every SIP submittal should include evidence that adequate public notice was given and a public hearing was held consistent with EPA’s implementing regulati ons in 40 CFR § 51.102.

Both the District and CARB have satisf ied applicable statutory and regulatory requirements for reasonable public notice and hear ing prior to adoption and submittal of the 2008 PM 2.5 Plan. The District conducte d public workshops, provided public comment periods, and held a public hearing prior to the adopti on of the Plan on April 30, 2008. See SJVUAPCD Governing Board Resolution, page 3. CARB al so provide the require d public notice and opportunity for public comment prior to its May 22, 2008 public hearing on the Plan. See CARB, Notice of Public Meeting to Consid er the Approval of the SJV 2008 PM 2.5 SIP, April 25, 2008. The District also provided the required public notice and hearing on the 2010 revision to the Plan. See SJVUAPCD Governing Board Resolution No. 10-06-18, June 17, 2010. CARB conducted public workshops, provided pub lic comment periods, and held a public hearing prior to its adoption of the 2007 State Strategy on September 27, 2007. See CARB, Notice of Public Meeting to Consider Approval of the Proposed State Strategy for California’s State Implementation Plan (SIP) fo r the Federal 8-Hour Ozone and PM 2.5 Standards, May 7, 2007 and CARB Resolution No. 07-28, September 27, 2007. CARB provide the required public notice, opportunity for public comment, and public hearing prior to its April 24, 2009 adoption of re visions to the Strate gy. See CARB, Notice of Public Hearing to Consider a Status Report on the State Strategy for California’s 2007 State Implementation Plan and Consider Approval of a Proposed Revision to th e State Implementation Plan Reflecting Implementation of the 2007 State Strategy, March 24, 2009 and CARB Resolution No. 09-34, April 24, 2009. CARB provide the required public notice, opportunity for public comment, and public hearing prior to its April 28, 2011 adoption of the 2011 Progress Report. See CARB, Notice of Public Hearing to Consider the Approval of a Progress Report and Proposed State Implementation Plan Revisions for PM 2.5 , March 29, 2011 and CARB Resolution No. 11-24, April 28, 2011.

2. Completeness Determinations on SIP Submittals CAA section 110(k)(1)(B) requires EPA to determine whether a SIP submittal is complete within 60 days of receipt. This section also provides that any plan that we have not affirmatively determined to be complete or in complete will become co mplete by operation of law six months after the day of submittal. A completeness review a llows us to determine if the submittal includes all the necessary items and information we need to act on it. We make completeness determinations us ing criteria we have established in 40 CFR part 51, Appendix V. These criteria fall in to two categories: administrative information and technical support information. The administ rative information provides documentation thatTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 14 the state has followed basic administrative pro cedures during the SIP-adoption process and thus we have a legally-adopted SIP revision in front of us. The technical suppo rt information provides us the information we need to determine the im pact of the proposed revision on attainment and maintenance of the air quality standards. We notify a state of our completeness determination by letter unless the submittal became complete by operation of law. A finding of comple teness does not approve the submittal as part of the SIP nor does it indicate that the submittal is approvable. It does start the 12-month clock we have to act on the SIP submittal. See CAA section 110(k)(2). The June 30, 2008 submittal of the 2008 PM 2.5 Plan went complete by operation of law on December 30, 2008. We found the 2010 revision to the Plan complete on September 23, 2010. See letter, Deborah Jordan, EPA Region 9 to James Goldstene, CARB, September 23, 2010. The November 16, 2007 submittal of the 2007 State Strategy and the August 12, 2009 submittal of the 2009 revisions to the Strategy went comp lete by operation of law on May 16, 2008 and February 12, 2010, respectively. We found the May 18, 2011 submittal complete on June 13, 2011. See letter, Deborah Jordan, EPA Region 9 to James Goldstene, CARB, June 13, 2011.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 15 

## II. Evaluation of the Sa n Joaquin Valley 2008 PM 2.5 

## SIPTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 16 

### A. Emissions Inventories

1. Requirements for Emissions Inventories CAA section 172(c)(3) requires a state to submit a plan provision that includes a “comprehensive, accurate, current inventory of actual emissions fr om all sources of the relevant pollutant.” Pursuant to this section, the PM 2.5 implementation rule requires a state to submit, within three years of th e designation of one of its areas as nonattainment, st atewide emissions inventories of direct PM 2.5 and PM 2.5 precursors. These inventor ies should meet the data requirements of EPA’s Consolidated Emissi ons Reporting Rule (CERR, codified at 40 CFR part 51 subpart A). 40 CFR § 51.1008(a)(1). 7 Direct PM 2.5 includes condensable PM. 40 CFR § 51.1000. PM 2.5 precursors are NO X , SO 2 , VOC, and ammonia. Id. The state must report inventories for each, even if it has determined that control of any of these precursors is not necessary for attainment. Id. and 72 FR 20586 at 20648.

The PM 2.5 implementation rule also requires a state to submit a baseline emissions inventory as part of the attainment and RFP demonstrations in its PM 2.5 attainment plan. The base year for this inventory s hould be calendar year 2002 or other suitable year for areas initially designated nonattainment for the PM 2.5 in 2004-2005. 40 CFR § 51.1008(b). The baseline inventory should be appropriate for th e geographical area addressed by the PM 2.5 attainment plan and consistent with applicable EPA guidance. 72 FR 20586 at 20648. A state is also required to submit any additional emissions inventory informa tion needed to support its attainment and RFP demonstrations. 72 FR 20586 at 20648 and 40 CFR § 51.1008(a)(2). EPA has issued the “Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Qu ality Standards (NAAQ S) and Regional Haze Regulations,” EPA–454/R–05–001, November 2005 (available at www.epa.gov/ttn/ chief/eidocs/eiguid/index.html). EPA developed this guidance document to complement the CERR and to provide specific guidance on how to develop emissions i nventories for 8-hour ozone, PM 2.5 , and regional haze SIPs. The emissions inventories required under the PM 2.5 implementation rule (as opposed to the CERR) are SIP provisions that must be a pproved by EPA under CAA section 110(k) and are subject to public hearing requi rements pursuant to sections 11 0(a)(2) and (l). A state should include in its SIP submittal documentation explaini ng how the emissions data were calculated. In estimating mobile source emissions, a state should use the latest emissions models and planning assumptions available at the time the SIP is developed. 72 FR 20586 at 20647. For California, the latest emissions model means the then most recently EPA approved version of EMFAC. Currently this is EMFAC2007. S ee 73 FR 3464 (January 18, 2008).

7 In late 2008, EPA promulgated the Air Emissions Reporting Rule (AERR) at 73 FR 76539 (December 17, 2008). The AERR updated the CERR reporting requirements by consolid ating and harmonizing new emissions reporting requirements with pre-existing sets of reporting requirements under the NO X SIP Call (which does not apply to California). Because this AERR was not finalized until after th e submittal of the SJV PM 2.5 Plan, its data requirements, in that they differ from the CERR requirements, do not apply to the Plan.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 17 2. Emissions Inventories in the SJV PM 2.5 SIP

Note : We discuss CARB’s statewide inventory to provide background to our evaluation of the emissions inventories in the SJV 2008 PM 2.5 Plan. We are not propos ing any SIP action on the statewide inventory here, only on the SJV inventor ies. EPA will address the statewide inventory in a separate rulemaking.

CARB submitted statewide inventories for direct PM 2.5 and PM 2.5 precursors (except for ammonia) as part of the 2007 State Strategy. S ee Appendix A for the emissions inventory output tables and Appendix F for documentation of the emissions inventory. In ventories are provided for the Strategy’s base year of 2002 and baseline years of 2005, 2006, 2008, 2009, 2010, 2011, 2012, 2013, 2014, 2015, 2017, 2018, 2020, and 2023. 8 These statewide emissions inventories are assembled and maintained by CARB in the Cali fornia Emissions Inventory Development and Reporting System (CEIDARS) and the California Emission Forecasting and Planning Inventory System (CEFS) databases. Both sy stems are described in Appendix F. The inventories in Appendix A are summer season planni ng inventories on which the 2007 State Strategy is based. Baseline inventories incorporate reductions from control measures adopted prior to December 2006. 2008 PM 2.5 Plan, p. B-1 and 2007 State Strategy, Appendix A, p. 1. Specific adjustments for State and District rules adopted in the 2004 to 2006 time period, as well as adjustments to among other things, heavy duty truck VMT in 2005 and pesticide emissions, are described in the introductory section to Appendi x A and can also be found in Appendix B to the December 2007 draft of the SJV 2008 PM 2.5 Plan. The planning invent ories for direct PM 2.5 and all PM 2.5 precursors (including ammonia) for the SJV PM 2.5 nonattainment area together with add itional documentation for the inventories are found in Appendix B of the SJV 2008 PM 2.5 Plan. Both average winter day and average annual day inventories are provide d for the year 2005 (the base ye ar for the attainment and RFP demonstrations) and each year from 2009 to 2014. A winter inventory is provided because the majority of high PM 2.5 days in the SJV occur during the winter months between November and February. 2008 PM 2.5 Plan, Figures H-4 and H-5. Th e inventories use EMFAC2007 for estimating on-road motor vehicle emissions. 2008 PM 2.5 Plan, p. B-1. These inventories provide the basis for the control measure analysis and the RFP and attainment demonstrations. As a starting point for the 2008 PM 2.5 Plan’s inventories, the District used CARB’s 2002 inventory. 2008 PM 2.5 Plan, p. B-1. The 2002 inventory was projected to 2005 and future years using CEFSv 1.06. 2008 PM 2.5 Plan, p. B-1. All inventories include emissions from point , area, on-road, and non-road sources. None specifically show emissions from non-anthropog enic sources (that is, natural sources) although inventories developed for input into the ai r quality modeling do include such sources. 2008 PM 2.5 Plan, p. G-3. A summary of the planning inve ntories for the Plan’s base year of 2005 and baseline years of, 2009, 2012 and 2014 is provided in Table A-1 below.

8 The 2007 State Strategy addresses both 8-hour ozone standard and the PM 2.5 standards; therefore, baseline inventories are given not only for years of importance for PM 2.5 plans but also ones of importance for 8- hour ozone plans.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 18 3. November 2010 Proposed Ac tion on Emissions Inventory In our November 2010 proposed action on the SJV 2008 PM 2.5 SIP, we proposed to find that the 2002 emissions inventory in the 2007 State Strategy and the 2008 PM 2.5 Plan met the CAA section 172(c)(3) requirement for the State to submit a plan provis ion that includes a comprehensive, accurate, current, inventory of actua l emissions from all sources of the relevant pollutant. We also proposed to find that the baseline inventories in the SJV 2008 PM 2.5 Plan provided an adequate basis for the reasonably available control measure, reasonable further progress and attainment demonstrations in th e Plan. See 2010 Draft TSD, section II.A. and 75 FR 74518 at 74522.

4. Evaluation and Conclusions

The emissions inventories were made availa ble to the public for comment at the same time as the draft 2007 State Strategy and 2008 PM 2.5 Plan and were subject to public hearing as part of final version of th e Strategy and Plan. See CARB Resolution No. 07-28, p. 3 and SJVUAPCD Governing Board Resolution, p. 3.

The SJV PM 2.5 SIP uses a 2005 base year inventory. When considered together with the inventory documentation in Appendix F of the St ate Strategy and the inventory documentation in Appendix B and air quality modeling documentation in Appendices E-G of the Plan, it contains all the elements required by EPA’ s emissions inventory guidance.

The inventories in the SJV PM 2.5 SIP are based on the most current and accurate information available to the State and District at the time the Plan was developed and submitted (including using the latest EPA-a pproved version of California’s m obile source emissions model, EMFAC2007), address comprehensively all s ource categories in the SJV, and meet the applicable requirements of EPA’ s inventory guidance. For thes e reasons, EPA is proposing to approve the 2005 base year emi ssions inventory in the SJV PM 2.5 SIP as meeting the requirements of CAA section 172(c)(3) and 40 CFR § 51.1008(a)(1). We also propose to find that the baseline inventories in the SJV PM 2.5 SIP provide an adequate basis for the reasonably available control measure, reasonable furt her progress and attainment demonstrations.

Post-Submittal Revisions to the Plan’s Ba se Year and Projected Baseline Inventories From late 2007 until mid-2009, California experienced an economic recession that greatly reduced and continues to affect the level of activity in the State’s construction and goods movement sectors. 2011 Progress Report, Append ix E. As a result, current and projected emission levels from these categories are now su bstantially lower than were projected in 2008 SJV PM 2.5 Plan. At this time, California is refl ecting these recession impacts as a line-item adjustments to the baseline inventories.

These recession-caused decreases in emissions do not affect either the Plan’s modeling year (2000) or base year (2005) inventories and thus do not change the carrying capacity estimates in the Plan (that is, th ey do not affect the ta rget level of overall emissions needed to demonstrate attainment) or the starting point fo r the reasonable further progress demonstration. Their principal effect is to re duce the reductions needed from the Plan’s control strategy to demonstrate RFP and attainment.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 19 CARB also made technical changes to the invent ory for diesel trucks and buses as part of its December 2010 rulemaking amending its In-U se On-Road Truck and Bus Rule. These included updates and revisions to:

• regional allocation factors

• out-of-state vehicle miles traveled estimates

• new vehicle inventory categories

• lifetime mileage assumptions
See CARB, Staff Report: Initial St ate of Reasons for Proposed Rulemaking, ProposedAmendments to the Truck and Bus Regulations, The Drayage Truck Regulation and the TractorTrailer Greenhouse Gas Regulation , October 2010, p. 17. CARB also comprehensively updated and revise d the inventory for off-road equipment as part its December 2010 rulemaking amending th e In-Use Off-Road Equipment Rule. These included updates and revisions to:

• equipment population

• hours of use

• load factors

• future equipment sales and activity

See CARB, Staff Report: Initial St ate of Reasons for Proposed Rulemaking, Proposed Amendments to the Regulation for In-Use Off-Road Diesel-F ueled Fleets and the Off-Road Large Spark-Ignition Fleet Requirements, October 2010, pp. 16-17.

CARB estimates that these technical revisions reduce the total 2005 base year NO x and PM 2.5 inventory by approximately 6 percent of the NO x and 5 percent, respectively. CARB Progress Report supplement, Attachment 1. These change are too small to affect the overall accuracy of the inventory given the normal and unavoidable uncertainties in emissions inventories. We have also considered the potential effect s of the revisions to the truck, bus, and offroad equipment emissions invent ory categories on the approvabil ity of the attainment and RFP demonstrations in the Plan and concluded they do not adversely affect th em. See sections II.B.5. and II.H. of this TSD. We note that the State an d District are currently working on a revisions to the SJV PM 2.5 SIP to address the 2006 24-hour PM 2.5 standard. These revisions are due to EPA in December 2012 and will include the latest updates to the emissions inventories.TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 20Table A-1Emissions Inventory Summaryfor the San Joaquin Valley PM2.5Nonattainment Area(tons per day)Annual Average Day Winter Average Day2005 2009 2012 2014 2005 2009 2012 2014Direct PM2.5Stationary Sources 13.3 13.8 14.2 14.4 12.8 13.3 13.7 14.0Area Sources 51.5 46.8 45.8 45.2 54.6 51.2 49.2 47.9On-Road Mobile Sources 12.1 11.3 9.9 8.9 12.2 11.4 10.0 9.0Off-Road Mobile Sources 9.0 7.9 7.2 6.6 8.1 7.0 6.3 5.7Total 86.0 79.8 77.0 75.0 87.6 82.9 79.1 76.6Nitrogen OxidesStationary Sources 80.1 62.7 58.7 56.5 71.9 58.5 56.2 55.0Area Sources 13.5 11.0 10.8 10.7 18.2 16.3 15.9 15.7On-Road Mobile Sources 327.9 297.4 243.8 206.7 342.1 311.5 255.1 216.0Off-Road Mobile Sources 153.9 129.7 111.1 102.2 141.0 118.4 101.2 93.4Total 575.4 500.9 424.4 376.2 573.1 504.7 428.4 380.1Sulfur DioxideStationary Sources 20.4 20.6 21.5 22.0 19.6 20.0 20.9 21.4Area Sources 0.9 0.9 0.9 0.9 0.8 0.8 0.8 0.8On-Road Mobile Sources 2.6 0.7 0.7 0.7 2.5 0.7 0.7 0.7Off-Road Mobile Sources 2.4 0.8 0.8 0.8 2.3 08 0.8 0.8TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 21Table A-1Emissions Inventory Summaryfor the San Joaquin Valley PM2.5Nonattainment Area(tons per day)Annual Average Day Winter Average Day2005 2009 2012 2014 2005 2009 2012 2014Total 26.4 23.0 23.8 24.5 25.2 22.3 23.1 23.7Volatile Organic CompoundsStationary Sources 121.5 121.9 123.9 129.5 101.4 102.0 103.4 107.1Area Sources 140.7 122.4 125.5 128.0 145.4 127.1 129.6 131.7On-Road Mobile Sources 94.8 76.5 64.8 57.2 99.7 80.9 68.1 59.9Off-Road Mobile Sources 62.7 54.3 50.8 48.5 55.7 48.6 45.8 43.9Total 419.8 375.2 365.0 363.2 402.2 358.6 346.9 342.6AmmoniaStationary Sources 19.8 21.0 22.2 23.0 19.8 21.0 22.2 23.0Area Sources 355.9 381.9 405.8 423.1 356.9 382.9 406.7 424.0On-Road Mobile Sources 6.2 5.3 5.0 4.8 6.2 5.3 5.0 4.8Off-Road Mobile Sources 0 0 0 0 0 0 0 0Total 382.0 408.3 433.0 451.0 382.9 409.2 433.9 451.8Source: SJV 2008 PM2.5Plan, Appendix B, Tables B-1 to B-5.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 22 

### B. Air Quality Modeling

1. Requirements for Air Quality Modeling

The PM 2.5 implementation rule requires states to submit an attainment demonstration based on modeling results. Specifi cally, 40 CFR § 51.1007(a) states:

For any area designated as nonattainment for the PM 2.5 NAAQS, the State must submit an attainment demonstration show ing that the area will attain the annual and 24-hour standards as e xpeditiously as practicable . The demonstration must meet the requirements of § 51.112 and Appendix W of this part and must include inventory data, modeling results, and em issions reduction analyses on which the State has based its projected attainment da te. The attainment date justified by the demonstration must be consistent with the requirements of § 51.1004(a). The modeled strategies must be consiste nt with requirements in § 51.1009 for RFP and in § 51.1010 for RACT and RACM. The attainment demonstration and supporting air quality modeling should be consistent with EPA’s PM 2.5 modeling guidance. 9

See also 72 FR 20586 at 20665. Air quality modeling is used to establish emission attainment targets, a combination of emissions of PM 2.5 and PM 2.5 precursors that the area can accom modate without exceeding the NAAQS, and to assess whether the proposed contro l strategy will result in attainment of the standards. Air quality modeling is performed for a base year and compared to air quality monitoring data in order to determine model pe rformance. Once the performance is determined to be acceptable, future year emissions inve ntory changes are simulated to determine the relationship between emissions reductions and ch anges in ambient air quality throughout the air basin. The procedures for modeling PM 2.5 as part of an attainment SIP are contained in EPA's “Guidance on the Use of Models and Other An alyses for Demonstrating Attainment of Air Quality Goals for the 8-Hour Ozone and PM 2.5 NAAQS and Regional Haze.”

2. Air Quality Modeling in the SJV 2008 PM 2.5 Plan

The 2008 PM 2.5 Plan uses multiple modeling analyses to demonstrate attainment of the PM 2.5 NAAQS in the SJV. It mainly relies on severa l variants of an approach based on receptor modeling for the annual PM 2.5 NAAQS. This approach begins with Chemical Mass Balance (CMB) modeling, which distinguishes the ambient PM 2.5 contributions of several broad emissions source categories based on how they match the chemical species components of PM 2.5 measurements. The CMB results are then refined with emissions inventory data to distinguish additional source categories, an ar ea of influence analysis to be tter reflect particular sources affecting a monitor, and information from past photochemical modeling to assess how secondarily formed PM 2.5 will respond to changes in precursor emissions. Several variants of this

9 EPA’s November 9, 2005 final rule revising the “G uideline on Air Quality Models” in 40 CFR part 51, Appendix W is available at www.epa.gov /ttn/scram/guidance/guide/appw_05.pdf.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 23 approach are used, with CMB results from differen t locations and different base case years. This modeling only addr esses the annual PM 2.5 standard.

The Plan also includes an attainment dem onstration using photochemical modeling with the Community Multiscale Air Quality (CMAQ) model. This modeling incorporates data collected during 2000 Californi a Regional Particulate Air Quality Study (CRPAQS) and addresses both the annual and 24-hour PM 2.5 standards. It is consid ered the main attainment demonstration, with the receptor mo deling as a corroborating analysis. 10

Based on verb tenses and on the structure of the Plan and appendices, it appears that the receptor modeling was completed first and was later supplemented with the photochemical modeling. Both the receptor and photochemi cal modeling focused primarily on the annual standard. The annual standard was viewed as cont rolling in the sense th at any control strategy that provided for annual standard attainment would also provid e sufficient emissions reductions for 24-hour standard attainment. At the time the Plan was prepared in 2006, ambient data for PM 2.5 was consistent with attainment of the 24-hour NAAQS. See 2008 PM 2.5 Plan, Appendix A, Table A-9.

The 2008 PM 2.5 Plan discusses air quality modeling in the “Executive Summary,” Chapter 3 “What is Needed to Demonstrate Atta inment?,” Appendix E “District Additions to the Conceptual Model,” Appendix F “SJV PM 2.5 SIP Modeling Protocol,” Appendix G “Regional Air Quality Modeling,” Appendix H “Weight of Evidence,” and the additional appendices “2014 Receptor Modeling Documentation,” “Meteorol ogical Model Performance Analysis,” and “Regional Model Performance Analysis.” CARB provided additional modeling documentation in “Three-Dimensional Grid-Based Photochemical Modeling-Related Responses to the US EPA’s Technical Support Document for the Proposed Action on the San Joaquin Valley 2008 PM 2.5 Plan and the San Joaquin Valley Portions of the Revised 2007 State Strategy”, California Air Resources Board, January 28, 2011, including Appendices A through D (hereafter, CARB modeling supplement). A conceptual model of PM 2.5 formation in the San Joaquin Valley is in Appendices E and F, with additional material in Appendix H. The principal discussion of the photochemical modeling is in Appendices F and G, along with the two model performance appendices. Receptor modeling is covered in Chapter 3, Appendix F, and the Receptor Modeling Documentation appendix. The Weight of Evidence analysis in Appendix H discusses both the photochemical and receptor modeling, as well as ambient trends and other data in support of the attainment demonstration. Consistent with the Guidance, EPA consider s the photochemical modeling to be the main basis for the PM 2.5 attainment demonstration. Guidance, p. 15. The receptor modeling may be considered supplemental analysis to corroborate the photochemical modeling results, e.g. as part of a weight of evidence approach. Guidance, p. 213.

10 Memorandum . Scott Bohning, EPA Region 9, Air Quality Analysis Office to Docket No. EPA-R09- OAR-2010-0516, June 17, 2011, re: Notes on call w/ ARB re: VOC as a PM 2.5 plan precursor in SJV, found in the docket for this proposal.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 24 a. Conceptual Description A conceptual description is a qualitative way of characterizing the nature of an area’s nonattainment problem. It can be helpful in iden tifying potential stakehol ders and for developing a modeling protocol. It can also influence the choice of air qualit y model, modeling domain, grid cell size, priorities for quality assuring and refi ning emissions estimates, and the choice of initial diagnostic tests to identify poten tially effective control strategi es. In general, a conceptual description is useful for helping a state to identify priorities an d allocate resources in performing a modeled attainment demonstration. The Guidance at pp. 128-130 lists 13 elements th at should be addresse d in the conceptual description. These are:

1. nonattainment problem (e.g., local versus regional)

2. relative importance of primary and secondary components of PM 2.5 3. most prevalent components of measured PM 2.5 4. components of measurements versus emissions

5. areas with large gradients

6. indications of limiting precursor for secondary formation

7. monitored violations at locations subject to mesoscale wind patterns (e.g., at a coastline) differing from the general wind flow

8. recent changes in PM emissions in or near the nonattainment area

9. trends in design values or other air quality indicato rs that have accompanied emissions changes

10. spatial pattern to trends in design va lues or other air quality indicators

11. past modeling results

12. distinctive meteorological measurem ents coinciding with exceedances

13. correlations of PM or components w ith each other and other pollutants

The Plan contains ampl e discussion of the PM 2.5 problem in the San Joaquin Valley. Much of the same material is covered in Chap ter 3 (pp. 3-3 – 3-9); most of Appendix E; the modeling protocol in Appendix F at pp. F-13 – F-18, F-21, F-52 – F-56; and various parts of Appendix H. Appendix E on “District Additions to the Conceptual Model” has substantial discussion of the effect on PM 2.5 concentrations of seasonal changes, the influence of meteorology including fog, dry deposition, and emissi ons variations. Analysis of data collected during the 2000 CRPAQS substantially added to the understanding of PM 2.5 in the SJV. The cited chapters and appendices excerpt a numbe r of conclusions from papers stemming from CRPAQS. 11

11 Appendix F at p. F-71 also includes by reference the paper “Conceptual Model of Particulate Matter Pollution in the California San Joaquin Valley,” Document Number CP045-1-98, 8 September 1998, prepared by: Betty Pun and Christian Seigneur, Atmospheric and Environmental Research, Inc. This paper has conclusionsTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 25 In brief, the PM 2.5 problem in the San Joaquin Valley is mainly due to secondary particulates, especially in wint er, with a substantial primary component throughout the year and during some winter episodes. PM 2.5 concentrations are much highe r in winter than in summer. Concentrations in April through Septem ber are generally less than 15 μg/m 3 , the level of the annual NAAQS. Nonattainment of the annual NAAQS is driven by high wintertime concentrations, including epis odes during stagnant, moist conditions. Stagnant conditions and surface radiation inversions restri ct pollutant dispersion, allowing c oncentrations to build to high levels. The enclosure of the SJV by mountain range s restricts air flow an d helps the inversion form a cap over the polluted air. Concentrations are highest at the southern end of the Valley, which is more enclosed than the northern e nd and experiences stagna tion during winter and recirculation of polluted air vi a the Fresno eddy during summer. The dominant component of PM 2.5 in the SJV is ammonium nitrate, formed from the abundant ammonia emissions in this agricultural area and NO x emissions from on-road motor vehicles, other mobile sources, and various fuel-combustion stationary sources. Ammonium nitrate formation is enhanced during the cool, moist winter months. Based on ambient concentrations and on previous modeling wor k, ammonia appears to be so abundant that formation of ammonium nitrate is limited by the rate of HNO 3 (nitric acid) formation via oxidation of NO x , rather by the availability of ammonia. In additi on to ammonium nitrate, organic carbon (OC) can also be a significant component of PM 2.5 . The main sources of OC are agricultural vegetative burning, residential wood combustion, othe r direct sources such as vehicles, and a smaller contribution from s econdary organic aerosols. During CRPAQS it was found that organic carbon has a strong spatial gradient, being much hi gher in urban areas, especially during high PM 2.5 episodes. This gradient was explai ned as being due to the greater vehicle emissions and residential wood combustion in cities. Ammonium sulfate is a relatively small component of secondary PM 2.5 in the SJV unlike areas in the eastern part of the United States where it is the domina nt component of secondary PM 2.5
. As discussed at 2008 PM 2.5 Plan pages 3-32 and F-39, the annual standard is the focus of the modeling analysis because ambient concentrations of PM 2.5 in the SJV were below the 24- hour PM 2.5 NAAQS during the development of the Pl an. There were thus no 24-hour episodes suitable for speciated rollback in the receptor mo deling approaches and little need to focus on the 24-hour standard for the photochemical mode ling, although 24-hour mode ling was performed. EPA believes that the concep tual description of the PM 2.5 problem in SJV provided in the Plan is adequately documented, convincing, and formed an adequate basis for the development of the modeling protocol and the analysis work.

b. Modeling Protocol A modeling protocol should detail and forma lize the procedures for conducting all phases of the modeling study, such as describing the b ackground and objectives for the study, creating a schedule and organizational stru cture for the study, developing the input data, conducting model performance evaluations, interpreting modeling results, describing pro cedures for using the model to demonstrate whether proposed strategi es are sufficient to attain the NAAQS, and

similar to those covered in the Plan sections listed above, a lthough it is based on analysis of data collected during an earlier study, the 1995 Integrated Monitoring Study (or IMS95).TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 26 producing documentation to be submitted for EPA Regional Office review and approval. The Guidance at pp. 133-134 describes a minimum list of topics to be addressed in the modeling protocol:

1. Overview of Modeling/Analysis Project

a. Management structure b. Technical committees or other comm unication procedures to be used

c. Participating organizations d. Schedule for completion of attainment demonstration

e. Description of the conceptual model for the nonattainment area (or Class I area(s))

2. Model and Modeling Inputs

a. Rationale for the selection of air qual ity, meteorological, and emissions models b. Modeling domain

c. Horizontal and vert ical resolution d. Specification of initial and boundary conditions

e. Episode selection f. Description of meteorological model setup
g. Development of emissions inputs h. Geographic area identified for applic ation of the attainment test(s) i. Methods used to quality-assure emissions, meteorological, and other model inputs

3. Model Performance Evaluation

a. Description of the ambient data base b. Description of the evaluation procedures

c. Identification of possible diagnostic testi ng that could be used to improve model performance

4. Supplemental Analyses

a. Description of the additional analyses to be completed to corroborate the model attainment test b. Outline of the plans for conducting a wei ght of evidence determination, should it be necessary

5. Procedural Requirements

a. Identification of how modeling and other analyses will be archived and documented b. Identification of specific deliverables to EPA Regional Office

2008 PM 2.5 Plan’s modeling protocol is contained in Appendix F, with descriptions of both the receptor modeling approaches and th e photochemical modeling. Many aspects of the photochemical modeling that are suitable for incl usion in a protocol are also covered in Appendix G and the “Regional Model Performance Analysis” appendix. The protocol covers all of th e above topics, with the excep tion of identifi cation of how modeling and other analyses will be archived. In th e Plan there is no discussion of this topic, nor any description of how modeling data files may be accessed, s hould EPA or other interestedTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 27 parties wish to replicate the re sults of the analysis. See Guidance, p. 117. However, section 1 of the CARB modeling supplement describes the data storage requirements for the modeling files, and discusses how they may be requested (pp. 2 - 3).

c. Air Quality Model Selection A model should meet several general criteria fo r it to be a candidate for consideration in an attainment demonstration. Guidance, p.136. Th ese general criteria ar e consistent with requirements in 40 CFR § 51.112 and 40 CFR part 51, Appendix W. EPA does not recommend a specific model for use in attainment demonstrati ons. At present, there is no single model which has been extensively tested and shown to be clear ly superior to its alternatives. Thus, 40 CFR Part 51 Appendix W does not identify a preferred m odel for use in attainment demonstrations of the PM 2.5 NAAQS. Based on the language in Appendi x W, models used for these purposes should meet requirements in the Appendix for alternative models. States should use a non-propr ietary model, that is, a model whose source code is available for free (or for a reasonable cost) and w hose code can be revised by the state in order to perform diagnostic analyses and/or to improve th e model’s ability to describe observations in a credible manner. A model should meet several ad ditional prerequisites before being used to support an attainment dem onstration. It should be:

1. revised in response to a scientific peer review,

2. appropriate for the specific app lication on a theoretical basis,

3. used with a data base which is ad equate to support its application,

4. shown to have performed well in past ozone or PM modeling applications (or if it is the first application, then the state should note why it believes the new model is expected to perform sufficiently); and

5. applied consistently wi th a protocol on methods and procedures.

2008 PM 2.5 Plan’s model selection is discussed at p. F-80 and p. G-2, with the Community Multiscale Air Qualit y (CMAQ) model selected. CM AQ is a “state-of-the-science [model that]... has been extensively peer-reviewe d, is well-documented, and ... has been applied successfully in a range of environments.” The Pl an mentions certain California-specific updates to the model, but these are not described othe r than via a citation. However, the Californiaspecific updates are described in CA RB modeling supplement, section 3.2, p.17. The California-specific updates included: 1) fixing a model bug involving overly large fine PM deposition velocities th at caused negative concentrati ons, 2) accommodation of hourly average emissions instead of the CMAQS default instantaneous assumption, 3) incorporation of a time-varying fine PM size distri bution, 4) using a smaller standard deviation for the coarse PM size distribution to keep it within the appropriate 2.5 – 10 μm size range, 5) a lower vertical diffusion coefficient to better reflect the stagna tion in California’s Cent ral Valley, 6) a cap on ionic strength used in activity coefficient calculations for the a queous phase oxidation of (bi)sulfate, 7) the addition of dimethyl sulfid e (DMS) to the chemical mechanism to reflect the sulfur compound emissions from the large oceanic portion of the modeling domain (expected to be a larger proportion of the total as anthropogenic sulfur emissions have been reduced in recentTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 28 decades). For each of these changes, a brief desc ription and rationale is presented; the changes appear to have a reasonable basis, and to ha ve been aimed at improving model performance suggested by problems encountered in applying the default model to conditions in the SJV. There is no discussion of any alternative mode ls considered. EPA, how ever, believes that the choice of the CMAQ model is adequately justified because the EPA-sponsored CMAQ is explicitly mentioned in the Guidance (p. 138) as being a suitable model.

2008 PM 2.5 Plan’s chemical mechanism selection is also discussed at p. F-80 and p. G-2, with SAPRC-99 selected for the gas phase m echanism, and CMAQ’s AE4-AQ as the aqueous phase mechanism. These are little described except for a journal paper citation.

There is little discussion of alternative mech anisms considered. EPA, however, believes that the use of SAPRC is adequately justifie d because SAPRC is a we ll-known and widely-used mechanism.

d. Episode Selection We recommend one of two possible appr oaches for the modeling the 24-hour PM 2.5 NAAQS (Guidance, p. 147):

1) Model every day for a full year (or multiple years). This is recommended for both dispersion modeling of primary PM 2.5 components and photochemical modeling of secondary and primary components. Ma ny areas that viol ate the 24-hour PM 2.5 NAAQS will also violate the annual PM 2.5 NAAQS. Therefore, full year modeling may already exist or is being planned for the annual NAAQS attainment test. Modeling at least a full year will also help ensure that a sufficient number of days are included in the relative response factor (RRF) calculations. 2) Model episodes when high PM 2.5 concentrations occur. Similar to modeling for the ozone NAAQS, episodes shoul d be selected where PM 2.5 concentrations are greater than the NAAQS (in this case, the 1997 standard of 65 μg/m 3 ) and are close to the baseline design value. Also similar to ozone modeling, data analyses can be completed to help select a variety of meteorological episodes which lead to high PM 2.5 concentrations. In some cases, there may be very limited conditions which lead to high 24-hour average PM 2.5 concentrations, and in other cases there may be a wide variety of cases. The specific si tuation in each nonattainment area will determine the number of epis odes and the time periods which need to be modeled. For example, if exceedance-level PM 2.5 concentrations in an area only occur in the winter, then a limited number of winter days can be modeled. In other areas, exceedance days may occur in all seasons.

2008 PM 2.5 Plan’s episode selection is not discussed, instead a full year of modeling was performed. As mentioned above, there was litt le need to focus on the 24-hour standard attainment since ambient concentrations were al ready consistent with attainment of the NAAQS at the time the Plan was developed. Therefore th ere was no selection of particular periods or episodes of interest for the 24-hour NAAQS, a lthough 24-hour modeling was in fact performed.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 29 EPA believes this is marginally adequate. Si nce nonattainment of the annual standard in the SJV is known to be driven by frequent partic ular episodes in winter, it would have been preferable to choose and examine th ese particular periods in more detail in order to ensure the model performs well during such periods. However, because the model is used in a relative sense in the attainment demonstrati on, the design value alre ady attaining the 24- hour standard would have been scaled by a modeled RRF that reflect s emissions reductions, an d so the predicted 24- hour PM 2.5 design value would also ha ve attained the standard.

e. Domain, Domain Size, and Spatial Resolution

i. Domain Size The principal determinants of model domain size are the nature of the PM 2.5 problem and the scale of the emissions which impact the nonatt ainment area. Isolated nonattainment areas that are not affected by regional tran sport of PM and its precursors ma y be able to use a relatively small domain. Some areas of the western U.S. ma y fall into this category. The modeling domain should be designed so that all major upwi nd source areas that influence the downwind nonattainment area are included in the modeli ng domain. The influence of boundary conditions should be minimized to the extent possible. Guidance, p. 153.

ii. Horizontal Resolution EPA is comfortable recommending that states may use grid cell sizes as large as 12 kilometers (km) for urban scale applications addressing secondary components of particulate matter. We are less sure about an acceptable upper limit for cell size in applications addressing primary components. We believe it is prudent to assume that, in some cases, cells as small as 4 km (or possibly smaller) are needed. A state im plementing the modeling/analysis protocol may wish to perform a diagnostic test using a grid model without chemistry to see whether estimated RRF’s for primary components are affected if one decreases the grid ce ll size from 12 km to 4 km. Alternatively, large sources of primary PM can be modeled with a dispersion model or a combination of grid and dispersion models. We e xpect that modeling anal yses for nonattainment areas will use grid cell sizes of 12 km or less. If a regional scal e model is applied, most of the domain will likely cover rural/remote areas or lo cations which are not out of compliance with the NAAQS. For the regional outer nest of the domain, grid cells as large as 36 km may be used. Guidance, p. 157.

iii. Vertical Layers

There is no correct minimum number of vert ical layers needed in an attainment demonstration. The vertical reso lution will vary depending on the application. Greater resolution allows more precise estimation of mixing heights and avoids unrealis tic step increases in mixing; alignment with the layers in the meteorological model can affect accuracy; the lowest layer should generally be no more than 50 meters thick; resolution above the boundary layer can generally be coarser. Recent ap plications of one atmosphere models (with model tops at 100 millibars (mb)) have used anywhere from 12 to 21 vertical layers with 8-15 layers approximately within the boundary layer (below 2500 m) and 4- 6 layers above the Pl anetary Boundary Layer (PBL). Guidance p. 159.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 30 2008 PM 2.5 Plan’s modeling domain is discussed at pp. F-39, F-81, and especially p. G-3, and is shown on a map on page G-18. The domain us es a nested grid, with the inner domain containing the entire District and nonattainme nt area. The inner domain has a 4 km grid resolution and measures 320 by 356 km (80 by 89 grid cells). This inner doma in is nested within an outer domain covering most of California (CCAQS domain ), extending from the Pacific Ocean in the west to the deserts in Nevada a nd southern California in the east, and from the Tehachapi Mountains in the south to the Sacr amento Valley in the north. It has a 12 km resolution and measures 756 km (63 grid cells) in both horizontal dimensions. Both domains used 15 vertical layers of varying thickness up to the 100 mb pressure level (the top of the meteorological domain) with the surface layer approximately 30 m thick.

CCAQS modeling domain with the SJV modeling domain inset

Source: 2008 PM 2.5 Plan, Appendix G, Figure 1, p. G-18

EPA believes the domain is adequate, even though the documentation is sparse on its selection. The Plan has no discussion of any rati onale for the particular domain chosen or its horizontal and spatial resolution. Nevertheless, the inner domain meets all of the Guidance modeling domain characteristics listed above for spatial resolution and layer thickness. It also appears adequate for minimizing the influence of boundary conditions, since the east and west boundaries are in areas of sparse population, and the southern boundary is beyond a mountain range. The northern boundary is less satisfactory from this standpoint but is justified on the basis the Sacramento area being a different nonatt ainment area and all c ounties exceeding the PM 2.5 NAAQS being located in the southern end of the San Joaquin Valley, well away from theTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 31 northern boundary. In addition, this inner domain is nested within an oute r one that also meets the Guidance criteria.

f. Initial and Boundary Conditions If there is no larger regional model application available, then it is recommended that background boundary conditions be used to specif y initial and boundary concentrations for the attainment demonstration modeling. However, con centration fields derived from a larger domain regional or global chemistry model (i.e., the nestin g approach) is considered more credible than the assumption of static concentr ations, since the pollutant concen tration fields reflect simulated atmospheric chemical and physical processes driv en by assimilated meteorological observations. Therefore, EPA recommends using boundary conditi ons derived from a regional or global scale model, whenever possible. We also reco mmend using a ramp-up period by beginning a simulation prior to the period of interest to dimi nish the importance of initial conditions. The recommended ramp-up period is at least 5-10 days for PM 2.5 . Diagnostic testing which indicates a large impact on the model results from initia l or boundary conditions may indicate that the domain is not large enough or the ramp-up period is too short. In either case, it should generally be assumed that initial and bounda ry conditions do not change in the future. The use of altered initial or boundary conditions in the future year should be documented and justified. Guidance, p. 153. Plan initial and boundary conditions are discussed at p. F-81 and p. G-3. Boundary conditions for the outer domain were taken fromthe global chemical transport Model for Ozone And Related Chemical Tracers (MOZART). Initial conditions were estimated as an average of these conditions. The outer domain’s boundary conditions varied monthly, while the inner domain’s were computed from modeling of the outer domain and varied hourly. The use of 8-day ramp-up (a.k.a. spin up) periods prior to each mo del simulation minimized the effect of uncertain initial conditions on the mode ling. Page F-73 in the 2008 PM 2.5 Plan has a table of annual average boundary conditions for the various chem ical species; there is no information on the monthly or hourly values. There is no discussion of any diagnostic testing. EPA believes the initial and boundary conditi ons are acceptable, although sparsely documented (the preceding summary is essentially the full description in the Plan). Conditions appear to have been based on a reasonable proc edure, and the ramp-up period appears adequate.

g. Meteorological Model i. Meteorological Model Selection A description of the methods used to gene rate the meteorologi cal fields should be included in the modeling protocol. In cases in which standard meteorological modeling (e.g. MM5, RAMS, or WRF in a retrospe ctive analysis mode) is not used, EPA recommends that a detailed description of the technique that wi ll be used to generate the three-dimensional meteorological fields be shared with the appropriate EPA regi onal office(s) prior to conducting the air quality modeling analysis. Guidance, p. 161.

2008 PM 2.5 Plan’s meteorological model selection is discussed at p. F-81 and p. G-4, with MM5 selected. While there is no discussion of al ternative meteorological models, since MM5 isTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 32 well-known and widely used and explicitly ment ioned in the Guidance (p. 160) as being a suitable model, EPA believes the model choice is adequately justified.

ii. Meteorological Model Domain It is expected that most attainment demonstrations will cover large areas and use nested grids. The outermost grid should capture all upw ind areas that can reasonably be expected to influence local concentrations of PM 2.5 . In terms of selecting an appropriate meteorological modeling domain, a state should extend the grid 3 to 6 cells beyond the domains of each air quality modeling grid to avoid bounda ry effects. For example, if 4 km grid cells are to be used in the fine portion of a nested region al air quality model, then the me teorological fields at this detail would need to extend 12-24 km beyond the boun ds of the 4 km grid used for air quality predictions. In terms of grid resolution, EPA recommends th at the dynamic meteorological models use the same grid resolution as desired for the air quality model applications. In some cases, however, this may not always be feas ible. One possible reason for modeling with meteorology using a different grid resolution is in the case of unacceptable model performance from the meteorological model at the desired grid resolution. In other instances, the need for finer resolution may be emissions-driven more th an meteorologically-driven and the costs do not warrant the generation of additi onal resolution in the meteorological data. In these specific situations it is recommended that the air qualit y model application use available results from meteorological models on the next coarser scale (i.e., 36 km for a desired 12 km estimate, 12 km for a desired 4 km estimate). The coarse grid me teorological fields can be mapped to the more finely resolved air qu ality modeling domain.

iii. Physics Options Most meteorological models have a suite of phys ics options that allow users to select how a given feature will be simulated. For example, there may be several options for specifying the planetary boundary layer scheme or the cumu lus parameterization. In many situations, the optimal configuration cannot be determined wit hout performing an initia l series of sensitivity tests which consider various combinations of physics options over specific time periods and regions. While these tests may not ultimately conc lude that any one configuration is clearly superior at all times and in all areas, it is r ecommended that these sensitivity tests be completed, as they should lead to a mode ling analysis that is best-suite d for the domain and period being simulated. Typically, the model configuration whic h yields predictions th at provide the best statistical match with observed data over the most cases (episodes, regions, etc.) is the one that should be chosen, although other more qualita tive information can also be considered. Additionally, model confi gurations should be designed to ac count for the pollutants and time periods that are of most intere st. As an example, a wintertime PM simulation in the Midwest (with high measured nitrate concen trations) may need a meteorolog ical model configuration that employs a land-surface model that properly handle s snow covered fields and their effects on boundary layer humidities and temperatures.

2008 PM 2.5 Plan’s meteorological model setup is discussed at p. F-81 and p. G-4 and in the appendix “Meteorological Model Performance Analysis” (hereafter, MMPA). A 14-month simulation was done (the year 2000 pl us a month at either end), us ing three nested grids, having horizontal resolutions of 36 k, 12 km, and 4 km, from outermost to innermost. Maps of the domains appear as Figure 2 on p.G-19 and Figure 1 on p. 2 on of MMPA. (The innermostTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 33 domain in the two figures does not match; th e one on the map in Appendix G appears to be incorrect since it is square, wher eas the horizontal dimensions are stated to be 94x85 grid cells in both appendices.) The meteorological model used 30 vertical la yers, extending up to the 100 mb pressure level, with the surface layer 30 m deep. The MMPA at pp. 2-3 states that sensitivity testing using 50 layers and a 15 m surface layer to better reso lve atmospheric processes for stable winter conditions, but this doubled run times with little improvement in model results. (The context implies that this refers to the meteorologica l model rather than the air quality model.) The MMPA goes on to state “Many sens itivity studies were conducte d using various model options to gain better agreement with observations.” Th e optimal configuration included various physics options listed, e.g., Grell cumulus parameteri zation, Blackadar boundary layer scheme, Dudhia ice scheme, Dudhia cloud radiation scheme, a nd Blackadar soil model. Analysis nudging was used for the outer 36 km and 12 km grids.

The Location of the Three Nested Grids Designed to Study the Meteorology And Air Quality in the SJV Domain

Source: 2008 PM 2.5 Plan “Meteorological Model Performance Analysis,” p. 2.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 34 PA believes the meteorological domain and model set-up are acceptable although sparsely documented (the preceding summary is majority of the description provided in the Plan). It appears that there was substantia l effort to improve the meteorological model performance before an optimal configuration was chosen.

h. Meteorological Model Performance

EPA recommends that states devote appropriate effort to the process of evaluating the meteorological inputs to the air quality mode l as we believe good meteorological model performance will yield more confidence in the predictions from the air quality model. This evaluation should determine if the meteorological model output fields represent a reasonable approximation of the actual meteorology that o ccurred during the modeling period. This can be done via an operational evaluation (i.e., quantitative, statistical, and graphical comparisons). A second objective of the evaluation should be to identify and quantify the existing biases and errors in the meteorological pr edictions in order to allow fo r a downstream assessment of how the air quality modeling results ar e affected by issues associated with the meteorological data. This evaluation can be done via a more phenome nological assessment (i.e., generally qualitative comparisons of observed features versus their depiction in the model data). Guidance, p. 163. Operational Evaluation (Guidance, p. 163): The operati onal evaluation results should focus on the values and distributions of specific meteorological parameters as paired with and compared to observed data. It is recommended that the observation-model matching be paired as closely as possible in space and time. Typical st atistical comparisons of the key meteorological parameters will include: comparisons of the means, mean bias, mean normalized bias, mean absolute error, mean absolute normalized e rror, root mean square error (systematic and unsystematic), and an index of agreement. For modeling exercises over la rge domains and entire seasons or years, it is recommended that the operational evaluation be broken down into individual segments such as geographic sub-regi ons and/or months/seasons to allow for a more comprehensive assessment of the meteor ological strength s and weaknesses. Phenomenological Evaluation (Guidance, p. 167): Within the conceptual description of a particular modeling exercise, EPA recommends th at a state identify and qualitatively rank in importance the specific meteorological parameters that influence air quality. When evaluating meteorological models or any other source of meteorological data, the focus of the phenomenological evaluation should be on those specific meteorological phenomena that are thought to strongly affect air po llution formation and transport w ithin the scope of a specific analysis. It is expected that this event-or iented evaluation will need to summarize model performance in terms of statistical metrics such as probability of detection and false alarm rate. As an example of a potential phenomenological analysis, many regional air quality modeling exercises attempt to assess the effects of tran sport of emissions from one area to a downwind area with an intent to establish source-recep tor relationships. For th ese types of modeling analyses, accurate transport wi nd trajectories are needed to properly establish these sourcereceptor linkages. In this type of model a pplication, a useful event-based meteorological evaluation would be to compare mo del-derived trajectories versus those based on ambient data to determine what error distance can be associated with the model fields. 2008 SJV Plan’s meteorological model performance is discussed in the appendix “Meteorological Model Performance Anal ysis” (MMPA). In addition, CARB modelingTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 35 supplement includes a phenomenological mode l evaluation, and its Appendixes A through D provide exhaustive documentation on performance of the model, with many time series and spatial plots for wind speed, wind direction, temperature. Appendix A has plots and statistics for modeled vs. observed temperat ure, relative humidity, and wind components for each meteorological station, and also accumulated pr ecipitation for some stations. Appendix B has some of the material that is in the “Meteorol ogical Model Performance An alysis” in the Plan, but also many histograms showing occurrence freque ncy of simulated and observed wind speeds, temperature, and relative humidity for each mont h, for the stations in the vicinity of Fresno. Appendix C has weekly time series plots for wind speed, wind direction, and temperature for each station. Finally, Appendix D has hourly spatial plots of predicted and observed surface winds, portrayed as a wind vector for each gr id cell of the modeling domain. There is an operational evaluation using three methods for te mperature, relative hum idity, and horizontal wind components for the full year and by season.

Evaluation Method 1 considers mean and sta ndard deviation, co rrelation, root mean square error, mean bias, and inde x of agreement; this information is stated to be in Attachment A, which is not provided. Results are stated (M MPA p. 6) to be generally well-correlated but less so for wind components. Relative humidity is generally over-predicted. Agreement between predictions and observations varies little seasonally.

Evaluation Method 2 involves examination of frequency histograms for temperature, wind speed, and humidity for 24-hour periods in alte rnate months. This information is stated to be in Attachment B, which is not provided. Th e MMPA states (p. 8): “The frequency distribution of air temperature, relative humidity, and mixing ratio for observations and model results show reasonably good agreement. There are only small differences in observed and simulated diurnal wind speed patterns.” This appears to be the case for the Fresno examples given. Finally, Evaluation Method 3 consists of hour ly comparisons for wind speed, direction, and temperature over two five-day periods with in each modeled month. This information is stated to be in Attachment C, which is not pr ovided, although graphs of a December, 1990 fiveday period for Fresno are shown. The MMPA (p. 9) concludes “the model can capture the diurnal evolution of observed wind speed, wind di rection and temperature variations reasonably well,” despite the fact that “the estimates for th e evolution of the wind sp eed and direction differ somewhat. However, the examination of all figur es given in Attachment C indicates that the model does capture the overall evolution.” Section 2 of the CARB modeling supplement (pp. 4 – 8) contains a phenomenological evaluation of the meteorological model perfor mance, including an assessment of seasonal variation. It describes some th e meteorological and topographic f actors leading to high pollutant concentrations. It also describes some alternat e MM5 model configurations that were evaluated, including analysis nudgi ng of the wind field, various numbers of vertical layers, and various physics model options such as the MRF, Blackadar, Gayno-Seaman, and ETA schemes for the evolution of the Planetary Boundary Layer (PBL). Each configuration was evaluated using time series graphs and statistics based on simulati on of a one-week period; no one configuration was found to be superior to the others. The seas onal assessment evaluate d the MM5 simulation’s ability to replicate phenomena important to San Joaquin Valley pollutant formation and distribution, such as slope flows, sea breezes, and low wind speeds, as well as overall wind patterns and temperature gradients. The assessmen t concludes that sea breezes and slope flows are replicated well, although less so for the Sacram ento delta region; wind speeds tended to be aTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 36 bit larger than observed, but acceptable; temperat ure gradients tended to be a bit smaller than observed; and overall flow pa tterns were replicated well.

The overall conclusion in the Plan is that the MM5 simulations “reproduce the overall statistical characteristic s of observed meteorological conditions ”. There is some underestimate of maximum surface temperature, although the model is able to capture the large temperature variations that occu r in some periods. EPA believes the meteorological model pe rformance was adequate, and thoroughly documented. It is apparent that substantial thought and effort went into the operational evaluation, including for particular periods throughout the year, ra ther than just overall annual statistics. The phenomenological evaluation also is adequate, with assessment. of how well phenomena important to PM 2.5 formation in the SJV are adequately captured in the meteorological modeling, including for va rious locations and times of year.

i. Emissions Inventory Air quality modeling requires emissions input s for base case, baseline, and future modeling years. Preparation of emissions data for air quality models for th e base and future years requires several steps. First, a state needs to compile base-year inventories for its modeling region (e.g., the states and tribes in the modeling grid). For PM model applications, emissions inventories should include emissions of an thropogenic and biogenic VOC (speciated), NO x , carbon monoxide, SO 2 , NH 3 , PM 2.5 (speciated), and PM coarse (PMC). Second, modelers must collect ancillary data associated with the inventor ies, which prescribes the spatial, temporal, and chemical speciation information about the emissi ons inventory. Third, modelers use the ancillary data for emissions modeling. Emissions models sp atially, temporally, chem ically, and vertically allocate emissions inventories to the resolution needed by air quality mo del. Fourth, modelers must collect data on growth rates and existing control programs for use in projecting the base year emissions inventories to the future year, an d then use an emissions model to prepare that future year inventory data for input to the ai r quality model. Fifth, emissions inventories that reflect the emissions reductions needed for attainment will have to be prepared for air quality modeling.

2008 PM 2.5 Plan’s emissions inputs are discussed at p. G-3, and references to the need for emissions input to modeling appear at various places in Appendix F. Page G-3 states A spatially, temporally, and chemically resolved emissions inventory of combined area, mobile, and point sour ces was generated using the California Emissions Forecasting System (CEFS) version 1.06 with offline adjustments. The inventory includes emissions estimates fo r gaseous and partic ulate species of anthropogenic and biogenic origin. Gridde d hourly emissions were developed for the CMAQ modeling domain for th e years 2000, 2005, and 2014 (baseline).

The Plan does not include a disc ussion of the procedures used to spatially or temporally allocate emissions for input to the model, other than the reference to CEFS. Quality assurance methods for emissions inputs are mentioned at p. G-3 but not discussed: “Quality assurance checks of domain emissions totals and spatial di stribution were performed at various steps.” There are no tables of modeli ng emissions totals for various pollutants, source groupings, subareas, or seasons. There are no maps of emissi on density or diurnal time series of emissions,TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 37 which could illustrate the spatial and tempor al allocation, and help in understanding PM 2.5 concentration variations over space and time. EPA believes the modeling emissions inventor y preparation procedures were adequate but sparsely documented (the preceding excerpts are essentially the full description in the Plan). It is apparent that substantial e ffort went into preparing emissions inputs in order for the model to have been run, but this effort is little documented in the Plan.

j. Air Quality Model Performance

PM 2.5 consists of many components and is typi cally measured with a 24-hour averaging time. The individual components of PM 2.5 should be evaluated individua lly. In fact, it is more important to evaluate the components of PM 2.5 than to evaluate total PM 2.5 itself. Apparent good performance for total PM 2.5 does not indicate whether modeled PM 2.5 is predicted for the right reasons (the proper mix of com ponents). If performance of the major components is good, then performance for total PM 2.5 should also be good. EPA recomme nds calculating statistics for components of PM 2.5 , and PM precursors. Useful metrics include mean fractional bias and mean fractional error, normalized mean bias, and nor malized mean error. Formulas for estimating these metrics are given in the Guidance. (Guidance, p. 203-204) Other statistics such as mean bias, mean error, root mean square error, correla tion coefficients, etc. should also be calculated to the extent that they provide meani ngful information. Since modeling for the PM 2.5 NAAQS will likely require modeling different times of year, season-specific statistics and graphic displays are helpful for evaluating and diagnosin g model performance. Statistics and graphics can be averaged for various time scales. For exam ple, statistical metrics and scatter plots can show daily averaged ambient modeled pairs, m onthly averaged pairs, quarterly (or seasonal averaged) pairs, or annual average pairs. Each of these averaging times can provide useful information. EPA recommends a range of diffe rent averaging times for annual or seasonal modeling. At a minimum, a state should examine daily averaged pairs an d seasonal (or quarterly) averaged pairs. Because statistics and plots te nd to look better as the av eraging time increases from daily to monthly to quarterly to annual, daily pairs should al ways be examined to ensure a detailed look at model performance on the time scale of the FRM and STN measurements (24- hour average). Soccer plots provide a conveni ent way to display a summary of model performance (including bias and erro r at the same time). Bugle plots 12 have variable bias and error goals, based on ambient con centrations. This allows for a hi gher percentage error and bias at very low concentrations. This recognizes th e fact that models often have difficulty in accurately predicting near background concentr ations and may be useful to prioritize examination of model performance within and near the non-attainment area(s) of interest. Additionally, priority may be placed on examination of the days that are potentially used in the attainment test (e.g., the days > 65 μg/m 3 for 1997 24-hour PM 2.5 ).

2008 PM 2.5 Plan’s air quality model performance is discussed in the appendix “Regional Model Performance Analysis” (hereafter RMPA ), starting at p. 6. Section 3.3 of the CARB modeling supplement (pp. 22 – 100) c ontains much additional detail.

12 Fractional error and bias tend to be large at small concentrations, since then the uncertainty can be nearly as big as the concentration. Since fractional error varies re latively slowly with concentra tion, but then grows larger at low concentrations, the shape of the plot resembles a long tube with a flared end at low concentrations, reminiscent of a bugle.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 38 The Plan does not include a discussion of the database used to evaluate model performance, other than many references to CRPAQS and referrals to the Central California Air Quality Studies’ website (http://www.arb.ca.gov /airways). (For example, “The CRPAQS main field program collected extens ive data during the period of December 1999 to February 2001” (p. F-32)).” It is know from media accounts, CARB’s website, the District’s website (http://www.valleyair.org/ ), and study reports and journal articles, th at the study involved intensive metrological and air quality measurem ents, including measurements taken on towers and in aircraft and created a wealth of da ta useful for developing and evaluating model applications. The Plan contains no speciated 24-hour PM 2.5 data. It contains onl y annual data and, in one case, monthly data (in Appendix H) are provided. Three types of information were used to evaluate model performance: maps with PM 2.5 spatial patterns, performance statistics at individual monitors, and time series plots. Filled concentration contour plots of the modeling domain are shown in RMPA, pp. 7-11 (figures 3 – 7), for annual PM 2.5 and four quarterly averages. Each of these has seven plots, one each for total PM 2.5 , nitrate, sulfate, amm onium, organic carbon, elem ental carbon, and dust. (An example is included below and shows fourth quarter total PM 2.5 .) A paragraph on RMPA p. 6 summarizes the plots, noting that nitrate forma tion follows the pattern expected from seasonal temperature and humidity, although th ird quarter nitrates appear t oo high. Sulfates are low for all quarters, while organic carbon (OC) and elemental carbon (EC) are hi gher in the first and fourth quarters, presumably due to enhanced wood bur ning during these periods. There is no discussion of the spatial variation of PM 2.5 or its components and how it comp ares to expectations or to monitored values.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 39 Fourth Quarter Average Concentrations for PM 2.5

Source: 2008 PM 2.5 Plan Appendix “Regional Model Performance Analysis,” Figure 7, p.11.

Next the RMPA at pp. 12 - 14 discusses stat istics for Mean Fractional Error (MFE) and Mean Fractional Bias (MFB), which are shown in th e form of bugle plots. Each plot is for annual average PM 2.5 total or a component, and shows MFE or MFB plotted agai nst concentration. CARB modeling supplement (pp. 24 – 31) show s additional bugle plots, for each calendar quarter and each chemical species component of PM 2.5 performance criteria were set at MFE ≤ 75 percent and |MFB| ≤ 60 percent. The RMPA not es that the criteria are met for all species except dust, which is substantially overestimated for reasons that are not understood. Eight other statistics are mentioned in the modeling protoc ol, at p. F-62, such as Mean Normalized Gross Error, but no values are presented.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 40 Finally, time series plots are examined at RMPA pp. 14-16. Bakersfield and Fresno concentrations of PM 2.5 total and components are plotted agai nst day of the year-long simulation, with a fluctuating line showing model prediction, and individual dots showing monitored values. CARB modeling supplement (pp. 32 – 65) shows additional time seri es plots showing all days of the simulation, for each of the 35 monitors, for each chemical species component of PM 2.5 ; it also has combined bar & line gr aphs of the monthly average species components (pp. 66 - 99). The RMPA notes that the over-predicted of nitrate in the thir d quarter is apparent, as is the overestimation of dust. The CARB modeling suppleme nt states that the cause of this is overestimation of specific humidity in the meteor ological model in the summer (p. 23) EPA examination of the plots also suggests that many PM 2.5 days are missed at both Bakersfield and Fresno, that organic carbon is unde r predicted (especially at Fr esno), and that ammonium is under predicted. Sulfate is al so often under predicted, but sulfate’s contribution to PM 2.5 levels in the Valley is small. Since the plots show the en tire year, it is hard to judge performance during particular months or seasons. No tables of numbers calculated for the pe rformance statistics ar e presented, but the many bugle graphs give an excellent idea of pe rformance for Mean Frac tional Error and Mean Fractional Bias, including comparison to performance goals. Sensitivity, or diagnostic testing of the mode l, can check whether it responds to input changes in a physically reasonable way, whethe r alternative input assumptions could have improved model performance, and whether the predictions are subj ect to compensating errors in the inputs. These are discussed only briefly, in the CARB modeling supplement, p. 23, which mentions numerous simulations performed to assu re the credibility of the simulation; these included changing boundary and initial conditions, va rying lengths of time fo r initial model “spin up”, and other tests. There is little discussion of qualitative assessment of whether the model is adequately capturing the various processes leading to high PM 2.5 concentration and no assessment of spatial variation of model performance, but it is ap parent that substantial effort went into evaluating the reas onableness of the simulation. EPA believes the air quality model performance is adequate, and adequately documented, though additional qualitative descri ption of how the model is capture important phenomena would have been desirable.

k. Modeled Attainment Test

A modeled attainment test is an exercise in which an air qu ality model is used to simulate current and future air quality. If future estimates PM 2.5 concentrations are less than the NAAQS, then this element of the attainment test is sa tisfied. EPA’s recommended test is one in which model estimates are used in a relative rather than absolute sense. That is, we take the ratio of the model’s future to current (baseline) pred ictions at monitors. We call these ratios, relative response factors , RRF. Future PM 2.5 concentrations are estimated at existing monitoring sites by multiplying a modeled relative response factor atlocations near each monitor by the observationbased, monitor-specific, baseline design value. Th e resulting predicted futu re concentrations are compared to NAAQS.

The PM 2.5 attainment test reflects the fact that PM 2.5 is a mixture. In the test, ambient PM 2.5 is divided into major species components, so EPA’s test is called the Speciated Modeled Attainment Test (SMAT). These are mass associat ed with sulfates, nitr ates, ammonium, organicTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 41 carbon, elemental carbon, particle bound water, othe r primary inorganic particulate matter, and passively collected mass. Note that FRM mon itors do not measure the same components and do not retain all of the PM 2.5 that is measured by routine speciati on samplers and therefore cannot be directly compared to speciation measuremen ts from the STN. By design, the FRM mass measurement does not retain all ammonium nitrat e and other semi-volatile materials (negative sampling artifacts) and includes pa rticle bound water associated with sulfates, nitrates and other hygroscopic species (positive sampling artifacts). This results in concentrations (and percent contributions to PM 2.5 mass) which may be different than the ambient levels of some PM 2.5 chemical constituents. Therefore we recomme nd a SMAT technique which uses an FRM mass construction methodology which results in reduced nitrates (relative to the amount measured by routine speciation networks), high er mass associated with sulfates and nitrates (reflecting water included in gravimetric FRM measurements) and a measure of organic carbonaceous mass which is derived from the difference between measured PM 2.5 and its non-organic carbon components. This approach is sometimes called SANDWICH, for s ulfate, a djusted n itrate, d erived water, i nferred c arbonaceous material balance approach . Guidance, p. 47. A separate RRF is calculated for each of the PM 2.5 components (except passive mass). We call each of these site-specific ra tios, a component-specific RRF. Future PM 2.5 design values are estimated at existing monitoring sites by mult iplying modeled relative response factors near each monitor times the observed component spec ific design value. This latter quantity is estimated using measured site-specific design values for PM 2.5 in concert with available measured composition data. Future site-specific PM 2.5 design values at a site are estimated by adding the future year values of the seven PM 2.5 components. If all future site-specific PM 2.5 design values are less than or equal to the con centration specified in the NAAQS, the test is passed. Guidance, pp. 15-16.

2008 PM 2.5 Plan’s annual PM 2.5 NAAQS attainment test is discussed in Chapter 3, pp. 3- 20 and 2-33, and in Appendix G on “Regional Air Quality Modeling”. Sec tions 4 and 5 of the CARB modeling supplement provi des additional information on SMAT and on the development of the RRFs. A variation on EPA’s SMAT approach is us ed, to account for the SJV’s abundance of ammonia and the dominance of ammonium nitrate ove r ammonium sulfate. This variation is to assume that ammonium on the monitor filter is the measured STN NH 4 minus any losses associated with fully neutralized nitrate (as NH 4 NO 3 ) that may have volatilized off the FRM filter. 2008 PM 2.5 Plan, p. G-10. Sections 4 and 5 of the CARB modeling supplement (pp. 100 – 103) provide additional justificat ion for the approach, with gra phical comparisons showing that measured ammonium is equal to the amount needed to neutralize measured nitrate and sulfate. The 2006 design values and the results of the SMAT for 2014 baseline conditions and for the result of new emissions cont rols are shown in Chapter 3, Ta ble 3-3 (p. 3-23) and Appendix G, Table 3 (p. G-21) of the 2008 PM 2.5 Plan. The 2014 controlled design value is seen to be less than the annual NAAQS level of 15 μg/m 3 for every monitor, thus demonstrating attainment. The highest 2014 value is 14.7 μg/m 3 at the Bakersfield Planz Road monitor. The RRFs, and details of their calculation are presented in s ection 5 of the CARB mo deling supplement, pp. 103 - 104, and RRF tables at pp. 104 -115.

2008 PM 2.5 Plan’s 24-hour PM 2.5 NAAQS attainment test is discussed in the same place as the attainment test for the annual standar d, with results in Appendix G, Table 4, p. G-22.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 42 Appendix G, Table 4 shows the 2006 design values for Bakersfield and Fresno monitors and the projected 2014 design values for the cont rolled case. Since the 2006 design values are already below the 1997 24-hr NAAQS level of 65 μg/m 3 , the controlled values are, too. The highest 2014 value is 46.2 μg/m 3 at the Bakersfield California Avenue monitor. The Relative Reduction Factors are presented in section 5 of the CARB modeling supplement, at pp. 117 - 138.

The attainment tests show attainment of both PM 2.5 NAAQS. The Plan cites several factors as justifying a variation on EPA’s SMAT approach (e .g., the prevalence of ammonia, the dominance of ammonium nitrate, the effect of substantial controls on fugitive dust and direct carbon emissions (p. G-10 and p. 3-20)) and th e CARB modeling supp lement shows the approach is reasonable for the ammonium i on. The RRFs are presented for each monitoring station and calendar quarter. EP A believes the attainment de monstration is adequately documented, and that it proj ects attainment by 2014 for both the annual and 24-hour PM 2.5 NAAQS.

l. Unmonitored Area Analysis

In addition to a modeled attainment de monstration, EPA recommends use of an unmonitored area analysis. This t ype of analysis is intended to ensure that a control strategy leads to reductions in ozone or PM 2.5 at other locations which coul d have baseline (and future) design values exceeding the NAAQS we re a monitor deployed there. The unmonitored area analysis should identify areas where future year design values are predicted to be greater than the NAAQS. The unmonitored area analysis for a particular nonattainment area is intended to address potenti al problems within or near that nonattainment area. The analysis should include, at a mini mum, all nonattainment counties and counties surrounding the nonattainment area (l ocated within the state). In order to examine unmonitored areas in all portions of the domain, EPA recommends that a state use interpolated spatial fields of ambient data combined with gridded modeled outputs. Guidance, p. 29. Gradient adjusted spatial fields are first crea ted for the base year. Future year estimates can then be created by applying gr idded RRFs to the gradient adju sted spatial fields. The basic steps are as follows (Guidance, p. 30):

1) Interpolate base year ambient data to create a set of spatial fields. 2) Adjust the spatial fields using gridded model output gradients (base year values). 3) Apply gridded model RRFs to the gradient adjusted spatial fields. 4) Determine if any unmonitored areas are pr edicted to exceed the NAAQS in the future.

2008 PM 2.5 Plan’s unmonitored area analysis is discussed on page G-15. It takes the form of a simple screening analysis, examination of a filled concentration cont our plot (Figure 3 on p. G-20), and the observation that “there are no area s with steep gradients that would result in higher design values than those measured at monitors”. In addition, section 6 of the CARB modeli ng supplement (pp. 139 - 182) contains an Unmonitored Area Analysis in the sense of th e EPA Guidance, using EPA’s Model Attainment Test Software (MATS). It in cludes spatial contour plots of quarterly and annual averageTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 43 concentrations for simulated PM 2.5 components for the 2005 base year (pp. 141 - 147), and comparable plots for the 2014 atta inment year, including concentra tions adjusted by the gridded model output gradients from MATS . CARB examined locations where the gradient implied high values. In one case, Modesto 14 th Street, the location already had a monitor, and modeled results there, and so did not strictly sp eaking need to pass the test. MATS and direct modeled results for the Bakersfield area appear to match, so CARB be lieves MATS results are reliable for that area, and MATS did not predict any unmonitored violati on. For the Fresno area, there appeared to be a 15-25 percent overestimate by MATS, based on 2005 measured values; discounting the MATS future high value in an unmon itored location west of Fresno by that amount led CARB to believe that this area, too, will not have an unmonitored PM 2.5 NAAQS violation.

EPA believes that CARB has shown that SJ V successfully passes the test in the Unmonitored Area Analysis.

m. Weight of Evidence States should perform complementary an alyses of air quality, emissions and meteorological data and consider modeling outputs other than the results of the attainment test. Such analyses are instrumental in guiding the conduct of an air quality modeling application. The results of corroboratory analyses may sometimes be used in a weight of evidence determination to show that attainment is likely despite modele d results which may be inconclusive. The further the attainment test is from being passed, th e more compelling contrary evidence produced by corroboratory analyses must be to draw a conc lusion differing from that implied by the modeled attainment test results. Guidance, p. 17. S upplemental analyses could include additional modeling using alternative models and inputs, modeling apportionment and process analysis tools, alternative metrics (such as change in the number of gr id cells above the NAAQS), trends in ambient air quality, trends in emissions, recep tor modeling, and indicator species approaches.

2008 PM 2.5 Plan’s weight of evidence determination is discussed in Appendix H. Supplemental analyses used in the weight of evidence determination are described in that Appendix and also in Chapter 3, Appendix F, and the appendix on “Receptor Modeling Documentation” (hereafter RMD).

As mentioned near the start of this TSD section on m odeling, the Plan emphasizes a receptor modeling-based approach for the a ttainment demonstration, with photochemical modeling added later. However, EPA views the receptor modeling mainly as a supplemental analysis to corroborate the photochemical mode ling as part of the weight of evidence determination. Chapter 3 describes three variants of a speciat ed rollback approach (p. 3-23). Method 1 is based on Chemical Mass Balance (CMB) modeling of PM 10 speciated measurements from the year 2000; this was converted to 2005 PM 2.5 values, which are in turn projected to 2014, with some adjustments described below. This met hod is applied to the Fresno, Kern, Kings, and Tulare County monitors. Method 2 is similar but is based on speciation data from the years 2004- 2006. This method is applied to the Fresno and Ke rn monitors only. The third method is based on a Positive Matrix Factorization (PMF) usi ng speciated data from the years 2003-2006. This method is applied to the Fresno and Kern monito rs only. Thus Fresno and Kern County monitors have all three methods applied, Kings and Tulare Counties have only Method 1 applied.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 44 Table B-1 

### Guidelines For Weight of Evidence Determinations

Results of Modeled Attainment Test Supplemental Analyses

Annual PM 2.5 24-Hour PM 2.5

Future Design Value < 14.5 μg/m 3 , all monitor sites Future Design Value < 62 μg/m 3

, all monitor sites Basic supplemental analyses should be completed to confirm the outcome of the modeled attainment test

Future Design Value 14.5-15.5 μg/m 3 , at one or more sites/grid cells Future Design Value 62-67 μg/m 3 , at one or more sites/grid cells A weight of evidence demonstration should be conducted to determ ine if aggregate supplemental analyses support the modeled attainment test

Future Design Value > 15.5 μg/m 3 , at one or more sites/grid cells Future Design Value > 68 μg/m 3

, at one or more sites/grid cells More qualitative results are less likely to support a conclusion differing from the outcome of the modeled attainment test.

All three of these approaches included various adjustments and proj ection to 2014 (and in some cases intermediate years). The adjustme nts included considera tion of the emissions inventory in order to attribute PM 2.5 in a more refined way than the CMB and PMF approaches could by themselves, as the latter cannot always distinguish between differe nt sources of a given chemical species. There is little text discussion in the Plan of how this refinement was done. Adjustments are also made considering the area of influence of each monito r in order to further refine which sources were relevant to particular monitors. There is no text definition of area of influence and no discussion of the procedure fo llowed, other than a diagram and formula at RMD, p. 79, though the meaning of this diagram a nd formula is not clear. Another adjustment involved modeled sensitivity f actors from CMAQ nitrate modeli ng (and linear nitrate projection and IMS95 modeling”) were used to estimate the response of the atmosphere to changes in NO x emissions. This was an attempt to address the inability of straight speciated rollback to handle secondary particulates, as they are not directly as sociated with emitted species from sources. It is not clear exactly to which mode ling exercises these refer. In addition there is discussion of variations on SMAT (p. 3-21), involving “appr oved alternate linear assumptions” on trapped water bonded to ammonium nitrate and ammonium sulfate and othe r issues, but it is not clear how this was done. The execution of much of this is in the spreadsheet in the RMD; however, there is very little documentati on on the spreadsheet and its formul as. The results from all these adjustments are in Table 3-2, p. 3-22, which lists for each county the 2005 design value,TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 45 “Receptor Modeled SMAT RRF 2005-2014” base d on the methods just described, and a projected 2014 design value. For all c ounties the value is less than 15 μg/m 3 the level of the annual NAAQS. The highest 2014 value is 14.09 μg/m 3 , for Kern County based on the PMF method.

EPA believes that the ideas used to refine the receptor modeling re sults are reasonable ways to address shortcomings of receptor modeli ng, especially for an area for which secondary particulates are so important. The results do s upport the attainment de monstration, and it is apparent that substantial t hought and effort went into a pplying the methods. However, documentation for the approaches used is conf using, not well organized, and in some cases missing altogether. Without improved documentation, it is difficult to assess the strength of this supplemental analysis. Appendix H. “Weight of Evidence” describes several other supplemental analyses. These include tables (pp. H-5 - H-4), bar charts (p. H-5), a Theil regressi on trend test (p. H-5) and time series plots (p. H-6 and p. H-10), all show ing a downward trend in 24-hour and annual PM 2.5 concentrations. Monthly time series (pp. H-7 – H-8) comparing 2001 to 2006 for Bakersfield and Fresno show substant ial decline in PM 2.5 during the winter months (summers remained about the same). Histograms (p. H-9) comparing frequency distributions for various concentration ranges from the years 1999-2001 to those in 2004-2006 for Bakersfield and Fresno show decreases in the frequency of the highest c oncentrations. This decrease is clearest for Fresno, which also shows increased occurrence of low concentratio ns. (Mid-range concentrations, between 15 and 40 μg/m 3 are more of a mixed pict ure.) Species and total PM 2.5 trends (pp. H-14 – H-15) also show declines over 2001-2006, principally in ca rbonaceous aerosols, but also in ammonium nitrate. The increased stringency of the Residential Wood Combustion Rule that was implemented in 2003 is cited as one of the causes of the decline (p. H-14). Further evidence of a downward trend in nitrate during 1987-2005 is shown in additional graphs (p. H-17). Emissions are also trending down, as seen in a 2001-2005 time series plot for emitted species, especially for NO x and for reactive organic gases. An indicator species analysis plots the Angiola and Fresno winter 2000-2001 concentrations of NH 3 (ammonia) against that of HNO 3 (nitric acid). It is the combination of these two that forms ammonium nitrate PM 2.5 . Ammonia concentrations are almost always far higher than those of nitric acid, a nd also vary over a much larger ra nge than nitric acid. This is evidence that nitric acid is the limiting precursor, with some implications for the advisability of controls of NO x emissions as opposed to ammonia. Finally, Appendix H (p. H-25) discusses the receptor modeling and photochemical modeling results already covered above. EPA believes that the supplemental analyses presented in Appendix H are useful in a weight of evidence, and support th e demonstration of attainment.

3. Conclusions

The 2008 PM 2.5 Plan with the CARB modeling supplement adequately document all the elements of a modeled attainment demonstrati on. Significant time, money, and effort by CARB, the District, and many others have gone into pr eparing the air quality modeling to support the attainment demonstration in SJV PM 2.5 plan for the San Joaquin Valley, including the multi-TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 46 million dollar CRPAQS study. EPA believes that the modeling is sound and provides an adequate basis for the reasonably available cont rol measures, reasonable further progress, and attainment demonstrations in the Plan.

4. Pollutant Ratios Used to Determine PM 2.5 Equivalency The 2011 Progress Report and the SJV PM 2.5 Progress Report use a PM 2.5 equivalency metric in a number of tables and demonstrations. Two ratios are used:

• 9 tpd NO x to 1 tpd direct PM 2.5

• 1 tpd SO x to 1 tpd direct PM 2.5
The NO x :PM 2.5 ratio is partly documented in supplemental information provided by CARB, entitled “Precursor Effectiveness,” which is available in the docket for this proposed rulemaking. Using the CMAQ modeling application used for the attainment demonstration, in two separate runs CARB simulated an additi onal 10 percent reduction in modeling domain NO x emissions and in direct PM 2.5 emissions. These PM 2.5 effects were divided by the (unstated) emissions totals for each pollutant , to give a concentration per em issions change, or effectiveness for each pollutant, and finally the direct PM 2.5 effectiveness was divided by the NO x effectiveness to arrive at a NO x :PM 2.5 ratio for each monitor; the average of these is about 9. This method appears to be adequate for purposes of assessing the effect of area-wide emissions changes, such as are used in RFP, contingency measures, and conformity budgets. 13

The approach used by the District to estimat e interpollutant equi valency ratios rests on the faulty assumption that ambient sensitivity to emissions reductions of a given precursor can be estimated as the ratio of concen tration to emissions. This is th e assumption of linear “rollback”, and inherently cannot addre ss the complexities of PM 2.5 formation chemistry, which is nonlinear. It is in contrast to the State’s approach for the NO x : PM 2.5 ratio which used photochemical modeling results to take into account such nonlinearity. Even if the ambient PM 2.5 response to precursor reductions is in fact linear for a range of emissions reductions, that response does not necessarily match the average response assumed in rollback. (Similarly, the slope of a curve at a given point does not necessarily match the slope of the line conn ecting the curve's end points.)

13 EPA is proposing to approve the use of this NO x to PM 2.5 interpollutant trading ratio to meet CAA planning requirements for the 1997 PM 2.5 standards in the SJV. EPA is also proposing to approve the use of this ratio in transportation conformity determinations for the 2006 24-hour PM 2.5 NAAQS but only until such time EPA finds adequate or approves budgets developed specifically for the 2006 standard. EPA is not proposing, at this time, to approve the use of this ratio in plans for future PM standards or in the Distri ct’s new source review (NSR) permitting program. The District recently submitted revisions to its NSR rule, Rule 2201, which require that interpollutant trading ratios used for purposes of satisfying PM 2.5 NSR offset requirements first be approved by EPA into the SIP. See Rule 2201 (April 21, 2011), section 4.13.3.2. The Rule 2201 submittal also states th at the District intends to submit SJV-specific PM 2.5 interpollutant trading ratios for EPA’s approval in a future SIP revision but will, in the interim, require project proponents to use the de fault ratios provided in the preamble to EPA’s PM 2.5 NSR rule (73 FR 28321 at 28339 (May 16, 2008)), until alternative trading ratios are approved by EPA into the SIP. See SJVAPCD, Final Draft Staff Report, Proposed Amendments to Rule 2201 (New And Modified Stationary Source Review Rule), March 17, 2011, p. 4.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 47 Ambient concentration might be very responsiv e initially and less responsive with greater reductions, or vice versa; both w ould appear as the same responsiveness under the faulty linear rollback assumption. Some strengths of the District's methodology ar e that it attempts to account for multiple monitors, the portion of each monitor's ambient c oncentration that is likely subject to local controls, the emissions that are in the monitor's area of influence and have the strongest affect on its concentration, and the time of year (4th quarter of the years) having th e highest emissions and concentrations. See Ratio Documentation p.1; Ratio spreadshee t; and SJVAPCD May 2009 letter, attachment II pp. 4, 8. 14 In addition, it makes use of information on the contribution of broad source categories to par ticular locations, which were available at the time from the receptor modeling approach, and not from the photochemical modeling. SJVAPCD May 2009 letter, attachment II, p. 6, 9. Fi nally, the District did try to assess how results might change during the 2005-2014 period. SJVAPCD May 2009 letter, attachment II, p. 8. These positive features are improvements within the confines of the recepto r modeling approach, but they cannot compensate for the faulty un derlying assumption discussed above. Two other potential problems in the approach are worth noting. First, the sensitivity to direct PM 2.5 emissions is based on organic carbon (OC), partly because OC is the main pollutant for which interpollutant offsets are sought in th e context of New Source Review permitting in the SJV. SJVAPCD May 2009 letter, attachment II, p.2). It is not clear whether this is the appropriate basis for evaluating equivalenc y for air quality planning purposes including contingency measures, and whether the se nsitivity to other types of direct PM 2.5 emissions would result in different ratios. Second, it is not clear what emission le vel to use in the concentration per emissions sensitivity ratio. For SO x , the District uses 2.97 tpy, the average of the 1.337 and 4.598 tpy for the “12-Ke” and “Kern” areas of infl uence, respectively. See ratio spreadsheet. The average may be reasonable to use within the c onfines of the approach, but for a given set of conditions, either of the two tons/year ratios might be more appropriate, with the result that the sensitivity, and the overall interpo llutant ratio, could vary by a factor of about 3.5. It is not clear how any of these ratios relates to actual sensitivity of ambient PM 2.5 to emissions changes. EPA does not believe that the approach used by CARB and the Distri ct is adequate for determining interpollutant equi valency ratios. This issue woul d be better explored with a photochemical model.

5. Effect of Inventory Changes on the Air Quality Modeling and Attainment Demonstrations As discussed above in section V.A., CARB has recently updated the inventories for several mobile source categories for both the base and future years as well as revised the economic forecasts on which the future invent ories were based. Ideally, new attainment demonstration modeling would be performed to evaluate the effect of these updates and

14 See document “Atmospheric Interpollutant Equivalency between Direct Particulate Emissions and Secondary Particulate Formed from Gaseous Sulfur Oxide Emissions” (SJV SOx PM2.5 ratio final2.doc), spreadsheet “Interpollutant Calculation” (SJV SOX PM2.5 ratio.xls), and letter from David Warner, San Joaquin Valley Air Pollution Control District to Mr. Joseph Douglas, California Energy Commission, May 27, 2009, Attachment II, “Interpollutant Offset Ratio Explanation” (SJVAPCD_AEP_IP_Ratio_20090527.pdf).TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 48 revisions; however, remodeling is a substantial undertaking and would not necessarily change the basic conclusions of the existing attainment demonstration analysis. Relative to emissions in the Plan, the decrea ses in the base year 2005 emissions inventory due to the inventory updates are about 6 percent for NO x and 5 percent for direct PM 2.5 emissions; the 2014 attainment year target em issions levels are unchanged. See Table B-2. Emissions decreases in the base ye ar tend to reduce the relative e ffect of controls and increase the projected PM 2.5 concentrations in the attainment year. We now know that base year emissions estimates were slightly too high, yet th e model matched the observed concentrations in that year. With those higher emissions, the base year modeling should have predicted higher concentrations. The model, therefore, has a tend ency to predict slightly lower concentrations than it should. To compensate for this model under-prediction, the pred icted attainment year concentration should be slightly higher than shown in the Plan. Using model sensitivity results provided by CARB (Table B-3), EPA estimates that predicted ambient concentrations would be higher by only about 2.5 percent due to the emi ssion inventory revisions , and predicted design values still attain the NAAQS. See Table B-4. EP A therefore concludes that the attainment demonstration remains valid, despite the emission inventory changes.

Table B-2 

### Changes to Base Year and Attain ment Year Emissions Levels (tons per annual average day)

2005 Base Year 2014 Attainment Year

NO x Direct PM 2.5 NO x Direct PM 2.5
Unrevised from 2008 Plan 575.4 86.0 291.2 63.3
Revised from Progress Report 540 82 291.2 63.3
Change -35.4 -4.0 0.0 0.0
Percent change -6.2% -4.7% 0.0% 0.0%

Notes: 1. Unrevised 2005 base year emissions from: 2008 PM 2.5 Plan App. B Table B-3 at p. B-11, and Table B-2 at p.B-7 2. Unrevised 2014 attainment year emissions from: 2008 PM 2.5 Plan, Table 8-1 3. Revised 2005 base year from: Progress Report supplement, Attachment 1 4. 2014 Progress Report emissions are same as Plan: emission target did not change.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 49 Table B-3 

### Effect on Modeling of Base Year Emissions Changes

Site Plan Modeled

2014 Design Value 2014 DV with 10% Additional Reductions Concentration Change

Per % Emission Change Due to Base Year Emission Changes Total

NO x Direct PM 2.5 NO x Direct PM 2.5 NO x Direct PM 2.5 Site 1(BakersfieldCalifornia) 14.3 14.1 13.6 0.02 0.07 -0.12 -0.33 -0.45

Site 2 (Bakersfield-Planz) 14.7 14.6 14 0.01 0.07 -0.06 -0.33 -0.39

Site 3(BakersfieldGolden) 14.4 14.2 13.7 0.02 0.07 -0.12 -0.33 -0.45

Notes: 1. Plan modeled design value and design value with additional reductions are from 2011 Progress Report supplement, Attachment 3 2. Total concentration change assumes that changes due to the individual pollutants can be added to get total change; this assumption is acceptable to 1st order

Table B-4 

### Effect on Attainment Year Design Va lue of Base Year Emissions Changes

Site Measured 2006 Design Value Fractional Effect on Design Value Percent effect on Design

Value Plan Modeled 2014 Design Value Scaled 2014 Design Value

Site 1(BakersfieldCalifornia) 18.5 1.025 2.5% 14.3 14.7

Site 2 (Bakersfield-Planz) 18.9 1.021 2.1% 14.7 15.0

Site 3(BakersfieldGolden) 18.6 1.025 2.5% 14.4 14.8

Notes: 1. Fractional effect of emissions changes revising base year emissions DOWN translates to scaling UP attainment year PM 2.5 ; the measured base year concentration was caused by emissions being lower than previously thought; effect is to make it harder to atta in. Fractional effect was calculated as the reciprocal of (2006 DV plus Total emissions change, divided by 2006 DV) 2. Effect would be reversed for emissions revisions in ta rget year, but no effect in this case since target emissions are unchanged.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 50 

### C. PM 2.5 

### Attainment Plan Precursors

1. Requirements for the Control of PM 2.5 Precursors EPA recognizes NO x , SO 2 , VOC, and ammonia as the main precursor gases associated with the formation of secondary PM 2.5 in the ambient air. Thes e gas-phase precursors undergo chemical reactions in the atmosphere to form secondary particulate matter. Formation of secondary PM 2.5 depends on numerous factors including th e concentrations of precursors; the concentrations of other gaseous reactive sp ecies; atmospheric c onditions including solar radiation, temperature, a nd relative humidity; and the interac tions of precursors with preexisting particles and with cloud or f og droplets. 72 FR 20586 at 20589. As discussed previously, states must include submit emissions inventories for each of the four PM 2.5 precursor gases in order to assure the info rmation on all pollutants and precursors that contribute to PM 2.5 concentrations is availabl e. 72 FR 20586 at 20589 and 40 CFR § 51.1008(a)(1). However, the overall contri bution of different precursors to PM 2.5 formation, and the effectiveness of alternative potential c ontrol measures will vary by location. Thus the precursors a state should re gulate for attaining the PM 2.5 NAAQS will also vary to some extent from area to area. 72 FR 20586 at 20589.

In the PM 2.5 implementation rule, EPA did not ma ke a finding that all potential PM 2.5 precursors must be controlled in each sp ecific nonattainment area. See 72 FR 20586 at 20589. Instead, for reasons explained in the rule, a state must evaluate control measures for sources of SO 2 in addition to sources of direct PM 2.5 in all nonattainment area s. 40 CFR § 51.1002(c) and (c)(1). A state must also evaluate control measures for sources of NO x unless the state and/or EPA determine that control of NO x emissions would not significantly reduce PM 2.5 concentrations in the specific nonattainment ar ea. 40 CFR § 51.1002(c)(2). By contrast, EPA has determined in the PM 2.5 implementation rule that states do not need to address controls for sources of VOC and ammonia unles s the state and/or EPA make a technical demonstration that such controls would significan tly contribute to reducing PM 2.5 concentrations in the nonattainment area. 40 CFR § 51.1002(c)(3) and (4). Such a demonstration is required “if the administrative record related to development of its SIP shows that the presumption is not technically justified for that area.” 40 CFR § 51.1002(c)(5). Significant contributor in this context means that a significant reduc tion in emissions of the precursor from sources in the area would be projected to provide a significant reduction in PM 2.5 concentrations in the nonattainment area. 72 FR 20586 at 20590. Although EPA did not establish a quantitative test for determining th e significance of such a change, EPA noted that even relatively small reductions in PM 2.5 levels are estimated to result in worthwhile public health benefits. Id. EPA further explained that a technical dem onstration to reverse the presumption for NO x , VOC, or NH 3 in any area could consider the emissi ons inventory, specia tion data, modeling information, or other special studies such as such as monitoring of additional compounds, receptor modeling, or special monitoring stud ies. 72 FR 20586 at 20596-20597. These factors could indicate that the emissions or ambient c oncentration contribution of a precursor, or the sensitivity of ambient concentrations to change s in precursor emissions, differs in the specific nonattainment area from the presump tion for that precursor in the PM 2.5 implementation rule.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 51 2. Identification of PM 2.5 Attainment Plan Precursors in the SJV 2008 PM 2.5 Plan and EPA’s Evaluation

The 2008 PM 2.5 Plan does not explicitly identify the pollutants that have been selected as PM 2.5 attainment plan precursors as this term is defined in 40 CFR § 51.1000. The Plan addresses only NO x and SO 2 in the RFP and attainment demonstr ations and the District’s RACM/RACT analysis and thereby implicitly identifies NO x and SO 2 , but not VOC and ammonia, as attainment plan precursors. It does include suppor ting documentation for the inclusion of NO x as an attainment plan precursor and for the exclus ion of ammonia. As discussed below, it has conflicting information about the impact of controlling VOC as a precursor for PM 2.5 attainment. However, supplemental information provided by CARB makes clear that the State does not consider VOC to be a PM 2.5 attainment plan precursor and provides supporting documentation for that position. Precursor relationships are discussed in the Plan’s “Executive Summary”, Chapter 3 “What is Needed to Demonstrate Attainment?”, Ch apter 7 “Local, State, and Federal Controls”, Chapter 8 “Reasonable Further Progress”, Appendix F “SJV PM 2.5 SIP Modeling Protocol”, Appendix G “Regional Air Qualit y Modeling”, Appendix J “Comme nts and Responses”, and the additional appendix “2014 Receptor Modeling Docu mentation” (“RMD”). The most detailed discussion is in Appendix F, p. F-53 ff

, with the main points repeated in Chapter 3, p. 3-8 ff

. The RMD presents additional evidence regarding prec ursors. Finally, supplemental information on VOC is presented in a CARB comment letter on EPA’s original proposal. See letter, James Goldstene, CARB, to Frances Wicher, EPA, January 31, 2011, attachment 4 (CARB VOC supplement). As mentioned above, ambient contribution and ambient sensitivity to emissions changes may both be considered in determining whether th e presumption for an attainment plan precursor should be reversed. The 2008 PM 2.5 Plan contains numerous quali tative statements that San Joaquin Valley’s ambient PM 2.5 is dominated by a mmonium nitrate (NH 4 NO 3 ), and that NO x reductions are more effective at reducing ambient PM 2.5 than reductions in the other precursors. Most of those statements are in Chapter 3 and Appendix F and are based on excerpts of findings from CRPAQS. Several of the excerpted and c ited CRPAQS documents are available at CARB’s “Central California Air Quality Studies” web site at http:// www.arb.ca.gov/airways.

For ambient contributions of precursors to the 24-hour PM 2.5 NAAQS, the Plan contains qualitative descriptions but no quantitative data , although it does refer to “CRPAQS data for the year 2000 is available at the ARB we bsite http://www.arb.ca.gov/airways”. 2008 PM 2.5 Plan, p. F-59

For the annual and 24-hour PM 2.5 NAAQS, the Plan contains some qualitative description of precursor ambient contribution. For example, it states on p. 2-8 that annual concentrations are driven by wintertime concentrations, and further, that the highest short te rm concentrations are driven by ammonium nitrate, as found in the CRPAQS:

For most of the sites within the SJV, 50–75% of the annual average PM 2.5 concentration could be attributed to a high PM 2.5 period occurring fromTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 52 November to January. At non-ur ban sites, the elevated PM 2.5 was driven by secondary NH 4 NO 3
. 15

There is also quantitative data in Appendi x G, Table 2. “Percent Composition Ratio Based on 2000 Average CRPAQS Data” (p. G-21), using measurements from the Speciation Trends Network (STN). The RMD also has projec ted 2014 species composition in data tables (at RMD pp. 1 - 70) and pie charts (at RMD pp. 71 -28) , based on various adjustments to Chemical Mass Balance (CMB) and Positive Matrix Factor ization (PMF) modeling results. Ammonium nitrate for 2000 monitored data rang es from 24-36 percent of total PM 2.5 , and if projected to 2014 ranges from 36-51 percent, co nfirming the importance of NO x , one source of nitrate, as a precursor that significantly contributes to annual PM 2.5 levels in the SJV. In addition to composition data, ambient sensit ivity to emissions changes can also be a consideration in determining which species shou ld be regulated in the SIP for an area as attainment plan precursors. For ammonium nitrate PM 2.5 , which is formed from both ammonia and NO x , a key issue is the effectiveness of emissions reductions of either or both precursors at reducing PM 2.5 concentrations. Among the findings cited by the Plan that address this issue are:

“Particulate NH 4 NO 3 concentrations are limited by the rate of HNO 3 formation, rather than by the availability of NH 3 ”

and “Comparisons of ammonia and nitric aci d concentrations show that ammonia is far more abundant than nitric acid, which indicates that ammonium nitrate formation is limited by the availability of nitric acid, rather than ammonia.... This study's analyses suggest that reductions in NO x emissions will be more effective in reducing secondary ammoni um nitrate aerosol concentr ations than reductions in ammonia emissions. Reductions in VOC emissions will reduce secondary organic aerosol concentra tions and may reduce ammoni um nitrate.... The results indicate ammonium nitrate formati on is ultimately controlled by NO x emission rates and the other species, includi ng VOCs and background oz one, which control the rate of NO x oxidation in winter, rather than by ammonia emissions.

2008 PM 2.5 Plan p. 3-10.

These findings are based on the relative amount s of ammonia and nitrate: there is so much ammonia present that even substantial redu ctions of ammonia emi ssions would still leave ample ammonia for forming ammonium nitrate. On the other hand, NO x is scarce (relative to ammonia), so reducing it will redu ce ammonium nitrate significantly. Finally, sensitivity results from photochemical modeling were used in conjunction with the CMB results mentioned above, though it is no t clear which particular modeling was used. The 2008 PM 2.5 Plan states at p. 3-15:

15 Quote from “Initial Data Analysis of Field Program Measurements,” DRI Document No. 2497, July 29, 2005; Judith C. Chow, L..W. Antony Chen, Douglas H. Lowenthal, Prakash Doraiswamy, Kihong Park, Steven D. Kohl, Dana L. Trimble, John G. Watson, Desert Research Institute.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 53 The first regional assessment used th e Urban Airshed Model, modified to address aerosol chemistry (UAM-AERO). This assessment used the IMS-95 dataset (an early component of CRPAQS) to evaluate a monitore d event of nitrate particulate formation. Regional modeli ng was also conducted for the later 2000- 2001 CRPAQS data, providing an update to the PM 10 receptor modeling projections in 2006. A third round of re gional modeling with the Community Multiscale Air Quality (CMAQ) model ha s been completed by CARB.... If this provides a different regional photochemistry analysis for nitrate formation, the receptor modeling estimates for nitrates will be reviewed.

The RMD section on “Review of control st rategy effectiveness supported by CMAQ nitrate particulate eval uation” shows the projected result of a 50 percent reduction in NO x emissions on the annual PM 2.5 concentration and on PM 2.5 concentrations in shorter episodes in several seasons. For the a nnual concentration, the NO x reduction gave a predicted 5 μg/m 3 PM 2.5 reduction, while for the winter episod e the predicted reduction was 28 μg/m 3 for the 24-hour period RMD, p. 80. A similar evaluation is also d one for to analyze the effect of a 50 percent reduction in ammonia emi ssions: the corresponding PM 2.5 predicted reductions for annual and winter were only 0.1 μg/m 3 and 0.3 μg/m 3 , respectively. See RMD, p. 81. When compared to the annual and 24-hour NAAQS of 15 and 65 μg/m 3 , respectively, the effect of NO x reductions appear to be significant while the effect of ammonia reductio ns do not. Thus the data and modeling results presented in the 2008 PM 2.5 Plan, as well as the resu lts of the cited studies, support the identification of NO x as an attainment plan precurso r, and the exclusion of ammonia, consistent with the EPA presumption in the PM 2.5 implementation rule. As to VOC, EPA presumption in the PM 2.5 implementation rule is that VOC need not be an attainment plan precursor. See 40 CFR § 51. 1002(c)(3). As explained in the preamble to the rule, however, this presumption ma y not be technically justified for a particular nonattainment
area, i.e., this presumption may be incorrect where em issions of VOC significa ntly contribute to PM 2.5 concentrations in the nonattainment ar ea. 72 FR 20586 at 20590-93, 20596-97. States or EPA may conduct a technical demons tration to reverse the presum ptive exclusion of VOC as a PM 2.5 attainment plan precursor based on the wei ght of evidence of available technical and scientific information. Id.

The 2008 PM 2.5 Plan contains conflicting info rmation on whether, for the SJV nonattainment area, VOC should be considered as a potential PM 2.5 attainment plan precursor. Several passages suggest that it should be. On an annual basis, Table 2 in Appendix G (p. G-21) gives an organic carbon range of 38-49 percent of the total PM 2.5 . This organic PM 2.5 can be further divided into vegetative burni ng (9-19 percent of total annual PM 2.5 ), direct VOC PM 2.5 emissions (also 9-19 per cent of total annual PM 2.5 ), and secondary organi c aerosols (2-5 percent of total annual PM 2.5 ). RMD, p. 19. This SOA contribution to overall PM 2.5 levels appears to be non-negligible. The Plan states: “Secondary organic aerosols (S OA) contribute to a si gnificant fraction of PM 2.5 . SOA is organic carbon particulate fo rmed in the photochemical oxidation of anthropogenic and biogenic VOC precursor gase s. Aromatic compounds are believed to be efficient SOA producers contributing to this secondary particulate.” 2008 PM 2.5 Plan, p.3-8. On a 24-hour episodic basis, the contribution of SOA c ould be higher than the annual 2-5 percent, though it is likely lower for the winter episodes of most concern in the SJV, due to decreasedTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 54 photochemical activity when fog an d clouds partially block sunli ght. The chemistry of SOA is less well understood than the chemistry of other ch emical species, so overal l these considerations are not enough to overcome the negative presumption for VOC. But as noted in the preamble to the PM 2.5 implementation rule at pp. 20592 - 20593, the lightest organic molecules can pa rticipate in atmospheric chemistry processes resulting in the formation of ozone and certai n free radical compounds (such as the hydroxyl radical [OH]) which in turn participate in oxidation reactions to form secondary organic aerosols, sulfates, and nitrates. That is, VOC may be a PM 2.5 precursor not just via forma tion of SOA, but also via its participation in the oxidant chemistry that lead s to nitrate formation, a necessary step in the formation of ammonium nitrate PM 2.5 . NO x emissions must be oxidi zed to nitric acid (HNO 3 ) before they form particulate ammonium nitrate. Two pathways for this to occur are 1) daytime oxidation by OH, which VOC radicals help creat e, and 2) nighttime oxidation by ozone, with N 2 O 5 as an intermediary. 16

The discussion in the 2008 PM 2.5 Plan regarding ammonium nitrate (at p. 3-10, quoted above) also refers to VOC, which is identifie d as one of the cont rolling factors in NO x oxidation, the key process in the formation of nitrate and then ammonium nitrate PM 2.5 . The Plan also stated: “Relatively low non-meth ane organic compounds (NMOC)/NO x ratios indicate the daytime photochemistry is VOC, sunlight, and background-ozone limited in winter.” Id . If nitrate formation is VOC-limited under some circumstances , then VOC emissions reductions could lead to ambient PM 2.5 reductions. Finally, the RMD at page 82 c ontains sensitivity analyses for VOC, similar to the ones described above for NO x and ammonia. According to the sensitivity analysis, the effect of a 50 percent reduction in VOC emissions was predicted reductions in PM 2.5 levels of 1.3 μg/m 3 for on annual basis, and 8.7 μg/m 3 for the (24-hour) winter episode. When compared to the annual PM 2.5 NAAQS of 15 μg/m 3 and the 1997 24-hour NAAQS of 65 μg/m 3 , these projected reductions appear significant. The RMD conclude s with “Finding: VOC re duction is effective for the annual standard and the winter episode for reduction of total carbon secondary particulates.” In addition, NO x and VOC reductions may have a synergistic effect, such that the ambient PM 2.5 benefit would be more than expected from looki ng at the pollutants individually. We note that this effect could be explored with the CMAQ model, but the hybrid CMB-CMAQ approach used in the 2008 PM 2.5 Plan would not be suitab le for such evaluations. Despite the above portions of the Plan implica ting VOC as an attainment plan precursor, the Plan also contains statements explicitly re jecting that position. In response to comments on the VOC issue made during the District public comment period, the Plan stated: “ARB modeling has shown that VOC reductions are not as effective in reducing secondary PM 2.5 as NO x or SO 2 reductions,” and “[a]ll of the technical evaluations for CRPAQ S and prior assessments of regional particulate models have indicated that NO x is the dominant factor and VOC and ammonia are not.” 2008 PM 2.5 Plan, pp.J-9 and p. J-19. These statements do not cite the specific modeling and technical evaluations they are ba sed on, but do reflect the District’s conclusion after completing the analyses in the Plan, na mely that VOC should not be considered an attainment plan precursor. Supplemental in formation provided by CARB confirmed this conclusion: “VOC emission reductions are ineffective in reducing PM 2.5 at current ambient

16 Lurmann, F. et. al. , 2006, op cit. , p. 1688.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 55 concentrations in the San Joaquin Valley... VOC should not be consid ered a significant PM 2.5 precursor in this instance ”. CARB VOC supplement. p.1. As explained above, although EPA’s presumption in the PM 2.5 implementation rule is that VOC need not be a PM 2.5 attainment plan precursor, this presumption may not be technically justified for certain nonattainment areas. I ndeed, technical information in the 2008 PM 2.5 Plan strongly suggests that VOC reductions can significantly reduce ambient PM 2.5 concentrations and contribute to expeditious attainment of the PM 2.5 NAAQS in the SJV.

The above statements from the PM 2.5 Plan indicating VOC is a significant precursor may not constitute a technical demonstr ation sufficient to reverse the PM 2.5 implementation rule presumption against VOC. Clearly they were not intended as such by the State, in view of various other statements in the Plan. Neverthele ss, they are part of the administrative record related to development of the SIP, constitute evidence showing that the VOC presumption may not be technically justified, and indicate that the State should s ubmit a demonstration to either support or reverse the presumption under the PM 2.5 implementation rule that VOC is not an attainment plan precursor. 40 CFR §51.1002(c)(5). In view of conflicting statements about VOC in the Plan, and in the absence of a technical demonstration by the State, EPA reviewed the resu lts of several modeling and monitoring studies of the San Joaquin Valley. For this action EPA also reviewed interpretations of these same studies provided in the CARB VO C supplement. Some of the reviewed documents are available on the “Central California Air Qual ity Studies” web site at www.arb.ca.gov/airways or are cited in the Plan, and are reports from contractors involved in CRP AQS. Others are papers from peer-reviewed journals and are analyses using data from CRPAQS or from the earlier IMS95 study. Four monitoring studies and six modeli ng studies were found to be relevant to the VOC precursor issue and are discussed furthe r below. The monitoring studies all contain evidence that the VOC pathway for nitrate creation is important at least some of the time but differ on the how important it is relative to other pathways such as the nighttime ozone pathway, and are not conclusive on the efficacy of VOC c ontrols. Unlike the monitoring studies, most of the modeling studies explicitly assessed the relativ e effectiveness of precursor controls. They generally found that VOC controls coul d be effective at reducing ambient PM 2.5 for some times and places, though there were also findings of littl e benefit or even a disbenefit in some cases. The monitoring studies examined time series of various pollutants annually and during severe winter PM 2.5 episodes. The monitoring studies were not all aimed at assessing the relative effectiveness of precursor controls , and insofar as they addressed that issue, they focused more on the relative importance of ammonia and NO x controls, rather than on VOC versus. NO x controls. They nevertheless do contain some te ntative conclusions about VOC. The monitored relative abundances of precursors and other intermediate chemical species can yield information on the chemical processes occurring and thei r relative importance. For example, nitrate concentrations far below those of ammonia ar e evidence that the formation of particulate ammonium nitrate is limited by NO x emissions rather than by a mmonia emissions. (Lurmann et. al., 2006). The concentration of nitric acid (HNO 3 ) relative to peroxides suggests the prevalence of VOC-limited OH and nitrate formation rela tive to VOC-abundant conditions (Pun, 1998). The correspondence of daytime ozone and nitrate PM 2.5 peaks for rural sites is evidence that they are driven by a common process, daytime NO x oxidation via NO x and VOC-driven oxidant photochemistry (Pun, 2004). However, a later st udy concluded that this correspondence could also be explained by ozone transport or by daytim e entrainment of nighttime nitrate formed aloftTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 56 (Lurmann et. al., 2006). The Plan quoted this stu dy’s somewhat generic statement that “daytime photochemistry is VOC, sunlight, and backgroun d-ozone limited in winter”, but also its conclusion that “entrainment of aerosol nitrate formed aloft at night may explain the spatial homogeneity of nitrate in the San Joaquin Va lley”. Lurmann, F. et. al., p.1688, cited at 2008 PM 2.5 Plan p. 3-10; also cited on CARB VOC supplement, p.5. This study recognized the importance of the nighttime ozone pathway for nitrate formation leading to PM 2.5 , a pathway that is not directly affected by VOC emissions redu ctions. The monitoring studies provide evidence that VOC-limited processes contribute to PM 2.5 formation, but are not conclusive on the efficacy of VOC controls. By contrast, most of the six relevant mode ling studies did explicitly assess the relative effectiveness of precursor cont rols, though again they tended to emphasize ammonia more than VOC. One study did not directly ad dress the issue, but stated that background ozone was the most important oxidant, implying that VOC contro l would have little eff ect (Ying et. al., 2009). The CARB VOC supplement cited this study (p.5 ), and CARB has stated that CARB staff involved in the CRPAQS study shar e this view. See ftn 10. The ot her five studies explicitly evaluated precursor controls, simulating the PM 2.5 effect of 50 percent re ductions in emissions of NO x , ammonia, and VOC. The two earliest of thes e studies used photochemical box models; one found VOC control to be ineffec tive (Stockwell, 2000), while th e other found it effective (Pun and Seigneur, 2001). However, the CARB VOC supplement (p.6) noted that the Pun and Seigneur study used a doubled VOC inventory to improve model pe rformance, so that it should not be weighted too heavily in making conclusi ons about the effectiven ess of VOC reductions. The later three studies used more sophisticated photochemi cal grid models, and generally found VOC control to be effective, at least for some times and places, though generally less so than NO x control. One of the photochemical grid modeling studies predicted VOC control to be about 2/3 as effective as NO x control (17.5 percent benefit fr om VOC vs. 25 percent from NO x ), though VOC disbenefits occurred at some smaller reductions (Kleeman, Ying, and Kaduwela, 2005). In addition, in its VOC supplement, CA RB drew attention to various NO x vs. VOC isopleth diagrams in the study, which contain curves showing the PM 2.5 effect of various combinations of NO x and VOC reductions. The flat or upward-tilting curves show that for the more realistic situation of NO x and VOC reductions occurring simultane ously, VOC reductions show very little PM 2.5 benefit, and even a disbenefit at greater NO x reductions. CARB VOC supplement, Figs. 2 & 3, pp. 7-8, facsimiles of Figs. 3 & 5 in Kleeman, Ying, and Kaduwela, reproduced below. CARB suggests that the disben efit may occur because in this case a VOC reduction reduces VOC-nitrate chemical reactions that form organic ni trates such as PAN; by lessening this nitrate “sink”, VOC reductions leave more nitrate available to form PM 2.5 . CARB VOC supplement, p.7TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 57 24-hour NOx/VOC particulate isopleths, μg/m 3

Source: Kleeman, Ying, and Kaduwela, 2005, portion of Figures 3 and 5

A second study predicted VOC control to be effective, though only by a relatively small amount, at most 10 percent, or just for certain days (Pun, Balmori, and Seigneur, 2009). CARB pointed out that the days for which there is a VOC sensitivity are those with the highest PM 2.5 levels, which occur toward the end of the mode led episode, and that th is is likely due to a different chemical re gime during the high PM 2.5 days. An alternative, that the sensitivity is somehow a result of cumulative carryover of polluta nts during the seven day episode, is stated to be unlikely, since 1) a large VOC photochemical contribution to nitrate formation would be expected to be accompanied by a daily rapid ozon e increase that was not observed, and 2) there is little day-to-day carryover of reactive VOC or of VOC radical products such as OH and HO 2 (hydroxyl and hydroperoxyl). CARB VOC supplemen t, p.10. These statements are not supported by quantitative evidence, but in any case, it is apparent that there is something chemically different between the 12/25 – 12/28 period of th e 2000 episode, and the 12/28 – 12/31 period; there is significant sensitivity to VOC only to ward the end of the episode, when total PM 2.5 is about 80 μg/m 3 for Angiola, and about 100 μg/m 3 for Bakersfield. CARB VOC supplement, Fig.5, p.11, reproduced below. If the da ytime VOC-driven OH route for NO x oxidation to nitrate were important, VOC sensitivity would be expected throughout the whole episode, not just the latter half with the highest PM 2.5 concentrations.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 58 Time series with daily observations, base case simulation results and results from four sensitivity cases of nitrate and PM2.5 at Angiola and Bakersfield

Source: Pun, Balmori, and Seigneur, 2009, Fig. 2.

The importance of this lack of VOC sensitivity for lower PM 2.5 concentrations for assessment of VOC as a plan precursor is the CA RB point that “nitrate was only responsive to a 50 percent reduction in VOCs at PM 2.5 concentration levels that ar e no longer reached in the San Joaquin Valley... the Valley is now in a nitrate ch emical formation regime that is less responsive to VOC controls.” CARB VOC supplement, p. 10. This implies that th e study results are of limited relevance. According to monitoring data in EPA's AQS database, there were 172 PM 2.5 daily maximum values over 80 μg/m 3 during 1999-2002; by contrast, there were only 24 maxima over 80 μg/m 3 during 2007-2010. 17 The decreased frequency of hi gh values lends support to the CARB position, but does not imply the study results ar e irrelevant. It does appear, however, that there is complexity to PM 2.5 formation in the SJV that is not fully understood, and this study did not consider the more realis tic scenario of VOC and NO x reductions occurring together. The third grid modeling study predicted VOC cont rol to give slightly more benefit than NO x control (23 percent for VOC vs. 21 percent for NO x ) (Livingstone et. al., 2009). CARB pointed out that, of the various scenarios modeled in this study, the most realistic one showed a PM 2.5 benefit of only 12 percent from a 50 percen t VOC reduction, and a 38 percent benefit from a 50 percent NO x . CARB VOC supplement, p.9. While the models, assumptions, input data, a nd results differed betw een these studies, they provide evidence that c ontrol of VOC by itself can si gnificantly reduce ambient PM 2.5

17 EPA's Air Quality System, Violation Day Count Report, May 13, 2011.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 59 concentrations in the San Joaqui n Valley, at least for some times and locations. However, some studies show little benefit, or even a disb enefit from VOC controls. The only study that thoroughly explored the effect of simultaneous VOC and NO x reductions, a more realistic scenario given the control measures that are in place, showed a VOC disbenefit, especially for larger NO x reductions. There is some indication that VOC sensitivity is less important for more recent episodes, with lower PM 2.5 . Finally, there also appears to be a partial consensus in the latest work, and in the most important mon itoring study, that the nighttime ozone route for nitrate formation is more important than the VOC-sensitive daytime OH route. Altogether, the currently-available ev idence does not amount to a technical demonstration that VOC s hould be considered a PM 2.5 attainment plan precursor. Since there remains substantial uncertainty about the efficacy of VOC reductions, and even some danger of a disbenefit from additional VOC reductions, EPA believes that the PM 2.5 implementation rule presumption that VOC is not an PM 2.5 attainment plan precursor should remain in place for the time being.

It is unfortunate that th e only study that explored th e combined effect of NO x and VOC reductions predated CRPAQS, the most comprehensive PM 2.5 study for the SJV so far. It is also unfortunate that modeling tools such as process analysis were not used to investigate the change in chemical regime that a ppears to occur at higher PM 2.5 concentrations, and th e relative roles of the daytime and nighttime NO x oxidation routes. It would be highly desirable for future modeling efforts, such as for the attain ment demonstration needed for the new PM 2.5 standard, to explore precursor effectiveness more definitively.

Table C-1 

### San Joaquin Valley Modeling a nd Monitoring Study Findings on VOC as a Precursor for PM 2.5 Study and Basis Quotes from Study

Pun and Seigneur, 1998 monitored IMS95 data p. E-3 Since only a small fraction of NO x is converted to HNO 3 ... it was possible that the oxidation system was limited by the availability of oxidants. During wintertime, thes e oxidants may be sensitive to VOC rather than NO x . However, these inferences need to be confirmed. p. E-4 However, further research is need ed to understand the production of oxidants during the fall season a nd to assess the sensitivity of oxidants and HNO 3 to VOC and NO x precursors. p. 3-14 Typical concentrations of HNO 3 ... and H 2 O 2 ... suggest that theoxidant chemistry of the San Joaquin Valley may be in the VOCsensitive regime during the wi nter season. This result is preliminary...TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 60 Table C-1 

### San Joaquin Valley Modeling a nd Monitoring Study Findings on VOC as a Precursor for PM 2.5 Study and Basis Quotes from Study

Stockwell et al. , 2000

box model using 1997 emissions p. 4715 decreases in the VOC emission rate have little effect

Pun and Seigneur, 2001

box model on 3-day IMS95 episode, 4-6 January 1996 p. 2979 The concentration of particulate ma tter (PM) nitrate was found to be sensitive to reductions in VOC emissions. ... Oxidant chemistry in wintertime conditions in the San Joaquin Valley was shown to be VOC-sensitive. p. 2984 the production of secondary PM is greatly reduced when the VOC emissions are halved...
A 50% reduction of VOC emi ssions reduces peak OH and O 3 concentrations by as much as 20%. The resulting N 2 O 5 concentrations are more than proportionately reduced, and consequently, the rate of HNO 3 production by this pathway is considerably reduced. p. 2987 Our box model simulations point to the fact that PM formation in the SJV during winter is HNO 3 -sensitive, that HNO 3 formation is oxidant-sensitive, and that oxidant formation is sensitive to reductions in VOC emissions.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 61 Table C-1 

### San Joaquin Valley Modeling a nd Monitoring Study Findings on VOC as a Precursor for PM 2.5 Study and Basis Quotes from Study

Pun, 2004

monitored CRPAQS data p. 2 During winter, high concentrations of PM 2.5 and O 3 occur together in [rural] Angiola because daily peak concentrations for both species occur during the day on many days with high PM concentrations. The diurnal cycles of winter PM and O 3 at the urban sites [Fresno and Bakersfield] show a phase difference between these two pollutants. In Angiola, nitrate is the do minant component of winter PM 2.5 and the daytime peaks of PM 2.5 are caused by daytime peaks in PM 2.5 nitrate concentrations. Since day time conditions are comparatively less favorable for nitrate to partiti on into the particulate phase, peak concentrations during the 1 to 4 p.m. period are strongly indicative of a daytime chemical proce ss occurring at this site.
The difference in the nitrate diurna l profiles in Angiola and at the urban sites indicates that the domin ant processes contributing to the observed surface nitrate concentratio ns may be different at urban and rural sites. Transport from aloft was assumed by Watson and Chow (2004) to account for a morning increase in nitrate concentrations at the Fresno supersite. p. 31 There is some evidence that chemi cal production of n itrate occurs at the surface during the day. It is post ulated that the daytime chemical process for the production of nitrat e involves OH radicals or nitrate radicals, if it persists due to slow er photolysis during the wintertime. Reliable measurements of NO 2 and HNO 3 and additional measurements of nitrate radicals may be needed to evaluate the feasibility of the nitrate reaction.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 62 Table C-1 

### San Joaquin Valley Modeling a nd Monitoring Study Findings on VOC as a Precursor for PM 2.5 Study and Basis Quotes from Study

Kleeman, Ying, and Kaduwela, 2005

UCD/CIT model on 3- day IMS95 episode, 4-6 January 1996 p. 5325 A 50% reduction in NO x emissions applied to sources within the SJV reduced the predicted con centration of total nitrate by approximately 25% during the study episode.... A 50% reduction in VOC emissions lowered predicted co ncentrations of total nitrate by 17.5%, while a 50% reduction in NH 3 emissions lowered predicted concentrations of total nitrate by only 10%. p. 5332 at Fresno... VOC controls actually increase the amount of particulate nitrate produced by upwind sources under the conditions experienced on 6 January, 1996. p. 5332 at Kern Wildlife Refuge... The to tal concentratio n of nitrate increases slightly as VOC is scaled downward and then decreases with greater VOC reduction. ... A 50% reduction in VOC concentrations at Kern Wildlife Ref uge leads to a predicted decrease in particulate nitrate concentr ations of approximately 25–30% pp.5336-5338 a 50% reduction in NO x emissions reduces maximum particulate nitrate concentrations by approximately 12 μg/m 3 ...VOC and NH 3 emissions controls are not as effective as NO x controls for particulate nitrate... a 50% reduc tion in VOC emissions reduces ground level particulate nitrate concentrations by only 7 μg/m 3 ... a 50% NH 3 emissions reduction reduces ground level particulate nitrate concentrations by only 4 μg/m 3

McCarthy, 2005

monitored CRPAQS data p. 18 Daytime HNO 3 production rates are limited by sunlight, VOCs, and background ozone Nighttime HNO 3 production is limited by background ozone which is abundant aloft but not at the surfaceTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 63 Table C-1 

### San Joaquin Valley Modeling a nd Monitoring Study Findings on VOC as a Precursor for PM 2.5 Study and Basis Quotes from Study

Lurmann et al. , 2006

monitored CRPAQS data p. 1679 [“implications” sidebar] Reductions in VOC emissions will reduce secondary organic aerosol concentrations and most likely contribute to reductions in ammonium nitrate concentrations. p. 1688 The results indicate that ammonium nitrate formation is controlled by the formation of nitric acid and, therefore, ultimately controlled by NO x and VOC emission rates and background O3 concentrations that control the rate of NO x oxidation. This analysis is not able to assess the relative bene fits of controlling NO x or VOC emissions for reducing nitric acid levels. p. 1689 The average diurnal pattern of nitrate at Sierra Nevada Foothills is one that could be expected from photochemical activity, yet the afternoon nitrate peak at this site is more likely because of transport of pollution from the SJV than photochemistry. The average diurnal pattern for the three core sites in the SJV (Fresno, Bakersfield, and Angiola) suggests that the day time nitric acid production is relatively slow. p. 1690 Valley-wide nighttime production of ammonium nitrate aloft followed by daytime entrainment into the surface layer could explain the spatial homogeneity of wintertime ammonium nitrate levels in the SJV p. 1690 Continuous aerosol nitrate data , in conjunction with NO and O 3 data, suggest that both daytime and nighttime nitric acid formation pathways are active in the SJV. pp. 1690-1691 The CRPAQS data examined here tend to support the valley-wide nighttime production aloft hypothesis. p. 1692 Estimated secondary organic aero sol concentrations are small compared with concentrations of likely VOC precursors; however, the estimated secondary portion of PM 2.5 OC and PM 2.5 mass is significant in several locations.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 64 Table C-1 

### San Joaquin Valley Modeling a nd Monitoring Study Findings on VOC as a Precursor for PM 2.5 Study and Basis Quotes from Study

Pun, Balmori, and Seigneur, 2009

CMAQ–MADRID model on 1-week CRPAQS episode, 25-31 December 2000 p. 402 Nitrate was only weakly sensitive to reductions in anthropogenic VOC emissions. p. 402 A control strategy that focuses on NO x and PM emissions would be effective on average, but reductions in VOC and NH 3 emissions would also be bene ficial for certain times and locations. p.405 Reductions in anthropogenic VOC led to decreased O 3 concentrations at both urban and rural sites. However, there was virtually no effect on OM p. 408 The reduction in NO x emissions by 50% induced a strong response in nitrate concentrations. At the rural site, nitrate reductions approached 50% on average, and th e time series in Fig. 2 shows a consistent decrease throughout the episode. At Bakersfield, reductions were of the order of 30–45% and were less than linear. p. 408 As discussed previously, the reduction of anthropogenic VOC emissions reduced O 3 concentrations in both urban and rural locations. However, nitrate concentrations were less sensitive to anthropogenic VOC emissions than to NO x emissions on average. Reductions in anthropogenic VOC emissions consistently caused small reductions in nitrate in the urban areas, even when nitrate increases resulted from reductions in NO x emissions. Rural nitrate concentrations were quite inse nsitive to anthropogenic VOC emissions on some days. [Fig. 2 shows at most 10% reduction in PM 2.5 peaks at Angiola and Bakersfield.] p. 408 an effective control strategy for PM 2.5 in the SJV that is comprehensive in time and location may require controls of multiple precursors rather than a single key precursor.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 65 Table C-1 

### San Joaquin Valley Modeling a nd Monitoring Study Findings on VOC as a Precursor for PM 2.5 Study and Basis Quotes from Study
Ying, Lu, and Kleeman, 2009

UCD/CIT model on 3- week CRPAQS episode, 15 December 2000 to 7 January 2001 p. 424 The NO x is not immediately transformed into nitric acid/NH 3 nitrate due to slow photochemical reacti ons in the winter. Background ozone is the most important oxida nt for reactive nitrogen with gradual conversion of NO x to particulate nitrate over several days.

Livingstone et. al.
, 2009

CMAQ model on 3- week CRPAQS episode, 17 December 2000 to 7 January 2001 p. 5971 We found that emission reductions of NO x and AVOC [anthropogenic VOC] showed similar effects on percentage basis in different areas, and both are mo re effective than reducing NH 3 for abating elevated concentrations of accumulation mode PM in California Central Valley dur ing the winter episode. p. 5971 [excerpt from] Table 1. Model resu lts for ammonium nitrate at a Bakersfield station. Sensitivity of two-week average (ammonium + nitrate) to precursor reductions [precursor] [response] -50% NO x -21% PM 2.5 -50% AVOC -23% PM 2.5 -50% NH3 -8.8% PM 2.5 p. 5976 The fine aerosol concentration was more sensitive to AVOC than NO x in small areas around a Bakersfield station with high concentrations of accumulation mode PM

Notes: CRPAQS and IMS95 are described on the Ce ntral California Air Quality Studies web site, http://www.arb.ca.gov/airways /crpaqs/publications.htm CPAQS is the California Regional Particulate Air Quality Study, a field study conducted from December 1999 through February 2001. IMS95 is the 1995 Integrated Monitoring Study, a field study that included a four week winter sampling program in December 1995 and ear ly January 1996. Central California Air Quality Studies web site, CRPAQS Documents and Publications page: http://www.arb.ca.gov/airways /crpaqs/publications.htm
Studies cited in table are: Kleeman, M.K., Ying, Q., and Kaduwela, A., 2005, “Control strategies for the reduction of airborne particulate nitrate in California's San Joaquin Valley”, Atmospheric Environment, 39: 5325-5341 September 2005. doi:10.1016/j.atmosenv.2005.05.044TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 66 Livingstone, P.L., et. al., 2009, “Simulating PM Concen trations During a Winter Episode in a Subtropical Valley and Sensitivity Simulations and Evaluation me thods”, Atmospheric Envi ronment, 43: 5971-5977. doi:10.1016/j.atmosenv.2009.07.033 Lurmann, F.W., Brown, S.G., McCarthy, M.C., and Ro berts P.T., 2006, “Processes Influencing Secondary Aerosol Formation in the San Joaquin Valley During Winter”, Journal of the Air & Waste Management Association, 56: 1679-1693. McCarthy, M., 2005, “The Role of Nighttime Chemistry in Winter Ammonium Nitrate Formation in the San Joaquin Valley”, presented at the American Associati on for Aerosol Research (AAAR), Supersites Conference, February 2005, Atlanta, GA. Available on CRPAQS web page listed above; direct link: http://www.arb.ca.gov/a irways/Documents/AAAR/2005/m ccarthy_nitrate_ present.pdf Pun, B.K. and Seigneur, C., 1998, “Conceptual Model of Particulate Matter Pollution in the California San Joaquin Valley”, prepared by Atmospheric and Environm ental Research for Pacific Gas & Electric, Document Number CP045-1-98, 8 September 1998. Available on CRPAQS web page listed above; direct link: http://www.arb.ca.gov/airways/Doc uments/reports/sjvpmc~1.pdf Pun, B.K. and Seigneur, C., 2001, “Sensitivity of Par ticulate Matter Nitrate Formation to Precursor Emissions in the California San Joaquin Valley”, Environmental Science and Technology, 35: 2979-2987. doi: 10.1021/es0018973 Pun, B., 2004, “CRPAQS Task 2.7 When and Where Does High O 3 Correspond to High PM 2.5 ? How Much PM 2.5 Corresponds to Photochemical End Products?”, prepar ed by Atmospheric and Envi ronmental Research, Inc. for the San Joaquin Valleywide Air Pollution Study Agency. Available on CRPAQS web page listed above; direct link: http://www.arb.ca.gov/airways/crpaqs/workshop/AER2.pdf Pun, B.K., Balmori R.T.F, and Seigneur, C., 2009, “Modeling Wintertime Particulate Matter Formation in Central California”, Atmospheric Environment, 43: 402-409. doi: doi:10.1016/j.atmosenv.2008.08.040 Stockwell, W.R., Watson, J.G., Robinson, N.F., Steiner, W., and Sylte, W.W., 2000, “The Ammonium Nitrate Particle Equivalent of NO x Emissions for Continental Wintertime Conditions”, Atmospheric Environment, 34: 4711-4717. doi:10.1016/S1352-2310(00)00148-5 Ying, Q., Lu, J., and Kleeman, M., 2009, “Modeling air quality during the California Regional PM 10 /PM 2.5 Air Quality Study (CPRAQS) using the UCD/CIT source-orient ed air quality model - Part III. Regional source apportionment of secondary and total airborne particulate matter”, Atmospheric Environment, 43: 419-430, January 2009. doi:10.1016/j.atmosenv.2008.08.033.

3. Conclusions EPA proposes to concur with the evaluation in the 2008 PM 2.5 Plan that, at this time, ammonia does not need to be considered an attain ment plan precursor for purposes of attaining the 1997 PM 2.5 NAAQS. The information submitted by CARB raises legitimate questions about the extent to which VOC emissions contribute to ambient PM 2.5 concentrations in SJV and does not provide a basis for reversing the presumption that VOC is not an attainment plan precursor. Accordingly, EPA proposes to maintain the presumption that VOC is not an attainment plan precursor, in the absence of a clear technical demonstration that the presumption is incorrect. 18 We note that

18 In its approval of the SJV 2003 PM 10 plan, EPA determined that for the purposes of section 189(b)(1)(B) and (e) and in the absence of final data from CRPAQS, VOC does not contribute significantly to PM 10 levels which exceed the standards in the SJV. See 69 FR 30006, 30011 (May 26, 2004). In that determin ation, EPA relied on the criteria that VOC control was not shown to be absolutely necessary for PM 10 attainment and that it had a lower effectiveness than NO x control in reduction PM 10 . In addition, EPA noted in its 2004 final rule the District’s intention to re-examine the VOC issue when CRP AQS results were available. 69 FR 30010. Since its 2004 finding, EPA promulgated the PM 2.5 implementation rule, which has an explicit criterion for determining which PM 2.5 precursors must be evaluated for controls, na mely, that a significant change in emissionsTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 67 because the SJV is designated as nonattainment for the 8-hour ozone standard, this area is already required to adopt VOC control measur es for ozone purposes, which may provide a cobenefit for PM 2.5 concentrations. See 72 FR 20586 at 20593.

It should be noted that EPA’s concurrence on excluding ammonia and VOC as attainment plan precursors is limited to the attainment of the 1997 PM 2.5 NAAQS. EPA revised the 24-hour PM 2.5 standard in 2006 to lower it to 35 μg/m 3 and is currently reviewing both the annual and 24- hour standards to determine if they should be furt her lowered to protect public health. See EPA, Policy Assessment for the Review of the Partic ulate Matter NAAQS, Se cond External Review Draft, June 2010. Evaluation of ammonia and VOC controls for the attainment of the 2006 standard and any future lower standards may sh ow that such controls would significantly contribute to lower PM 2.5 levels in the Valley.

of the precursor would be projected to provide a significant change in PM 2.5 concentrations in the nonattainment area. See 72 FR 20586 at 20590 and 40 CFR § 51.1000. This is a different criterion than the one relied on in the 2004 determination. Data and analyses from CRPAQS have also become available.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 68 

### D. Reasonably Available Control Meas ures/Reasonably Available Control Technology

1. Requirements for RACM/RACT CAA section 172(c)(1) requires that each attainment plan “provide for the implementation of all reasonably available contro l measures as expediti ously as practicable (including such reductions in emissions from ex isting sources in the area as may be obtained through the adoption, at a minimum, of reasonabl y available control technology [RACT]), and shall provide for attainment of the national primary ambient air quality standards.” We interpret reasonably available control m easures (RACM) in CAA section 172(c)(1) as referring to measures of any type that may be a pplicable to a wide range of sources, whereas the parenthetical reference to reasonably available control technology (RACT) refers to measures applicable to stationary sources. Thus, RACT is a type of RACM specifically designed for stationary sources. 72 FR 20586at 20610. EPA defines RACM as any poten tial control measure for appl ication to point, area, onroad and non-road emission source categories that meets the following criteria: the control measure is (1) technologically feasible, (2) econo mically feasible, (3) doe s not cause “substantial widespread and long-term adverse impacts,” (4) is not “absurd, unenforceab le, or impracticable,” and (5) collectively can advance the attainment date by at l east one year. 72 FR 20586 at 20610. We define RACT as the lowest emission limitation that a particular stationary source is capable of meeting by the application of technology (i.e ., devices, systems, process modifications, or other apparatus or techniques that reduce air pollu tion) that is reasonably available considering technological and economic f easibility. 72 FR 20586 at 20610.

For PM 2.5 attainment plans, EPA is requiring a combined approach to RACM and RACT under subpart 1 of Part D of the CAA. Under th is approach, RACM/RACT are measures that a state finds are both reasonably available and contribute to atta inment as expeditiously as practicable in its nonattainme nt area. Thus, what cons titutes RACM/RACT in a PM 2.5 attainment plan is closely tied to that plan’s expeditious attainment demonstration. 40 CFR § 51.1010; 72 FR 20586 at 20612. By definition, measures that are neither necessary for meeting the RFP requirement nor helping an ar ea attain the NAAQS as expediti ously as practicable are not required RACM/RACT. A state’s atta inment plan must include a list of measures considered and information sufficient to show that a state ha s met all requirements for determination of RACM/RACT. 72 FR 20586 at 20612. A state must evaluate RACM/RACT for each identified PM 2.5 attainment plan precursor. Under this combined approach, EPA considers RACT be part of an area's overall RACM obligation. Subpart 1, unlike subparts 2 and 4 of title 1, Part D of the CAA, does not identify specific source categories for which EPA must i ssue control technology documents or guidelines for what constitutes RACT or identify specific source categories for state evaluation during attainment plan development. 72 FR 20586 at 20 610. Because of the variab le nature of the PM 2.5 problem between nonattainment areas, which may requi re states to develop attainment plans that address widely disparate circumstan ces, EPA determined that a state should have flexibility with respect to RACT and RACM controls but also that in areas needing significant emissions reductions to attain the standards, RACT/RACM controls on smaller sources may be necessary to reach attainment as expeditiously as practicable. 72 FR 20586 at 20612 at 20615.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 69 The determination of RACM/RACT is a three-step process: (1) identifying technologically and economically feasible meas ures and associated emissions reductions, (2) conducting air-quality modeling and related analyses, and (3) selecting RACM/RACT. 72 FR 20586 at 20613. Any measures that are nece ssary to meet these requirements which are not already either federally promul gated, part of the state’s SIP, or otherwise creditable in SIPs must be submitted in enforceable form as part of a state’s attainment plan for the area. 72 FR 20586 at 20614. The first step, identification of potential m easures, should be based on an inventory of emissions of direct PM 2.5 and PM 2.5 attainment plan precursors from the range of relevant sources and source categories. 72 FR 20586 at 20613. A state is requ ired to evaluate RACM/RACT for direct PM 2.5 and SO 2 . A state is also required to evaluate RACM/RACT for NO x sources unless it finds that such sources do not significantly contribute to the PM 2.5 levels in its area. 72 FR 20586 at 20613. Signifi cantly contribute in this c ontext means that a significant change in emissions of the precursor from sour ces in the area would be projected to provide a significant change in PM 2.5 concentrations in the area. 72 FR 20586 at 20590. In the preamble to the PM 2.5 implementation rule, EPA provided a recommended list of the types of source categories and control measur es that may be appropriate for evaluation given the local source mix and attainment need s of a specific area. 72 FR 20586 at 20621. Technological feasibility refers to whether there are ava ilable measures capable of reducing emissions of PM 2.5 or PM 2.5 precursors or both. A number of factors are considered in this analysis, such as proce ss and operating conditions, raw mate rials, physical plant layout, nonair quality and energy impacts, and the time need ed to install and operate controls. 72 FR 20586 at 20618. Economic feasibility refers to whether the cost of a measure is reasonable for the source or source category. A number of fact ors are considered in this anal ysis, such as cost per ton of pollution reduced, capital costs and annualized cost. 72 FR 20586 at 20619.

2. RACM/RACT Analysis in the SJV PM 2.5 SIP

The 2008 PM 2.5 Plan and the 2007 State Strategy are th e latest in a series of air quality plans that the District and CARB have developed to provide for attainment of the federal air quality standards in the SJV. 19 These planning efforts have resu lted in a comprehensive set of rules and programs that address the vast majority of emissions sources in the Valley. Many of these District and State rules are amo ng the most stringent in the nation.

For the 2008 PM 2.5 Plan and the 2007 State Strategy, the District, CARB, and the local agencies (through the SJV’s eight metropolitan planning organizations (MPO)) each undertook a process to identify and evaluate potential reas onably available control measures that could contribute to expeditious attainment of the PM 2.5 standards in the SJV. We describe each agency’s efforts below.

19 These plans include the 2003 PM 10 Plan (approved, 69 FR 30005 (May 26, 2004)), the 2004 Extreme Ozone Attainment Plan (approved 75 FR 10420 (March 8, 2010)), and the 2007 Ozone Plan (submitted November 16, 2007).TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 70 a. District RACM/RACT Analysis The District’s RACM/RACT analysis and its results are described in Chapter 6 and Appendix I of the 2008 PM 2.5 Plan. The analysis focused on controls for the categories of stationary and area sour ces under the District’s direct jurisdiction. To identify potential RACM/RACT, the Distri ct reviewed potential measures from a number of sources incl uding but not limited to:

• EPA’s list of potential PM 2.5 control measures (in the PM 2.5 implementation rule preamble);

• control strategies and measures from other districts and agencies , including the South Coast AQMD, Sacramento Metropolitan AQMD, Bay Area AQMD, and Ventura County APCD;

• further study measures in the SJV 2007 Ozone Plan;

• measures suggested by the public including those recommended by the International Sustainable Systems Research Center (ISSRC) in its draft document “Clearing the Air: A Path to Clean Air by 2017,” dated August 2007;

• recommendations from CARB’s 2003 audit of the District; and

• recommendations from the 2007 CARB staff repo rt, “Accelerating Attainment in the San Joaquin Valley” November 6, 2007.

2008 PM 2.5 Plan, pp. 6-6 to 6-8. The identified potential measures, as well as existing District meas ures, are described by emissions inventory category in Appendix I. Th ese measures address emissions of direct PM 2.5 , NO x and SO x . See 2008 PM 2.5 Plan, p. 6-8 and Appendix I. Po tential RACM/RACT controls for VOC or ammonia were not specif ically identified or evaluated. From this set of potential controls, the District developed a Stationary Source Regulatory Implementation Schedule (2008 PM 2.5 Plan, Table 6-2) which give s the schedule for regulatory adoption and implementation of the selected RACM/RACT measur es. See also Table F-1 of this TSD. The schedule was developed based on a variety of factors, including:

• technological feasibility and pr acticality of emission controls;

• magnitude of emissions from the source cate gory and likely emissions reductions (where possible to determine);

• cost, financial impacts, and potential fo r socioeconomic impacts (e.g., employment, profitability);

• District authority and enforceability of emissions reductions;

• rate and timing of emissions reductions;

• public acceptability, including interests a nd concerns of community members;

• pollutants reduced – NO x , PM 2.5 , VOC, SO x , or multiple pollutants;

• any potential adverse environmental impacts; and.

• potential for disparate environmenta l impacts (environmental justice).

2008 PM 2.5 Plan, p. 6-7.

The District also identified a number of sour ce categories for which feasibility studies to refine the inventory and evalua te potential controls would be done. These categories and theTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 71 schedule for studying them are gi ven in Table 6-4 of the 2008 PM 2.5 Plan and Table F-6 of this TSD. The Plan also includes descriptions of the Di strict’s incentive programs (which target onand off-road engine replacement with an emphasi s on diesel engines), it s innovative strategies program including its Fast Track emissions reduc tions measures, and public education efforts. See 2008 PM 2.5 Plan, pp. 6-13 to 6-23. See also, SJV PM 2.5 Progress Report, sections 2.3 and 2.4.

Since submittal of the 2008 PM 2.5 plan, the District has adop ted a number of measures intended to meet its commitments and provi de for the implementation of RACM/RACT.

b. Local Jurisdictions’ RACM Analysis The local jurisdictions’ RACM/RACT anal ysis was conducted by the SJV’s eight MPOs. 20 This analysis, which focused on potential NO x emissions reductions from transportation control measures (TCM) and builds on the wo rk done for the SJV 2007 Ozone Plan. TCMs are generally measures designed to reduce emissi ons from on-road moto r vehicles through reductions in vehicle miles travel ed or traffic congestion. The resu lts of the MPOs’ analysis are described in Chapter 7 of the 2008 PM 2.5 Plan. For the SJV 2007 Ozone Plan, the SJV MPOs developed a local RACM strategy which consisted of two parts: (1) evaluation of potential RACM for advancing the 8-hour ozone standard attainment date and (2) the adopti on of a Congestion Mitig ation and Air Quality (CMAQ) policy to fund cost-effectiv e emissions reductions projects.

For the 2008 PM 2.5 Plan, the MPOs reviewed and updated the evalua tion of potential RACM from the 2007 Ozone Plan fo llowing EPA’s guidance in the PM 2.5 implementation rule preamble. The evaluation is documented in the 2008 PM 2.5 Plan on pp. 7-8 to 7-11 and included the following steps: Step 1: Identification of poten tial new measures: The MPOs reviewed the measures in the 2007 Ozone Plan, EPA’s draft list of PM 2.5 measures (see 72 FR 20586 at 20621), and other SIPs including the South Coast 2007 AQMP and the Ne w Jersey 2007 SIP. No new measures were identified that had not already been considered in the 2007 Ozone Plan. Step 2: Calculation of the possible emissions reductions from potential TCM: Given the nature of the PM 2.5 problem in the SJV, the analysis focused on NO x to assess whether the reductions from these TCM could advance attain ment. It did not look at potential emissions reductions of direct PM 2.5 , SO x , VOC, or ammonia. In the 2007 Ozone Plan, emissions reductions estimates were calcula ted for the list of possible local TCM. The maximum feasible emissions reductions for NO x estimated from implementing all of these TCMs are approximately 7 tons per day (tpd) in 2020 and 5 tpd in 2023. 2008 PM 2.5 Plan, p. 7-10. These estimates are based on the maximum travel reductions that

20 These eight MPOs represent the eight counties in the San Joaquin Valley air basin: the San Joaquin Council of Governments, the Stanislaus Council of Govern ments, the Merced County As sociation of Governments, the Madera County Transportation Commission, the Council of Fresno County Governments, Kings County Association of Governments, the Tulare County Association of Governments and the Kern Council of Governments.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 72 could be expected from the applicable measur es and the average gram/mile emission rate of light-duty vehicles (i.e., passe nger cars and light-duty trucks ) operated during the summer.

These summer time estimates for NO x reductions for 2020 and 2023 needed to be adjusted to reflect 2013/2014. Due to the benefits of fleet turnover and increasingly stringent motor vehicle emission standards, the fleet average emission rates in 2020 and 2023 are projected to be lower than t hose in 2013/2014. This means the NO x reductions estimated in 2020 and 2023 underestimate the reductions that could be produced in earlier year s. Using a ratio of fleet average NO x emission rates for light-duty vehi cles in 2013 to 2020 (2.07), maximum reductions are estimated to produce a reducti on of roughly 14 tpd in 2013 (assuming the same level of travel reductions apply in 2013 as did in 2020 and 2023). 21 Unlike ozone levels which are higher in the summer time, PM 2.5 levels in the SJV are higher in the winter time. Because mobile source NO x emissions are higher in the summer than winter, NO x reductions for summer will be higher than for the winter. Thus, applying the reductions estimated for the summertime to the wintertime to evaluate whether the implemen tation of TCM would advance attainment in the SJV is conservative (i.e., over estimate the potential emissions reductions). 2008 PM 2.5 Plan, p. 7-10. Step 3: The emissions reductions estimates were compared against the attainment demonstration to determine if they collectively advance attainment by a full year. Using Table 9- 1 from the draft PM 2.5 plan, it was estimated that an additional 93.1 22 tons per average annual day of NO x emissions reductions would be necessary in 2013 to advance attainment of the PM 2.5 standard by one year which is considerable more than the estimated 14 tpd of potential NO x reductions from TCM. 2008 PM 2.5 Plan, p. 7-11. Based on the above analysis, the MPOs determ ined that there were no additional local RACM, beyond those measures al ready adopted, that would a dvance attainment of the PM 2.5 NAAQS in the SJV and thus no additional adoption of measures was necessary. 2008 PM 2.5 Plan, p. 7-11. The eight MPOs did adopt a CMAQ policy th at includes developing a standardized process across the Valley for distributing, be ginning in FY2011, 20 percent of the CMAQ funds to projects that meet a minimum cost-effectiven ess. This policy focuses on achieving the most cost-effective emissions reductions, while mainta ining flexibility to m eet local needs. 2008 PM 2.5 Plan, p. 7-8.

21 The methodologies and assumptions used to derive this number overstate the true potential reductions from reasonable TCMs in the SJV. For example, one assump tion used is that the effec tiveness of measures (e.g., transit improvements) will be the same in rural areas as they are in urban areas, even though TCMs are generally much less effective in rural areas. See Sierra Research, Reasonable Available Control Measure (RACM) Analysis
, March 5, 2007, pp. 2-3 (which may be found in Appendix C of the SJV 2007 Ozone Plan).

22 Calculated as the 2013 controlled level of emissions (394.3 tpd) minus the attainment level (291.2 tpd). Values from 2008 PM 2.5 Plan, Table 9-1. Based on the information in the 2011 Progress Report, this value would be 15.6 tpd after adjustments due to the r ecession and updated estimates of reductio ns from District’s adopted controls. See Table E-2 of this TSD.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 73 c. State’s RACM Analysis CARB describes its proposed strategy to reduce emissions from sources within its jurisdiction – on- and off-road engines and ve hicles, fuels, and consumer products –- in Chapter 3 of the 2007 State Strategy. Californi a has unique authority under the CAA to adopt standards for most categories of on- and off-road engines and vehi cles, subject in most instances only to a waiver by EPA under CAA section 209. CARB developed its proposed statewide stra tegy after an extens ive public consultation process to identify potential SIP measures . This process is described in the 2008 PM 2.5 Plan, p. 7- 11. It included a SIP Symposium in October 200 6 and a workshop in November 2006 to discuss development of potential cont rol concepts for meeting the federal 8-hour ozone and PM 2.5 standards. 23 CARB made available a draft of the 2 007 State Strategy for public review in April 2007 and then conducted a series of pub lic workshops on the draft. On April 26, 2007, CARB staff released a revised draft of the Proposed State Strategy that incorporated changes based on further staff analysis and pub lic comments. CARB Resolution 07-28, p. 3. From this process, CARB identified and committed to propose 15 new defined measures to address California’s ozone and PM 2.5 nonattainment problem. 2007 State Strategy, p. 65 and CARB Resolution 7-28, Attachment B, p. 8. Thes e measures focused on cleaning up the in-use (“legacy”) fleet as well as increasing the stri ngency of emissions standards for a number of engine categories and further reductions from motor vehicle fuels and consumer products. Many, if not most of these measures, were being propos ed and adopted for the first time anywhere in the nation. They built on CARB’s already comprehe nsive program to address emissions of direct PM 2.5 , NO x , VOC, and SO x from all types of mobile so urces, through both regulations and incentive programs, as well as from fuels a nd consumer products. See 2007 State Strategy, p. 38. Table D-1 lists these measures and includes one additional measure each from the California Bureau of Automotive Repair and the California Department of Pesticide Regulation. Table D-2 provides the list of these measures as updated in the 2011 Progress Report.

23 More information on this public process including presentations from the workshops and symposium that proceeded adoption of the 2007 State Strategy can be found at www.arb.ca.gov/planning/sip/2007sip/ 2007sip.htm.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 74 Table D-1 

### 2007 State Strategy Defined Measures Schedule for Consideration

Defined State Measure Expected Adoption Expected Implementation
Smog Check Improvements 2007-2008 By 2010

Expanded Vehicle Retirement 2008-2014 2008-2014

Modification to Reformulated Gasoline Program 2007 Phase-in starting 2010

Cleaner In-Use Heavy Duty Trucks 2008 2010-2015
Auxiliary Ship Cold Ironing and Clean Technologies 2007-2008 Phase-in starting 2010

Cleaner Main Ship Engines and Fuels Fuel: 2007 Engines: 2009 Fuel: 2007-2010 Engines: Phase-in starting 2010

Port Truck Modernization 2007-2008 2008-2020

Accelerated Introductio n of Cleaner LineHaul Locomotives (enforceable agreement) 2007-2008 Starting in 2012

Clean Up Existing Harbor Crafts 2007 2009-2018

Cleaner In-Use Off-Road Equi pment 2007 Phase-in starting 2008

Cleaner In-Use Agricultural E quipment 2009 Phase-in starting 2014

New Emissions Standards for Recreational Boats 2009-2010 2012-2013

Expanded Off-Road Recreational Vehicle Emissions Standards By 2010 2012-2015

Enhanced Vapor Recovery for Above Ground Storage Tanks 2007 Phase-in starting 2008

Additional Evaporative Emissions Standards By 2010 2010-2012

Consumer Products Program (I & II) 2007-2008
2010-2012 By 2010 By 2012-2014 Department of Pesticides Pesticide Regulation 2008 2008

Source: CARB Resolution 07-28, Attachment B, p. 8.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 75 Table D-2 

### Updated 2007 State Strategy: PM 2.5 

### SIP Measures

Defined State Measure Action

Smog Check Improvements 2007-2009

Expanded Vehicle Retirement 2007

Modification to Reformulated Gasoline Program 2007

Cleaner In-Use Heavy Duty Trucks 2007, 2008, 2010

Auxiliary Ship Cold Ironing and Clean Technologies 2007-2008

Cleaner Main Ship Engines and Fuels Fuel: 2008-2011 Engines: 2008
Port Truck Modernization 2007, 2008, 2010

Accelerated Introduction of Cleaner Line-Haul Locomotives (enforceable agreement) 2008

Clean Up Existing Harbor Crafts 2007, 2010

Cleaner In-Use Off-Road Equipment 2007, 2010

New Emissions Standards for Recreational Boats Expected 2013
Expanded Off-Road Recreational Vehicle Emissions Standards Expected 2013

Enhanced Vapor Recovery for Above Ground Storage Tanks 2008

Additional Evaporative Emissions Standards 2009 Expected 2013
Consumer Products Program (I & II) 2008, 2008, 2011

Department of Pesticides Pesticide Regulation 2008, 2009

Source: 2011 Progress Report, Table 1TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 76 3. November 2010 Proposed Action on the RACM/RACT Demonstration In November 2010, EPA proposed to disapprove the RACM/RACT dem onstration in the SJV 2008 PM 2.5 SIP based on our proposed disapproval of the attainment demonstration and proposed denial of California’s attainment da te extension request. We also proposed to disapprove the RACM/RACT demonstration becaus e it did not evaluate potential controls on VOC. See 2010 Draft TSD, sec tion II.D. and 75 FR 74518 at 74528. We noted in our proposed disapproval that is appeared that the Stat e, District, and local jurisdictions have identified a nd otherwise provided for the imp lementation of a comprehensive set of measures that are among the most stringent in the nation and should the District and State correct the deficiencies in the attainment demo nstration and appropriately address VOC as an attainment plan precursor in its RACM/RACT demonstration in the PM 2.5 Plan, we would be most likely be able to approve the SIP’s RACM/RACT demonstration. 75 FR 74518 at 74528.

4. Evaluation and Conclusions

Under the PM 2.5 implementation rule, RACM/RACT ar e the set of measures necessary for expeditious attainment. The measures must address emissions of direct PM 2.5 24 and all PM 2.5 attainment plan precursors that are necessary for expeditious a ttainment. Thus, in order for a PM 2.5 plan to demonstrate that it provides for RACM/RACT, it must also demonstrate that it provides for expeditious atta inment. 72 FR 20586 at 20612-20623.

As discussed in Sections II.E and G. of this TSD, we are proposing to grant California’s request to extent the attainment date fo r the SJV until April 5, 2014 and to approve the attainment demonstration in the 2008 PM 2.5 plan as providing for expeditious attainment of the 1997 PM 2.5 standards in the San Joaquin Valley by that date. As discussed in Section II.C. of this TSD, EP A proposes to concur w ith the evaluations in the 2008 PM 2.5 Plan and supplemental information pr ovided by CARB, at this time, ammonia and VOC do not need to be considered attainment plan precursors for purposes of attaining the 1997 PM 2.5 NAAQS in the SJV. Therefore, EPA is proposing to find that the 2008 PM 2.5 Plan, together with the 2007 State Strategy, provides for the implementation of all RACM/RACT necessary for expeditious attainment of the 1997 PM 2.5 standards in the San Joaquin Valley as required by CAA section 172(c)(1) and 40 CFR § 51.1010 and to approve the SJV PM 2.5 SIP’s RACM/RACT demonstration pursuant to these sections.

Petitions for consideration on provisions of the PM 2.5 Implementation Rule related to RACT: As discussed in section I.A.2.b., EPA received a petition for reconsideration of several provisions in the PM 2.5 implementation rule including thr ee provisions related to RACT. We describe each below and whether the provisions affect our proposed action on the RACM/RACT demonstration in the SJV 2008 PM 2.5 SIP:

24 Condensable PM 2.5 , which is considered direct PM 2.5 , did not need to be addressed in rules prior to January 1, 2011. 40 CFR § 51.1002(c).TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 77 1. The presumption that compliance with the Clea n Air Interstate Rule (CAIR) satisfies the NO x and SO 2 RACT requirements for electric generating units. 72 FR 20586 at 20623- 28. The SJV nonattainment area was not subjec t to the CAIR which was intended to control the interstate transport of pollu tants in the eastern United States. See 70 FR 25162 (May 12, 2005).

2. The allowance for states to defer establis hing emission limits for condensable PM (CPM) until January 1, 2011. 72 FR 20586 at 20652 (codified at 40 CFR § 51.1002(c)). EPA will evaluate any rule adopted or revi sed after January 1, 2011 to assure that it appropriately addresses CPM. 3. The revisions to the criteria for analyzi ng the economic feasibility of RACT from a presumption that a given source must bear a cost similar to other sources to a consideration of whether the cost of a measur e is reasonable for the regulated entity to bear, in light of benef its. 72 FR 20586 at 20619-20620.

While the 2008 PM 2.5 Plan includes some discu ssion of criteria for economic feasibility that seem to reflect the revised criteria in the PM 2.5 implementation rule (see pp. 6-2 and 6-7), we can find no example of wh ere those criteria act ually resulted in the rejection of a poten tial RACT measure.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 78 

### E. Attainment Date Extension

1. Requirements for Attainment Date Extensions CAA section 172(a)(2)(A) states that an area’ s attainment date “shall be the date by which attainment can be achieved as expeditiously as practicable, but no later than 5 years from the date such area was designated nonattainment ..., except that the Administrator may extend the attainment date to the extent the Administrato r determines appropriate, for a period no greater than 10 years from the date of designation as nonattainment considering the severity of nonattainment and the availability and feasibility of pollution control measures.” Because the initial PM 2.5 designations, including that for the SJV nona ttainment area, have an effective date of April 5, 2005, the initial attainment date for PM 2.5 areas is no later than April 5, 2010. For any areas that EPA grants the full 5-year attain ment date extension under section 172(a), the attainment date is no later than April 5, 2015.

Section 51.1004 of the PM 2.5 implementation rule addre sses the attainment date requirement. Section 51.1004(b) requir es a state to submit an attain ment demonstration justifying its proposed attainment date and indicates that EP A will approve an attainment date at the same we approve the attainment demonstration. Thus, our approval of an extended attainment date is dependent upon a demonstration sh owing expeditious attainment. A state that requests an exte nsion of the attainment date under CAA section 172(a)(2)(A) must provide sufficient information to show that attainment by the initial attainment date of April 5, 2010 is impracticable due the severity of the nonattainm ent problem in the area and the lack of available control measures. It must also demonstrate that all local control measures that are reasonably available and techno logically feasible for the area are being implemented to bring about expeditious attainment of the standard by th e alternative attainment date for the area. The state’s plan will need to proj ect the emissions reductions expected due to federal and state regulations and local measures such as RACT and RACM, and th en conduct modeling to project the level of air quality improvement in accordance with EPA’s modeling guidance. EPA will not grant an extension of the attainment date for an area beyond the initi al 5 years allowed by section 172(a)(2)(A) if the state has not consid ered the implementation of all RACM and RACT local control measures for the area. 72 FR 20586 at 20601.

2. Proposed Attainment Date in the SJV 2008 PM 2.5 Plan The expeditious attainment demonstration that supports the District’s proposed attainment date is found in Chapter 9 of the Pl an and summarized in Table E-1 below. This demonstration has been revised by the updated RFP demonstration in Appendix C of the 2011 Progress Report. See Table E-2 below. Based on this analysis for the annual sta ndard, the District and CARB requested an attainment date extension to April 5, 2015 for both the annual and 24-hour PM 2.5 standards. See SJVUAPCD Governing Board Resolution, p. 4 a nd CARB Resolution 08-28, p. 4. In its 2011 Progress Report, CARB continues to project Apri l 5, 2015 as the most expeditious attainment date in the SJV. See 2011 Progress Report, p. 1.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 79 Table E-1 

### Expeditious Attainment Dem onstration for the Annual PM 2.5 

### Standard in the San Joaquin Valley (tons per annual average day)

Year 2009 2010 2011 2012 2013 2014

Baseline NO x inventory 500.9 469.5 443.3 424.4 393.1 376.2

District commitment - 2.43 -3.24 -4.26 -8.56 -8.82 -8.97

CARB commitment N/A N/A N/A N/A N/A -76.0 Controlled inventory 498.5 466.3 439.0 415.8 384.3 291.2

NO x emissions level needed for PM 2.5 attainment 291.2 291.2 291.2 291.2 291.2 291.2

At attainment level? no no no no no yes

Baseline directed-emitted PM 2.5 inventory 79.8 79.0 77.9 77.0 75.9 75.0

District commitment -1.60 -2.96 -4.46 -6.69 -6.70 -6.70

CARB commitment N/A N/A N/A N/A N/A -5.0 Controlled inventory 78.2 76.0 73.4 70.3 69.2 63.3

Direct PM 2.5 emissions level needed for PM 2.5 attainment 63.3 63.3 63.3 63.3 63.3 63.3

At attainment level? no no no no no yes

Baseline SO 2 inventory 26.4 23.0 23.3 23.6 23.8 25.5

District commitment - 0.06 -0.11 -0.16 -0.92 -0.92 -0.92

CARB commitment N/A N/A N/A N/A N/A N/A Controlled inventory 26.3 22.9 23.1 22.7 22.9 24.6

SO 2 emissions level needed for PM 2.5 attainment 24.6 24.6 24.6 24.6 24.6 24.6

At attainment level? no yes yes yes yes yes

Overall annual PM 2.5 standard attainment? no no no no no yes

Projected attainment year/ attainment date 2014/April 5, 2015

Source: 2008 PM 2.5 Plan, Table 9-1. N/A: not applicable. CARB provided commitments to NO x and PM 2.5 reductions in 2014 only .TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 80 Table E-2 

### Revised Expeditious Attainment Demonstration for the Annual PM 2.5 

### Standard in the San Joaquin Valley (tons per annual average day)

Year 2009 2012 2013 2014
Baseline NO x inventory 500.9 424.4 393.1 376.2
District commitments/actual achieved 1 2.4 11.8 12.4 9.0

Adjustments to baseline 2 117.5 84.6 73.9 5 76 CARB commitment 3 N/A N/A N/A Controlled inventory 4 381 328 306.8 291
NO x emissions level needed for PM 2.5 attainment 291.2 291.2 291.2 291.2

At attainment level? no no no yes

Baseline direct PM 2.5 inventory 79.8 77.0 75.9 75.0
District commitments 1 1.6 6.7 6.7 6.7 Adjustments to baseline 2 5.2 1.3 2.0 5.0 CARB commitment 3 N/A N/A N/A Controlled inventory 4 73 69 67.2 63.3
Direct PM 2.5 emissions level needed for PM 2.5 attainment 63.3 63.3 63.3 63.3

At attainment level? no no no yes

Baseline SO 2 inventory 26.4 23.6 23.8 25.5
District commitments/actual reductions 1 0.1 3.5 3.6 3.6

Adjustments to baseline 2 3.3 0.1 0.3 0.5
CARB commitment 3 N/A N/A N/A N/A Controlled inventory 4 23.0 20 19.9 21.4 At attainment level? no yes yes yes

Overall annual PM 2.5 standard attainment? no no no yes
Projected attainment year/attainment date 2014/April 5, 2015

Source: 2008 PM 2.5 Plan, Table 9-1 and 2011 Progress Report, Appendix C, Table C-1. N/A: not applicable.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 81 1. Actual reductions from District rules (without regard to creditability) are used for 2009, 2012, and 2013 if they are higher than the commitment. The 2014 commitment level is used here instead of actual emissions reductions achieved because any excess reduc tions from the District’s measures count towards meeting CARB’s commitment and do not increase the overall emissions reductions. See note 3 below.

2. Calculated as baseline inventory minus controlled inventory and District commitment. No adjustments are made to the baseline to eliminate uncreditable reductions from Rule 9510.

3. 2007 State Strategy, p. 62. Accord ing to the 2007 State Strategy, actua l emissions decreases that occur in the San Joaquin Valley that are greater than those from adopted measures may be counted toward meeting CARB’s commitments (CARB Resolution 07-28, Attachme nt B, p. 3); therefore, adjustments to the baseline are counted towards meeti ng the State’s commitment. 2014 figures are CARB’s commitment as given on p. 21 of the 2009 State Strategy Update.

4. 2012 and 2014 numbers are from the 2011 Progress Report, Appendix C, Table C-1. 2013 PM 2.5 and NO x numbers are estimated from information in the 2011 Progress Report and additional information provided by the District, see SJVUAPCD, Tables 3-1 “Adjusted PM 2.5 Inventory” and Table 3-2 Adjusted NO x Inventory,” no date.

5. Calculated by averaging 2014 adjustments to baseline (63.1 tpd for NOx and 2.7 tpd for PM 2.5 , see Table F-7) and averaging this result with the adjustment to baseline for 2012. A similar calculation is done for PM 2.5 , and SO x .

The 2008 PM 2.5 Plan does not specifically addres s the most expeditious date for the attaining the 24-hour PM 2.5 standard. In reference to attainment of the 24-hour standard, the Plan
states: Attainment of the 24-hour 65 microgram sta ndard is projected to occur prior to 2014 and with fewer reductions required than are needed to attain the annual standard. This means that the annual standard iden tifies the amount of reductions needed to achieve attainment. CARB used the regional model to evaluate the top 25% of days modeled to provide the annual analysis . Based on design values for 2005, CARB projected a 2014 value of 45 micrograms or less at all sites. Due to conc erns that the last two years have experienced slightly higher 24- hour values, the Distri ct also performed a screening assessment with estimated design values for 2007 (based on incomplete and uncertified data). Evaluation by the Distri ct projected a 2014 value of 53 micrograms. Both of these projections are well below the 65 microgram standard and do not require a weight of evidence evaluation.

2008 PM 2.5 Plan, p. 3-32.

3. November 2010 Proposed Action on the Attainment Date Extension In 2010, we proposed to not grant the State’s requ est to extent the attainment date for the 1997 PM 2.5 standards in the SJV to April 5, 2015. Th is proposal was based primarily on our proposed disapproval of the RACM/RACT demons tration. See 75 FR 74518, 74534. As stated in preamble to the PM 2.5 implementation rule (72 FR 20586 at 20601), EPA cannot grant an extension of the attainment date beyond the initial five years pr ovided by secti on 172(a)(2)(A) if the state has not adequately considered and ev aluated the implementation of RACM and RACT in the area .We had proposed to disapprove th e RACM/RACT demonstration because of the issues with the air quality modeling and abse nce of analysis of VOC controls. We noted, however, that given th e severity of the PM 2.5 nonattainment problem in the SJV, an extension of the attainment date would most likely be appr opriate and approvable if it were supported by theTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 82 necessary analysis and part of an attainment plan that meet s the applicable statutory and regulatory requirements.

4. Evaluation and Conclusions SJV’s degree of PM 2.5 nonattainment can fairly be characterized as severe. The area typically records the highest ambient PM 2.5 levels in the nation, w ith 2008-2010 design value for the annual PM 2.5 levels in urban Bakersfield area of 21.2 μg/m 3 . See EPA, Air Quality Subsystem, Design Value Report, June 1, 2011. The PM 2.5 problem in the San Joaquin Valley is complex, caused by both direct and secondary PM 2.5 and compounded by the area’s topographical and meteorological conditions that ar e particularly conducive to the formation and concentration of PM 2.5 . See 2008 PM 2.5 Plan, Chapter 3. As discussed in section II.F. below, the Dist rict's and State’s stra tegy for attaining the PM 2.5 standard in the SJV relies on si gnificant reductions of direct PM 2.5 as well as the PM 2.5 precursor pollutants NO x and to a lesser degree SO x . The State and District have already adopted and are currently implementing a comprehensive set of PM 2.5 , NO x , and SO x control measures. We have proposed to find that these rules and programs provide for the implementation of RACM/RACT as required by CAA section 172(c)(1). See section II.D. above.

Reductions in direct PM 2.5 emissions are achieved primar ily from control measures on open burning, commercial charbroiling, resident ial wood combustion, and in-use trucks and buses. These types of control measures present sp ecial implementation challenges (e.g., the large number of individuals subject to regulation and the difficu lty of applying conventional technological control solu tions). Reductions in NO x emissions come largely from District rules for fuel combustion sources and from the St ate’s mobile source rules. Reductions in SO x emissions come primarily from controls on co mbustion sources and glass melting furnaces. Because of the necessity of obtaining addi tional emissions reductions from the more challenging-to-control so urce categories and the need to condu ct significant public outreach if applicable control approaches ar e to be effective, EPA agrees with the District and CARB that the 2008 PM 2.5 Plan reflects expeditious implementa tion of these controls during the 2008-2014 time frame. We also agree that the implement ation schedule for the District’s enhanced stationary source controls is e xpeditious, taking into account the ti me necessary for purchase and installation of the require d control technologies. Fina lly, we believe that it is not feasible at this time to accelerate the emissions reduction schedu le for the State and Federal mobile source control program which must rely on fleet turnover over the y ears to ultimately deliver the anticipated emissions reductions beyond what is already anticipated from the State’s in-use mobile source control and incentive programs. Given the severity of the PM 2.5 air quality in the SJV and adoption and expeditious implementation of all reasonably availa ble measures to reduce direct PM 2.5 and PM 2.5 precursors, we believe that the SJV PM 2.5 SIP provides for attainment of the 1997 PM 2.5 standards as expeditiously as practicable. EPA, therefore, is proposing to a grant California’s request for an attainment date extension to April 5, 2015 for the San Joaquin Valley pursuant to CAA section 172(b)(2).TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 83 

### F. Adopted Control Strate gy and Enforceable Commitments

1. Requirements for Control Strategies and Enforceable Commitments CAA section 172(c)(6) requires nonattainment plans to “inc lude enforceable emission limitations, and such other control measures , means or techniques (including economic incentives such as fees, marketable permits, a nd auctions of emission rights), as well as schedules and timetables for compliance, as may be necessary or appropriate to provide for attainment of such [NAAQS] in such ar ea by the applicable attainment date....” CAA section 110(a)(2)(A), which applies to all SIPs, contains virtua l identical language.

The PM 2.5 implementation rule requires all control measures needed for attainment be implemented as expeditiously as practicable but no later than the beginning of the year prior to the attainment date. 40 CFR § 51.1007(b). In most instances, a nonattainment plan shoul d include the adopted measures it relies on to demonstrate attainment and RFP and/or meet any other CAA requirement or should identify the adopted measures it relies on that are al ready SIP approved, fede rally promulgated, or otherwise SIP creditable. EPA, however, recognizes that circumstances ex ist that warrant the initial use of enforceable state commitments in place of these adopted measures. We believe that the CAA allows approval of such enforceable commitments as elements of a CAA control strategy requirement when they are limited in scope. The language in CAA sections 110(a)(2)(A) and 172(c)(6), given above, is quite broad, allowing a SIP to contain any “means or techniques” that EPA determines are “necessary or appropriate” to meet CAA requirements, such th at the area will attain as expeditiously as practicable, but no later than the applicable date. Furthermore, the express allowance for “schedules and timetables” demonstrates that Congress understood that al l required controls might not have to be in place before a SIP could be fully approved. Commitments approved by EPA under CAA section 110(k)(3 ) are enforceable by EPA and citizens under, respectively, CAA sections 113 and 304. In the past, EPA has approved enforceable commitments and courts have enforced actions against states that failed to comply with them. 25 Additionally, if a state fails to meet its commitments, EPA could make a finding of failure to implement the SIP under CAA section 179(a)(4), which starts an 18-month period for the state to correct the non-implementati on before mandatory sanctions are imposed. Once EPA determines that circumstances warrant use of an enforceable commitment, EPA considers three factors in determining wh ether to approve the enforceable commitment: (a) does the commitment address a limited portion of the statutorily-requi red program; (b) is the state capable of fulfilling its commitment; and (c) is the commitment for a reasonable and appropriate period of time. 26

25 See, e.g., American Lung Ass'n of N.J. v. Kean , 670 F. Supp. 1285 (D.N.J. 1987), aff'd, 871 F.2d 319 (3rd Cir. 1989); NRDC, Inc. v. N.Y. State Dept. of Env. Cons. , 668 F. Supp. 848 (S.D.N.Y. 1987); Citizens for a Better Env't v. Deukmejian , 731 F. Supp. 1448, recon. granted in par, 746 F. Supp. 976 (N.D. Cal. 1990); Coalition for Clean Air v. South Coast Air Quality Mgt. Dist. , No. CV 97-6916-HLH, (C.D. Cal. Aug. 27, 1999).

26 The U.S. Court of Appeal s for the Fifth Circuit upheld EPA's interpretation of CAA section 110(a)(2)(A) and 172(c)(6) and the Agency's use and application of the three factor test in approvingTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 84 2. Control Strategy in the SJV 2008 PM 2.5 Plan and Revised 2007 State Strategy For the purposes of evaluating the SJV 2008 PM 2.5 Plan and 2007 State Strategy, we have divided the measures relied on in the attainme nt and RFP demonstrations and to meet the RACM/RACT and contingency measures requireme nts into two categories: baseline measures and control strategy measures. As the term is used here, baseline measures are federal, State, and District rules and regulations adopted prior to December 2006 (i .e., prior to the development of 2008 PM 2.5 Plan and 2007 State Strategy) that continue to generate emissions reductions th rough to the attainment year of 2014 and beyond. 27 2007 State Strategy, Appendix A, p. 1 and 2008 PM 2.5 Plan, Appendix B, p. B-1. Reductions from these measures are incorporated into the baseline inventory and, for the most part, not individually quantifie d. These measures provide the majority of emissions reductions needed to attain the PM 2.5 standards in the SJV. See Table G-1 in this TSD. Control strategy measures are the new rule s, rule revisions, commitments, and other adjustments to the inventory that provide th e additional increment of emissions reductions needed beyond the baseline measures to dem onstrate RFP and attainment, meet RACM/RACT, and/or provide for contingency measures. We evaluate the control strategy measures in this section. Baseline measures are listed in the Appendices A and B to this TSD.

a. District Control Strategy Measures and Commitments

For the 2008 PM 2.5 Plan, the District identifie d and committed to adopting and implementing 13 new control measures for direct PM 2.5 , NO x , and/or SO x . In Table F-1 below, we list these measures, which mostly involve st rengthening existing District rules, along with their anticipated and actual adoption, final comp liance, and initial implementation dates. As can be seen from Table F-1, the District has mos tly met its rulemaking schedule and has only two rule actions remaining. In Table F-2 below, we list the expected emissions reductions from each measure as given in the 2008 PM 2.5 Plan; however, we note that the District’s commitment is only to the aggregate emissions reductions shown. See 2008 PM 2.5 Plan, p. 6-9 and SJVUAPCD Governing Board Resolution, p. 5. The reductions listed in Tabl e F-2 are those anticipat ed to be achievable from each rule at the time the 2008 PM 2.5 Plan was adopted. In Table F-3, we give the current SIP submittal and approval status of the measures in the Plan. In Table F-4, we show the emissions reductions, as updated in the SJV PM 2.5 Progress Report, for the measures that have been approved or proposed for approval by EPA. For a number of potential measures identif ied during the District’s RACM analysis, insignificant information was available to evaluate the feasibility of implementing them in the San Joaquin Valley. For these measures, the Di strict developed a schedule for performing

enforceable commitments in the Houston-Galveston ozone SIP. BCCA Appeal Group et al. v. EPA et al. , 355 F.3d 817 (5th Cir. 2003).

27 These measures are typically rules that have complia nce dates that occur after the adoption date of a plan and mobile source measures that generate reductions through fleet turnover.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 85 feasibility studies. See 2008 PM 2.5 Plan, page 6-13 and Table 6-4. Measures that are identified as being feasible through these studies will be includ ed in future plan updates with schedules and emissions reduction commitments. A list of these st udies, their anticipated completion dates, and their current status is given in Table F-6. Add itional information on these feasibility studies can be found in the SJV PM 2.5 Progress Report, Appendix C.TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 86Table F-1San Joaquin Valley Air Pollution Control District2008 PM2.5Plan Specific Rule CommitmentsMeasure Number & DescriptionDistrict RuleNumberRule MakingCompletionDateActualAdoptionDateComplianceDateActualComplianceDateYearReductionsStartActual YearReductionsStartS-AGR-1 Open Burning (Phase IV) 4103 2ndQ – 2010 April 2010 2010 June 2010 2009 2010S-COM-1 Advanced EmissionsReductions for Boilers, SteamGenerators and Process Heaters (> 5MMBtu/hr)4320 3rdQ – 2008 October 2008 2012July 2012 toJanuary 20142012 July 2011S-COM-2 Boilers, Steam Generatorsand Process Heaters(2 to 5 MMBtu/hr)4307 3rdQ – 2008 October 2008 2012July 2010 toJanuary 20162012 July 2010S-COM-3 Boilers, Steam Generatorsand Process Heaters (0.075 to < 2 MMBtu/hr)4308 4thQ – 2009December20092011 January 2011 2011 January 2011S-COM-5 Stationary Gas Turbines 4703 3rdQ – 2007September20072012 January 2012 2012 July 2009S-COM-6 Reciprocating InternalCombustion Engines4702 4thQ – 2010Anticipated:August 20112012 TBD 2012 TBDS-COM-7 Glass Melting Furnaces4354 3rdQ – 2008October 2008;RevisedSeptember20102009PM10& SOx–January 2011NOxlimits –January 2014-20182009PM10& SOx–June 2009NOxlimits –January 2011S-COM-9 Residential Water Heaters 4902 1stQ – 2009 March 2009 Attrition Attrition 2011 January 2010S-COM-10 Natural Gas-Fired, FanType Residential Central Furnaces4905 4thQ – 2014 N/A Attrition TBD 2015 TBDS-COM-141Wood Burning Fireplacesand Wood Burning Heaters4901 3rdQ – 2009October 2008 2010 2010 2010 2010S-IND-9 Commercial Charbroiling4692 2ndQ - 2009September20092011 January 2011 2011 January 2011TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 87Table F-1San Joaquin Valley Air Pollution Control District2008 PM2.5Plan Specific Rule CommitmentsMeasure Number & DescriptionDistrict RuleNumberRule MakingCompletionDateActualAdoptionDateComplianceDateActualComplianceDateYearReductionsStartActual YearReductionsStartS-IND-21 Flares 4311 2ndQ – 2009June 2009 2010 July 2011 2010 July 2011M-TRAN-1 Employer Based TripReduction Program9410 4thQ – 2009December20092012 January 2012 2012 January 2012Source: 2008 PM2.5Plan, Table 6-2, revised June 17, 2010. Anticipated adoption date for Rule 4702, SJVAPCD, District Highlights, June 16, 2011 Actions bythe District Governing Board.1Listed as S-COM-11 in Table 6-2 but as S-COM-14 elsewhere in the Plan.TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 88Table F-2San Joaquin Valley Air Pollution Control DistrictEstimated Emissions Reductions for 2008 PM2.5Plan Specific Rule Commitments Plan Assumptions(tons per average annual day)NOxEmissions Reductions2009 2010 2011 2012 2013 2014S-AGR-1 4103 - Open Burning (Phase III & IV) 1.21 1.95 2.68 2.67 2.66 2.65S-COM-1Rule 4320 - Advanced Emissions Reductionsfor Boilers, Steam Generators and ProcessHeaters (> 5 MMBtu/hr)0 0 0 1.49 1.50 1.52S-COM-34308 - Boilers, Steam Generators and ProcessHeaters (0.075to < 2 MMBtu/hr)0 0 0.12 0.27 0.39 0.55S-COM-5 4703 - Stationary Gas Turbines 0 0 0 2.21 2.21 2.21S-COM-7 4354 - Glass Melting Furnaces 1.22 1.25 1.18 1.60 1.67 1.58S-COM-9 4902 - Residential Water Heaters 0 0 0.20 0.25 0.32 0.40S-COM-144901 - WoodBurning Fireplaces and WoodBurning Heaters0 0.04 0.08 0.07 0.07 0.06Commitment to Total NOxReductions 2.43 3.24 4.26 8.56 8.82 8.97Direct PM2.5Emissions Reductions2009 2010 2011 2012 2013 2014S-AGR-1 4103 - Open Burning (Phase III & IV) 1.60 2.57 3.53 3.52 3.50 3.49S-COM-1Rule 4320 - Advanced Emissions Reductionsfor Boilers, Steam Generators and ProcessHeaters (> 5 MMBtu/hr)0 0 0 0.23 0.24 0.24S-COM-144901 - WoodBurning Fireplaces and WoodBurning Heaters0 0.39 0.76 0.73 0.71 0.69S-IND-9 4692 - Commercial Charbroiling 0 0 2.17 2.21 2.25 2.28Commitment to Total PM2.5Reductions 1.60 2.96 4.4616.69 6.70 6.70TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 89Table F-2San Joaquin Valley Air Pollution Control DistrictEstimated Emissions Reductions for 2008 PM2.5Plan Specific Rule Commitments Plan Assumptions(tons per average annual day)SOxEmissions Reductions2009 2010 2011 2012 2013 2014S-AGR-1 4103 – Open Burning (Phase III & IV) 0.0620.10 0.14 0.14 0.14 0.14S-COM-1Rule 4320 - Advanced Emissions Reductionsfor Boilers, Steam Generators and ProcessHeaters (> 5 MMBtu/hr0 0 0 0.76 0.76 0.76S-COM-144901 - WoodBurning Fireplaces and WoodBurning Heaters0 0.01 0.02 0.02 0.02 0.02M-TRAN-19410 – Employer Based Trip ReductionProgramsTBD TBD TBD TBD TBD TBDCommitment to Total SO2Reductions 0.06 0.11 0.16 0.92 0.92 0.92Source: 2008 PM2.5Plan, Table 6-31The value 4.46 is given on Table 6-3b in the 2008 PM2.5Plan. PM2.5reductions expected in 2011, however, sum to 6.46 tpd.2Value given as 0.03 tpd in Appendix I, page I-4.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 90 Table F-3 

### Approval and Submittal Status of SJVAPCD Rules in the 2008 PM 2.5 

### Plan

Rule Submittal and/or Approval Status Dates and Citations

Rule 4103 - Open Burning (Phase IV) Proposed for approval Proposal: proposed approval signed June 29, 2011 Most current revision of rule approved (Phase III): May 17, 2007 at 74 FR 57907 (November 10, 2009)
Rule 4307 - Boilers, Steam Generators and Process Heaters (2 to 5 MMBtu/hr) Approved 75 FR 1715 (January 13, 2010)

Rule 4308 - Boilers, Steam Generators and Process Heaters (0.075 to < 2 MM Btu/hr) Approved 76 FR 5276 (January 31, 2011)

Rule 4320 - Advanced Emissions Reductions for Boilers, Steam Generators and Process Heater s (> 5 MMBtu/hr) Approved 76 FR 16696 (March 25, 2011)

Rule 4703 - Stationary Gas Turbines Approved 74 FR 53888 (October 21, 2009)

Rule 4702 - Reciprocating Internal Combustion Engines (2010 revisions) Under development, Anticipated adoption: August 2011 Most current revision of rule approved: January 18, 2007 at 73 FR 1819 (January 10, 2008)

Rule 4354 - Glass Melting Furnaces Proposed for Approval Proposal: 76 FR 37044 (June 24, 2011) Most current revision of rule approved August 17, 2006 at 72 FR 41894 (August 1, 2007)
Rule 4902 - Residential Water Heaters Approved 75 FR 24408 (May 5, 2010)
Rule 4905 - Natural Gas-Fired, Fan Type Residential Central Furnaces (2014 revisions) Adoption scheduled for 2014 Most current revision of rule approved: October 20, 2005 at 72 FR 29886 (May 30, 2007) Rule 4901 - Wood Burning Fireplaces and Wood Burning Heaters Approved 74 FR 57907 (November 10, 2009)

Rule 4692 - Commercial Charbroiling Proposed for approval Proposal: proposed approval signed June 9, 2011 Most current revision of rule approved: March 21, 2002 at 68 FR 33005 (June 3, 2003)

Rule 4311 - Flares Submitted Proposal: action pending Submittal date: January 10, 2010 Submittal found complete: February 4, 2010 Most current revision of rule approved: June 20, 2002 at 68 FR 8835 (February 26, 2003)

Rule 9410 - Employer Based Trip Reduction Program Action pending Proposal: action pending Submittal date: May 17, 2010 New rule.TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 91Table F-4San Joaquin Valley Air Pollution Control DistrictEmissions Reductions for 2008 PM2.5Plan From Approved or Proposed for Approval Measures Reductions(tons per average annual day)NOxEmissions Reductions2009 2012 2014S-AGR-1 4103 - Open Burning1.21 1.87 1.87S-COM-14306 - Boilers - Phase 3 & 4320 - Advanced EmissionsReductions for Boilers, Steam Generators and ProcessHeaters (> 5 MMBtu/hr)10 (1.58) (1.60)S-COM-2 4307 - Boilers, 2 to 5 MMBtu/hr 0 1.25 1.29S-COM-3 4308 - Boilers, 0.075 to 2 MMBtu/hr 0 0.69 1.45S-COM-5 4703 - Stationary Gas Turbines 0 2.20 2.20S-COM-7 4354 - Glass Melting Furnaces1.22 3.50 3.64S-COM-9 4902 - Residential Water Heaters 0 0.30 0.50S-COM-144901 - Wood Burning Fireplaces and Wood BurningHeaters0 0.12 0.12M-TRAN-1 9410 - Employer-Based Trip Reduction20 (0.31) (0.33)Total Creditable NOxReductions from Approved/Proposed For Approval Measures2.43 9.93 11.1Direct PM2.5Emissions Reductions2009 2012 2014S-AGR-1 4103 - Open Burning 1.60 2.91 2.91S-COM-14306 - Boilers - Phase 3 & 4320 - Advanced EmissionsReductions for Boilers, Steam Generators and ProcessHeaters (> 5 MMBtu/hr)0 0.24 0.24S-COM-144901 - Wood Burning Fireplaces and Wood BurningHeaters0 1.15 1.08TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 92Table F-4San Joaquin Valley Air Pollution Control DistrictEmissions Reductions for 2008 PM2.5Plan From Approved or Proposed for Approval Measures Reductions(tons per average annual day)S-IND-9 4692 - Commercial Charbroiling30 0.0 0.0M-TRAN-1 9410 - Employer-Based Trip Reduction20 (0.03) (0.03)Total PM2.5Reductions from Approved/Proposed for Approval Measures1.6 4.30 4.23SOxEmissions Reductions2009 2012 2014S-AGR-1 4103 - Open Burning 0.05 0.05 0.05S-COM-14306 - Boilers - Phase 3 & 4320 - Advanced EmissionsReductions for Boilers, Steam Generators and ProcessHeaters (> 5 MMBtu/hr)0 1.92 1.92S-COM-7 4354 - Glass Melting Furnaces 0 1.49 1.62S-COM-144901 - Wood Burning Fireplaces and Wood BurningHeaters0.01 0.02 0.02Total SO2Reductions from Approved/Proposed for Approval Measures0.06 3.48 3.61Source: SJVUAPCD, “Table 3-1 Adjusted PM2.5Emission Inventory; Table 3-2 Adjusted NOxEmission Inventory; and Table 3-3 Adjusted SOxEmission Inventory,” March 2011, available in the docket for this proposal. All reductions are based on the Plan’s emissions inventory.1NOxreductions from Rule 4320 are not currently SIP creditable. See EPA’s approval of the rule at 76 FR 16696 (March 25, 2011)2Because Rule 9410 has not been proposedfor approval, reductions from this rule arenot included in the totals reductions listed. Should EPA complete arulemaking to approve this rule prior to final action on the SJV 2008 PM2.5plan, we propose to grant the rule the listed credit.3Erroneous value given in SJVUAPCD tables.TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 93Table F-5San Joaquin Valley Air Pollution Control District2008 PM2.5Plan Feasibility StudiesMeasure Number & DescriptionDistrict RuleNumberAnticipated StudyCompletion DateStatusS-AGR-2 Conservation ManagementPractices4550 2010On-going through 2011. Study currently focused on refining estimates ofdirect PM2.5from sources covered by this rule.S-COM- 4 Solid Fuel Boilers, SteamGenerators and Process Heaters (> 5MMBtu/hr)4352 2009Completed. Study found additional controls are technologically feasible tofurther reduce NOx. District will evaluate various control options duringrule revisions in 2011.S-COM-6A Small Spark-Ignited Enginesand Agricultural Spark-Ignited Engines4702 2008Completed. Rule revisions are currently under development. Adoptionexpected August 2011.S-COM-8 Lime Kilns 4313 2011Completed. Study found that there are no lime kilns currently operating inthe SJV.S-COM-11 Dryers 4309 2011Continuing through 2011. Several options for rule revisions are beingconsidered.S-GOV-6 Prescribed Burning 4106 2008Feasibility study completed. Based on results of the study, District isseeking legislative changes to raise priority of air quality related healthconcerns in decision making on prescribed burning. District has alsodeveloped a comprehensive outreach program and participates in dailycoordination calls with agencies involved in prescribed burning.S-IND-8 Cotton Gins 4204 2009On-going through 2012. Completion delayed pending results from thenational cotton gin particulate matter emissions study.S-IND-4 Fugitive PM10Prohibitions Reg. VIII 2009On-going through 2011. Study currently focused on refining estimates ofdirect PM2.5from sources covered by this regulation.M-OTH-8 Indirect Source ReviewEnhancement9510 2010 Completed. Study concluded that no rules revisions are needed at this time.M-OTH-10 Fireworks – 2012On-going through 2012. Study is looking at legal limitations and potentialfuture control options.Source: 2008 PM2.5Plan, Table 6-4 and SJV PM2.5Progress Report, Appendix C.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 94 b. CARB Measures and Commitment The 2007 State Strategy includes a commit ment by CARB to propose new defined measures. 2007 State Strategy, p. 62 and CARB Resolution 7-28, Attachment B, p. 8 and 2011 Progress Report, Appendix B. Table F-6 below li sts these defined measures and their current adoption and approval status. As can be seen from this table, the State has already adopted and EPA has approved or proposed to approve, or is in the process of granting waivers under CAA section 209 to most of these measures. Thes e new measures build on the State’s already extensive list of adopted measure; a list of wh ich can be found in the 2007 State Strategy (p. 38) and in Appendix A of this TSD.

In addition to the State’s commitment to propose specific measures, the 2007 State Strategy includes an enforceable commitment for emissions reductions sufficient in combination with existing measures and the District’s commitments to attain the PM 2.5 NAAQS in the San Joaquin Valley by the requested attainment da te of April 5, 2015. For the SJV, the 2007 State Strategy includes a State commitment to achieve 5 tpd of direct PM 2.5 and 76 tpd of NO x in the SJV by 2014. See 2007 State Strategy, p. 63 and CARB Resolution 07-28, Attachment B, p. 6. The nature of this commitment is desc ribed in the State Strategy as follows:

The total emission reductions from the new m easures necessary to attain the federal standards are an enforceable State commitmen t in the SIP. While the proposed State Strategy includes estimates of the emission re ductions from each of the individual new measures, it is important to note that the comm itment of the State Strategy is to achieve the total emission reductions necessary to atta in the 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 reduc tions, whether this is realized through additional reductions from the new measures or from alternative control measures or incentive programs. If actual emission d ecreases occur in any air basin for which emission reduction commitments have been made that are greater than the projected emissions reductions from the adopted measur es in the State Strategy, the actual emission decreases may be counted toward meeting A RB’s total emission reduction commitments. CARB Resolution 07-28 (September 27, 2007), Appendix B, p. 3. The 2011 Progress Report further discusses this commitment: When ARB adopted the 2007 State Strategy as a SIP revision, the State of California made a legal commitment, required by the Clean Air Act and enforceable in federal court, to reduce emissions to the levels necessary for attainment. ARB specifically identified several ways this emission reduction commitment could be achieved:

• New measures as described in the SIP

• Other alternative measures that ARB had not considered at the time the SIP was adopted

• Incentive programs that support the replacement or retrofit of aging, higher polluting pieces of equipment

• Actual emission decreases 2011 Progress Report, p. 4.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 95 As described in section II.A.3. of this TS D, CARB has adjusted baseline emissions estimates for source categories subject to its r ecently-revised in-use rules. Table F-7 shows original and adjusted baseline em issions inventories for the source categories. The adjustments to the inventories show the effect of the resent economic recession and, for some source categories, changes to inventory methodologies . Table F-8 lists the emissions reductions (from the adjusted baseline emissions inventories) th at the State now estimates it will achieve from its measures as adopted or revised and which are currently creditable to decrease CARB’s commitment.

Table F-6 

### 2007 State Strategy Defined Measures Schedule for Consideration and Current Status

State Measures Expected Action Year Current Status

Defined Measures in 2007 State Strategy
Smog Check Improvements 2007-2009 Approved 75 FR 38023 (July 1, 2010) 28 Expanded Vehicle Retirement (AB 118) 2007 Adopted by CARB, June 2009; by BAR, September 2010. Modification to Reformulated Gasoline Program 2007 Approved, 75 FR 26653 (May 12, 2010)

Cleaner In-Use Heavy Duty Trucks 2008 Proposed action pending.

Accelerated Introduction of Cleaner Locomotives 2008 Prop 1B bond funds awarded to upgrade linehaul locomotive engines not already accounted for by enforceable agreements with the railroads. Those cleaner line-hauls will begin operation by 2012.

Cleaner In-Use Off-Road Engines 2007, 2010 Waiver action pending.
Cleaner In-Use Agricultural Equipment 2009 Incentive program in progress. No credit taken.

New Emissions Standards for Recreational Boats 2013 Additional action expected 2013.

Source: 2009 State Strategy Update, p.4 and 2011 Pr ogress Report, Table 1. Additional information from www.ca.arb.gov. Only defined measures with PM 2.5 , or NO x reductions in the SJV are shown here.

28 California Assembly Bill 2289, passed in 2010, requir es the Bureau of Automotive Repair to direct older vehicles to high performing auto technicians and test stations for inspection and certification effective 2013. Reductions shown for the SmogCheck program in the 2011 Progress Report and this TSD do not include reductions from AB 2289 improvements. CARB Progress Report supplement, attachment 5.TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 96Table F-7Original and Adjusted Baseline Emissions InventoriesBy State Measure(tons per day, 2014)State MeasureDirect PM2.5NOxSOxOriginal Adjusted Change Original Adjusted Change Original Adjusted ChangeSmog Check Improvements (BAR) 2.5 2.5 0.0 41 41.2 +0.2 – – –Cleaner In-Use Heavy-Duty Trucks& Buses6.2 4.3 -1.9 156.9 111.3 -45.6 0.3 0.2 -0.1Accelerated Intro. Of Cleaner LineHaul Locomotives0.5 0.5 0.0 19.9 19.9 0.0 – – –Cleaner In-Use Off-RoadEquipment (>25hp)1.4 0.6 -0.8 31.4 13.7 -17.7 0.0 0.0 0.0New Emission Standards forRecreational Boats– – – 3.5 3.5 0.0 – – –All Other Measures 6416410.0 123.0 123.0 0.0 2422420.0Totals: 74.6 71.9 -2.7 375.7 312.6 -63.1 24.3 24.2 -0.1Source: 2011 Progress Report, Appendix E, p. 4.1Includes emissions from recreational boats.2Includes emissions from all sources categories except for those subject to the Truck & Bus and Off-Road Equipment RulesTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Jun e 29, 2011

EPA- Region 9 Page 97 Table F-8 

### Creditable Emissions Reductions from Defined Measures in the 2011 Progress Report for the San Joaquin Valley (tons per day 2014)

State Measure Direct PM 2.5 NO x Smog Check Improvements (BAR) 0.1 0.7
Expanded Vehicle Retirement – –
Cleaner In-Use Heavy-Duty Trucks 1.7 1.1
Accelerated Intro. Of Cleaner Line-Haul Locomotives 0.0 0.0 Cleaner In-Use Off-Road Equipment (>25hp) 0.0 0.3

Cleaner In-Use Agricu ltural Equipment – –
New Emission Standards for Recreational Boats – – Adjustments to Baseline Emissions 2.7 63.1

Totals: 4.5 65.2

Source: 2011 Progress Report, p. 18. Only defined measures with PM 2.5 , or NO x reductions in the SJV are shown here. Note: The 2007 State Strategy did not include SO x reductions for the SJV.

3. November 2010 Proposed Action on the Control Strategy and Enforceable Commitments In our 2010 proposed action, we found that circ umstances warranted the consideration of enforceable commitments as part of the SJV PM 2.5 SIP’s attainment demonstration. We also found that both the State and the District ha d demonstrated the capability to meet their commitments. We did not find, however, that th e commitments constituted a limited portion of the required emissions reductions needed for a ttainment. The State’s and District’s unfulfilled commitments at the time of our 2010 pr oposal represent 41 percent of the PM 2.5 reductions, 28 percent of the NO x reductions, and 44 percent of the SO x emissions reductions estimated to be needed for attainment. We also found that the co mmitments, which were for the most part to achieve the reductions by 2014, were not for an appropriate timeframe given that we were proposing to not grant the State’s request to extent the applicable attainment date from 2010 to 2015. 75 FR 74518, 74535. Because we could not make tw o of the necessary findings, we were unable to propose to approve the attainment demonstration that re lied in part on these commitments. We did, however, propose to a pprove SJVUAPCD's and CARB’s commitments to adopt and implement specific control measures on the schedule identified in their plans and to achieve the aggregate emissions reductions id entified in their plan s because they would strengthen the California SIP.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Jun e 29, 2011

EPA- Region 9 Page 98 4. Evaluation and Conclusions

a. Baseline and Control Strategy Measures As shown in Table F-9, the majority of the emissions reductions needed to demonstrate attainment come from baseline measures. These re ductions come from a co mbination of District and State measures as well as adjustments to the baseline that reflect re visions to the economic forecasts that underlie the Plan’s es timates of future emissions levels. 29
In the past two decades, the District has a dopted or revised almost 40 prohibitory rules that limit emissions of NO x , SO x and/or particulate matter including most of the rule adoptions/revisions it committed to as part of the 2008 PM 2.5 Plan. See Appendix B and Table F3. These rules include controls for boilers, fug itive dust sources, engines, woodburning, and open burning. The great majority of th ese rules and rule revisions ar e currently SIP approved and as such their emissions reductions are fully creditab le in attainment and RFP demonstrations and for other CAA requirements, such as contingency measures. The 2005 baseline inventory includes uncredi table reductions from the District’s Rule 9510-Indirect Source Review (4.2 tpd NO x ). 2008 PM 2.5 Plan, Appendix B, Table B-2. While EPA has approved the rule in to the California SIP, it is not currently allowing emissions reductions credits from the rule to be relied on for SIP planning purposes. 76 FR 26609 (May 9, 2011). In our evaluation of the RFP and attainment demonstrations, we have exclude reductions from this rule.

29 Reductions in the baseline also come from fede ral measures. These federal measures include EPA’s national emissions standards for heavy duty diesel trucks (66 FR 5001 (January 18, 2001)), certain new construction and farm equipment (Tier 2 and 3 non-road engines standards, 63 FR 56968 (October 23, 1998) and Tier 4 diesel non-road engine standards, 69 FR 38958 (June 29, 2004)), and locomotives (63 FR 18978 (May 16, 1998) and 73 FR 37045 (June 30, 2008)). States are allowed to rely on reductions from federal measures in attainment and RFP demonstrations and for other SIP purposes.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Jun e 29, 2011

EPA- Region 9 Page 99 Table F-9 

### Summary of Reductions Needed for SJV’s PM 2.5 

### Attainment Demonstration (tons per average a nnual day in 2014)

Direct PM 2.5 NO x SO 2

A 2005 baseline emissions level 86.0 575.4 26.4
B 2014 attainment target level 63.3 291.2 24.6

C Total reductions needed from 2005 baseline levels to attain in 2014 (A – B) 22.7 284.2 1.8

D Unadjusted 2014 baseline emissions level 75.0 376.2 25.5
E Adjustment to 2014 baseline emissions level 2.7 63.1 0.1

F Uncreditable reductions from Rule 9510 in the 2014 baseline – 4.2 –

G Adjusted 2014 baseline emissions level (D–E+F) 72.3 317.3 25.4

H Reductions from baseline measures (A-G) 13.7 258.1 1.0

Percent of reductions needed for attainment from baseline measures 60.4% 90.8% 56%

Reductions needed from control strategy measures (C-H) 9.0 26.1 0.8

Percent of reductions needed for attainment from control strategy measures 39.6% 9.2% 44%

California has adopted standards for many cate gories of on- and off-road vehicles and engines, gasoline and diesel fuels, and numer ous categories of consumer products. The State’s measures fall within two categories: measures fo r which the State has obtained or has applied to obtain a waiver of federal pre-emption under CAA section 209 (“section 209 waiver measure” or “waiver measure”) and those for which the State is not required to obtain a waiver (“non-waiver measure”). See EPA’s proposed approval and final approval of the SJV 1- Hour Ozone Plan at 74 FR 33933, 33938, (July 14, 2009) and 75 FR 10420, 10424 (March 8, 2010). 30

30 EPA position is also discussed in Brief of Respondents, Sierra Club, et al., And Committee for a Better Arvin, et al. v. United States En vironmental Protection Agency, et al ., United States Court of Appeals for the Ninth Circuit, Case Nos. 10-71457 and 10-71458, May 5, 2011, pp. 33-44.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Jun e 29, 2011

EPA- Region 9 Page 100 i. Section 209 Waiver Measures A waiver under CAA section 209 is, in general, required for most of California’s on- and non-road vehicle or engine standards. Examples of State waiver meas ures are: low emission vehicle program, heavy duty bus standards, and small off-road engine standards. A list of California’s waiver measures can be found in the Appendix A of this TSD.

California’s motor vehicle emissions control program predates the first federal statute regulating motor vehicle emissions, the Motor Ve hicle Air Pollution Control Act of 1965 (which amended the CAA of 1963). In further CAA amendm ents, referred to as the Air Quality Act of 1967 (Pub. L. 90-148), Congress allowed the State of Ca lifornia, and only California, a waiver of the Air Quality Act’s pre-emption of state emi ssions standards for new motor vehicles or new motor vehicle engines because of California’s pi oneering efforts and uniq ue problems. This was not changed when the statute was amende d in 1970. The 1977 amendments to the CAA expanded the flexibility granted to California in order “to afford California the broadest possible discretion in selecting th e best means to protect the health of its citizens and th e public welfare.” (H.R. Rep. No. 294, 95th Congr., 1st Sess. 301-2 (1977) . So long as California determines that its motor vehicle standards are “in the aggregate” at least as protective of public health and welfare as applicable federal standards, title II of the CAA requires EPA, unless it makes certain findings, to waive the Act’s general prohibition on state adoption and enforcement of standards relating to the control of emissi ons from new motor vehicles or new motor vehicle engines. See CAA section 209, subsections (a) and (b). As part of the 1990 Amendments to the CAA, Congress enacted subsection (e) of section 209. In nearly identical language to subsections (a) and (b) of section 209, subsection (e) sets forth the federal pre-emption of state emissions standards for non -road vehicles or engines but allows the State of California, and only Calif ornia, a waiver of pre-emption (with certain exceptions) under criteria that mi rror the section 209(b) waiver provisions for motor vehicles.

In EPA’s review of the California SIP and its many revisions, EPA has historically allowed emissions reduction credit for the motor ve hicle emissions standards that are subject to a section 209(b) waiver without requiring Californi a to submit the standards themselves to EPA for approval as part of the California SIP. In this respect, EPA treated these rules similarly to the federal motor vehicle control requirements, which EPA has always allowed states to credit in their SIPs without submitting the program as a SIP revision. Since 1990, EPA has treated California non-road standards for which EPA has issued waivers in the same manner as California motor vehicle standards, i.e., allowing cred it for standards subject to the waiver process without requiring submittal of the standa rds as part of the SIP. In so doing, EPA has treated the California non-road standards similarl y to the Federal non-road standards, which are relied upon, but not includ ed in, various SIPs. Credit for Federal measures, including thos e that establish on -road and non-road standards, notwithstanding their absence in the SIP, is justified by reference to CAA section 110(a)(2)(A), which establishes the following co ntent requirements for SIPs: “... enforceable emission limitations and other control measures , means, or techniques (including economic incentives such as fees, marketable permits, and auctions of emissions rights), ... , as may be necessary or appropriate to meet the applicable requirements of this chapter.” (emphasis added). Federal measures are permanent, independent ly enforceable (by EPA and citizens), and quantifiable without regard to whether they ar e approved into a SIP, and thus EPA has neverTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Jun e 29, 2011

EPA- Region 9 Page 101 found such measures to be “necessary or appr opriate” for inclusion in SIPs to meet the applicable requirements of the Act. Section 209 of the CAA establishes a process under which EPA allows California’s waiver measures to subs titute for Federal measures, and like the Federal measures for which they substitute, EPA has hi storically found, and continues to find, based on considerations of permanence, enforceability, and quantifiability, that such measures are not “necessary or appropriate” for California to include in its SIP to meet the applicable requirements of the Act. First, with respect to permanence, we note that, to maintain a waiver, CARB’s on-road waiver measures can be relaxed only to a leve l of aggregate equivalen ce to the Federal Motor Vehicle Control Program (FMVCP). See section 209(b)(1). In this re spect, the FMVCP acts as a partial backstop to California’s on-road waiver measures (i.e., absent a waiver, the FMVCP would apply in California). Likewise, Federal no n-road vehicle and engine standards act as a partial backstop for corresponding California non-roa d waiver measures. The constraints of the waiver process thus serve to limit the extent to which CARB can relax the waiver measures for which there are corresponding EPA standards, an d thereby serve an an ti-backsliding function similar in substance to those established fo r SIP revisions in CAA sections 110(l) and 193. Meanwhile, the growing convergence between Ca lifornia and EPA mobile source standards diminishes the difference in the emissions reduc tions reasonably attributed to the two programs and strengthens the role of the Federal program in serving as an effective backstop to the State program. In other words, with the harmonizati on of EPA mobile source standards with the corresponding State standards, the Federal progr am is becoming essentially a full backstop to most parts of the California program. Second, as to enforceability, we note that the waiver process itself bestows enforceability onto California to enforce the on-road or non-ro ad standards for which EPA has issued the waiver. CARB has as long a history of enforcemen t of vehicle/engine emissions standards as EPA, and CARB’s enforcement program is e qually as rigorous as the corresponding EPA program. The history and rigor of CARB’s enforcement program lends assurance to California SIP revisions that rely on the emissions reduc tions from CARB’s rules in the same manner as EPA’s mobile source enforcement program lends assu rance to other state’s SI Ps in their reliance on emissions reductions from the FMVCP. While it is true that citizens and EPA are not authorized to enforce California waiver measures under the Clean Air Act (i.e., because they are not in the SIP), citizens and EPA are authorized to enforce EPA standards in the event that vehicles operate in California without either California or EPA certification,

As to quantifiability, EPA’s historical prac tice has been to give SIP credit for motorvehicle-related waiver measures by allowing Ca lifornia to include motor vehicle emissions estimates made by using California’s EMFAC (a nd its predecessors) motor vehicle emissions factor model in SIP inventories. EPA verifies the emissions reductions from motor-vehiclerelated waiver measures through review and a pproval of EMFAC, which is updated from time to time by California to reflect updated methods and da ta, as well as newly-established emissions standards. (Emissions reductions from EPA’s mo tor vehicle standards are reflected in an analogous model known as MOBILE.) The EMFAC model is based on the motor vehicle emissions standards for which California has received waivers from EPA but accounts for vehicle deterioration an d many other factors. The motor vehi cle emissions estimates themselves combine EMFAC results with vehicle activit y estimates, among other considerations. See the 1982 Bay Area Air Quality Plan, and the relate d EPA rulemakings approving the plan (seeTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Jun e 29, 2011

EPA- Region 9 Page 102 48 FR 5074 (February 3, 1983) for the proposed rule and 48 FR 57130 (December 28, 1983) for the final rule) as an example of how the waiver measures have been treated historically by EPA in California SIP actions. 31 The San Joaquin Valley plan was developed using a version of the EMFAC model referred to as EMFAC2007, which EPA has approved for use in SIP development in California. See 73 FR 3464 (January 18, 2008). Thus, the emissions reductions that are from the California on-road “waiver m easures” and that are estimated through use of EMFAC are as verifiable as are the emissi ons reductions relied upon by states other than California in developing their SI Ps based on estimates of motor vehicle emissions made through the use of the MOBILE model. Moreover, EPA’s waiver review and approval process is analogous to the SIP approval process. First, CARB adopts its emissions standa rds following notice and comment procedures at the state level, and then submits the rules to EPA as part of its waiver request. When EPA receives new waiver requests from CARB, EPA publishes a noti ce of opportunity for public hearing and comment and then pub lishes a decision in the Federal Register following the public comment period. Once again, in substance, the pro cess is similar to that for SIP approval and supports the argument that one hurdle (the wa iver process) is all Congress intended for California standards, not two (waiver process pl us SIP approval proce ss). Second, just as SIP revisions are not effective until approved by EPA, changes to CARB ’s rules (for which a waiver has been granted) are not effective until EPA grants a new waiver, unless the changes are “within the scope” of a prior waiver and no new waiver is needed. Third, both types of final actions by EPA--i.e., final actions on California requests for waivers and final actions on state submittals of SIPs and SIP revisions—may be challenged under section 307(b)(1 ) of the CAA in the appropriate United States Court of Appeals. Further statutory support for EPA’s long-standing practice is found in CAA section 193. CAA section 193, enacted as part of the 1990 Amen dments to the CAA, is a general savings clause that provides for, among other things, EPA statutory inte rpretations that predate those amendments to remain in effect so long as not inconsistent with the Act. At the time it enacted section 193, Congress did not insert any language into the statut e rendering EPA’s consistent prior treatment of California’s motor vehicle st andards inconsistent with the Act. Moreover, where Congress intends state contro l measures that are otherwise pre-empted under title II of the

31 EPA’s historical practice in allo wing California credit for waiver measures notwithstanding the absence of the underlying rules in the SIP is further documented by reference to EPA’s review and approval of a May 1979 revision to the California SIP entitled, “Chapter 4, California Air Quality Control Strategies.” In our proposed approval of the 1979 revision (44 FR 60758, October 22, 1979), we describe the SIP revision as outlining California’s overall control strategy, which the State had divided into vehicular sources and non-vehicular (stationary source) controls. As to the former, the SIP revision discusses vehicular control measures as including technical control measures and transportation control measures . The former refers to the types of measures we refer to herein as waiver measures, as well as fuel content limitations, and a vehicle inspection and maintenance program. The 1979 SIP revision included several appendices, including appendix 4–E, which refers to “ARB vehicle emission controls included in title 13, California Administrative Code, chapter 3 * * *,” including the types of vehicle emission standards we refer to herein as waiver measures; however, California did not submit the related portions of the California Administrative Code (CAC) to EPA as part of the 1979 SIP revision subm ittal. With respect to the CAC, the 1979 SIP revision states: “The following appendi ces are portions of the Ca lifornia Administrative Code. Persons interested in these appendices should refer direc tly to the code.” Thus, the State was clearly signaling its intention to rely on the California motor vehicle control program but not to submit the underlying rules to EPA as part of the SIP. In 1980, we finalized our approval as proposed. See 45 FR 63843 (September 26, 1980).TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Jun e 29, 2011

EPA- Region 9 Page 103 Clean Air Act to be incorporated into SIPs, it has required that explicitly. See
, e.g ., section 211(c)(4)(C) (State fuels regula tions), section 211(m) (oxygenate d gasoline regulations), and section 246 (centrally fueled fleets). Thus, in section 193, Congress eff ectively ratified EPA’s longstanding pre-1990 practice of allowing emissi ons reduction credit for California standards subject to the waiver process notwithstanding the absence of th e standards in the SIP itself. As noted above, under the CAA Amendments of 1990, Congress enacted subsection (e) of section 209. In nearly identi cal language to subsections (a) and (b) of section 209, subsection (e) sets forth the federal pre-emption of stat e emissions standards for non-road vehicles or engines but allows the State of California, and only California, a waiver of pre-emption (with certain exceptions) under criteria that mirror the section 209(b) waiver provisions for motor vehicles. Congress is presumed to be aware of ag ency interpretations and its subsequent revision of the statute to add subsection (e) without overruling EPA’s interpretation w ith respect to motor vehicle standards is further compelling evidence that the Ag ency correctly interpreted congressional intent with respect to crediting California requirements subject to a section 209 waiver without requiring Calif ornia to submit the standards themselves to EPA for approval as part of the California SIP. We believe that section 193 of the CAA, th e general savings clause added by Congress in 1990, effectively ratified our long-st anding practice of granting cred it for the California waiver rules because Congress did not inse rt any language into the statut e rendering EPA’s treatment of California’s motor vehicle standards inconsistent with the Act. Rather, Congress extended the California waiver provisions to most types of non-road vehicles and engines, once again reflecting Congressional intent to provide Calif ornia with the broadest possible discretion in selecting the best means to prot ect the health of its citizens and the public welfare. Requiring the waiver measures to undergo SIP review in addi tion to the statutory waiver process is not consistent with providing Califor nia with the broadest possible discretion as to on-road and nonroad vehicle and engine standards, but rather , would add to the regul atory burden California faces in establishing and modifying such standa rds, and thus would not be consistent with Congressional intent. In short, we believe that Congress intend ed California’s mobile source rules to undergo only one EPA review process (i.e., the waiver process), not two. Even if section 193 did not provide congressional ac quiescence as to EPA’s treatmen t of the standa rds, the Act’s structure, evolution, and provisi on for the waiver of Federal pr e-emption for California mobile source emissions standards, as discussed above , support EPA’s long-sta nding interpretation of the CAA to allow California to rely on emissions reductions resulting from waiver measures in SIPs, notwithstanding the waiver meas ures’ absence from the SIP itself.

ii. Non-waiver measures These measures include improvements to Cali fornia’s inspection and maintenance (I/M) program, SmogCheck, and cleaner burning gasoline and diesel regulations. A list of these nonwaiver measures, many of which have b een SIP approved, can be found Appendix A.

b. Enforceable Commitments As stated and shown in Table F-10 below, redu ctions in the projecte d baseline inventory resulting from the economic recession, changes to activity estimates and emissions factors, and measures already adopted by the District and St ate (both prior to and pursuant to the 2008 PM 2.5TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Jun e 29, 2011

EPA- Region 9 Page 104 Plan) and approved or proposed for approval by EPA provide more than 90 percent of the emissions reductions needed to de monstrate attainment of the 1997 PM 2.5 standards in the SJV. The balance of the needed reductions is in the form of enforceable commitments by the District and CARB. We believe that, with re spect to the 2008 SJV PM 2.5 SIP, circumstances warrant the consideration of enforceable commitments as part of the attainment demonstration for the SJV. As shown in Table F-9 above, the majority of emissions reductions needed to demonstrate attainment and RFP in the SJV come from rules and regulations that we re adopted prior to 2007, i.e., they come from the baseline measures. As a result of these State and District efforts, most sources in the San Joaquin Valle y nonattainment area were alrea dy subject to stringent rules prior to State Strategy’s and th e Plan’s development, leaving fewer and more technologically challenging opportunities to reduce emissions. In the 2008 PM 2.5 Plan and the 2007 State Strategy, the District and CARB identified potenti al control measures th at could achieve the additional emissions reductions n eeded for attainment. See 2008 PM 2.5 Plan, Appendix I and 2007 State Strategy, Chapter 5. However, the time line needed to develop, adopt, and implement these measures went many years beyond the April 5, 2008 32 deadline to submit the PM 2.5 attainment plan. As discussed above, the Distri ct and State have made progress meeting their commitments but have not completely fulfilled th em. Given these circumstances, we consider the District’s and CARB’s reliance in the 2008 PM 2.5 Plan and 2007 State Strategy on enforceable commitments to be warranted. Having concluded that the use of enforceable commitment is warranted, we now consider the three factors EPA uses to determine whether the use of enforceable commitments in lieu of adopted measures to meet a CAA planning requir ements is approvable: (a) does the commitment address a limited portion of the statutorily-require d program; (b) is the state capable of fulfilling its commitment; and (c) is the commitment fo r a reasonable and appropriate period of time.

32 The 2007 State Strategy was developed to address both the 1997 PM 2.5 NAAQS and the 1997 8-hour Ozone NAAQS. The 8-hour ozone SIPs were due in November 2007, and the development and adoption of the State Strategy was timed to coordinate with this submittal date. 2007 State Strategy, p. 1.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Jun e 29, 2011

EPA- Region 9 Page 105 Table F-10 

### Reductions Needed for Attainment Remaining as Commitments based on SIP-Creditable Measures

(tons per average a nnual day in 2014)

Direct PM 2.5 NO x SO x

A Total reductions needed from baseline and control strategy measures to attain 22.7 284.2 1.8

B Reductions from baseline measures (Table F9) 13.7 258.1 1.0

C Total reductions from approved/proposed for approval measures (Tables F-4 and F-8) 6.0 13.2 3.6

D Total reductions remaining as commitments (A-B-C) 1 3.0 12.9 0.0

Percent of total reducti ons needed remaining as commitments 13.2% 4.5% 0.0%

E Total District commitments 6.7 9.0 0.9

F Outstanding reductions from Rule 9510 – 4.2 –
G Total reductions from approved/proposed for approval District measures 4.2 11.1 3.6

H Total reductions remaining as District commitments (E+F-G) 2.5 2.1 0

I Reductions in excess of District commitment 0 0 2.7
Percent of District’s commitments remaining as commitments 37.3% 23.3% 0%TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Jun e 29, 2011

EPA- Region 9 Page 106 Table F-10 

### Reductions Needed for Attainment Remaining as Commitments based on SIP-Creditable Measures

(tons per average a nnual day in 2014)

Direct PM 2.5 NO x SO x

J Total CARB commitments 5.0 76.0 N/A

K Total reductions from approved/proposed for approval/waived measures & adjustments to baseline (Tables F-7 & F-8) 4.5 65.2 0.1

L Reductions in excess of District’s commitments (Line H) – – 2.7

M Total reductions remaining as CARB commitments (J-K-L) 0.5 10.8 -2.8

Percent of CARB commitments remaining as commitments 10% 14.2% N/A

1 Sum may be different due to rounding.

i. The Commitment is a Limited Portion of Required Reductions For the first factor, we look to see if the commitment addresses a limited portion of a statutory requirement, such as the amount of em issions reductions needed for attainment in a nonattainment area. As shown in Table F-10, the remaining portion of the enforceable commitments after accounting for approved and proposed for approval measures as well as adjustments to the baseline that resulted from the recen t economic recession, are 3.0 tpd direct PM 2.5 and 12.9 tpd NO x . When compared to the total reductions needed by 2014 for PM 2.5 attainment in the SJV on a per-pollutant basis, these commitments repres ents approximately 13 percent of the direct PM 2.5 and 4.5 percent of the NO x needed to attain the 1997 PM 2.5 standards in the SJV.

We believe that the reductions remaini ng as enforceable commitments in the 2008 PM 2.5 Plan and 2007 State Strategy represent a limited portion of the total emi ssions reductions needed to meet the statutory requirement for attainment in the SJV and therefore satisfy the first factor. The level of reductions remaining as commitment s is reasonable close to the 10 percent range that EPA has historically accepted in approving attainment demonstrations. 33

33 See, for example, our approval of the SJV PM 10 Plan at 69 FR 30005 (May 26, 2004), the SJV 1-hour ozone plan at 75 FR 10420 (March 8, 2010), and the Houston-Galveston 1-hour ozone plan at 66 FR 57160 (November 14, 2001).TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Jun e 29, 2011

EPA- Region 9 Page 107 ii. The State is Capable of Fulfilling Its Commitment For the second factor, we consider whether the State and District are capable of fulfilling their commitments. As discussed above, CARB has adopted a nd submitted a 2009 State Strategy Status Report and a 2011 Progress Report which update and revise the 2007 State Strategy. These reports show that CARB has made significant pr ogress in meeting its enforceable commitments for the San Joaquin Valley and several other non attainment areas in California. Additional ongoing program that address locomotives and in-u se agricultural equipment have yet to be quantified but are exp ected to reduce NO x and direct PM 2.5 emissions in the SJV by 2014. 34
The District has already exceeded its commitments for reducing NO x and SO x emissions and has substantially met its commitment to reduce direct PM 2.5 emissions. See Table F-10. It also has already adopted ru les (Rules 9510 and 4320) that are projected to achieve NO x reductions of 5.8 tpd in 2014. These reductions, how ever, are not currently creditable to the attainment and RFP demonstrations. See Tables F- 4 and F-9. In a ddition, it is expecting to adopt later this year revisions to District Rule 4702 (Reciprocating Internal Co mbustion Engines) that are likely to achieve substantial NO x reductions by 2014. See SJVAPCD, Draft Staff Report For Draft Amendments To Rule 4702 (Internal Com bustion Engines–Phase 2), September 9, 2010. It is also continuing to work to identify and adopt additional measures to reduce emissions. Table F-5 in this TSD describes a number of th e feasibility studies cu rrently underway at the District. Beyond the rules discussed above, both CA RB and the District have well-funded incentive grant programs to reduce emissions from the on- and off-road engine fleets. Reductions from several of these programs have yet to be quantified and/or credited in the attainment demonstration. See, for example, SJV PM 2.5 Progress Report, section 2.3 Finally, the SJV is designated nonattainment for the 2006 24-hour PM 2.5 standard. The State must submit a plan to address attainment of that standard is by December 2012. 74 FR 58688, 58689 (November 13, 2009).

Given the evidence of the State's and District’s efforts to date and their continuing efforts to reduce emissions, we believe that the Stat e and District are capable of meeting their enforceable commitments to reduce emissions of direct PM 2.5 and NO x by 2014 to the levels needed to attain the 1997 PM 2.5 standards in the San Joaquin Valley by 2014.

iii. The Commitment is for a Reasonable and Appropriate Timeframe For the third and last factor, we consider whether the commitment is for a reasonable and appropriate period of time.

In order to meet the commitments to reduce em issions to the levels needed to attain the 1997 PM 2.5 standards in the San Joaquin Valley, the 2008 PM 2.5 Plan and 2007 State Strategy included an ambitious rule de velopment, adoption, and implementation schedules, which both

34 See, for example, SJVAPCD; U. S. EPA; USDA, NRCS; and CARB; St atement of Principles Regarding the Approach to State Implementation Plan Creditability of Agricultural Equipment Replacement Incentive Programs Implemented by the USDA Natural Resource Conservation Service and the San Joaquin Valley Air Pollution Control District,” December 2010.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Jun e 29, 2011

EPA- Region 9 Page 108 the District and CARB have substantially met. EPA considers these schedules to provide sufficient time to achieve by 2014 the few remaining reductions needed to attain by the proposed attainment date of April 5, 2015. See Tables F-3 a nd F-6 above. We, therefore, conclude that the third factor is satisfied.

iv. Summary of Proposed Finding on Enforceable Commitments in the SJV 2008 PM 2.5 SIP

EPA believes circumstances warrant the cons ideration of enforceable commitments as part of the attainment de monstration in the 2008 SJV PM 2.5 SIP. As stated above, measures already adopted by the District and State and approved or proposed for approval pursuant to CAA section 110(k) or waived pursuant to CAA section 209 by EPA provide the great majority of emissions reductions needed to demonstrate attainment of the 1997 PM 2.5 standards in the SJV by 2015. We have found that the reductions that re main as enforceable commitments represent a limited portion of the overall reductions needed fo r attainment. We have also found that the State and District are capable of fulfilling their rema ining commitments and that the commitments are for a time period that is both reasonable and appr opriate to assure that the remaining reductions are in place prior to the attainme nt date of April 5, 2015. As a resu lt of our findings here, EPA is proposing to accept enforceable commitments as pa rt California’s strategy to attain the 1997 PM 2.5 NAAQS in the SJV.

v. Proposed Action on Enforceable Commit ments to Reduce Emissions and Adopt Specific Measures We propose to approve, with exception of the commitment to revise Rule 4702 “Reciprocating Internal Combustion Engines” , the SJVUAPCD's commitments to adopt and implement specific control measures on the schedule identified in Table 6-2 (as amended June 15, 2010) in the 2008 PM 2.5 Plan, to the extent that these commitments have not yet been fulfilled and to achieve specific aggregate emissions reductions of direct PM 2.5 , NO x and SO x by specific years as given in Table 6-3 of the 2008 PM 2.5 Plan. EPA proposes to disapprove the commitment to revise to Rule 4702 by December 2010 because that date is now passed and the District has not adopted re visions to the rule. Should the Distri ct adopt revision to the rule by the time of EPA’s final action on the Plan, EPA pr oposes to take no action on the commitment because it will have already been fulfilled. Adoption of revisions to Rule 4702 is now expected in August 2011. We are also proposing to approve CARB's commitments to propose certain defined measures, as given in Table B-1 in 2011 Progres s Report, Appendix B and to achieve the total aggregate emissions reductions necessary to attain the 1997 PM 2.5 standards in the SJV, whether these reductions are realized from the new meas ures, alternative control measures, incentive programs, or other actual emissions decrea ses in the area. See CARB Resolution 07-28 (September 27, 2007), Appendix B, p. 3. This commitment is estimated to be aggregate emissions reductions of 5 tpd direct PM 2.5 and 76 tpd NO x in the San Joaquin Valley by 2014 as given on page 21 of the 2009 State Strategy Status Report.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 109 

### G. Attainment Demonstrations

1. Requirement for Attainment Demonstrations CAA sections 172(b) and (c) require states to submit plans that demonstrate attainment of the applicable standard as expeditiously as practi cable but no later than the applicable attainment date. Under the PM 2.5 implementation rule, this demonstra tion should consists of four parts: (1) technical analyses that locate, identify, and quantify sources of emissions that are contributing to violations of the PM 2.5 NAAQS; (2) analyses of future year emissions reduc tions and air quality improvement resulting from already-adopted national and local prog rams, and from potential new local measures to meet the RACT, RACM, and RFP requirements in the area; (3) adopted emissions reduction measure w ith schedules for implementation; and (4) contingency measures required u nder section 172(c)(9) of the CAA.

See 72 FR 20586 at 20605. The requirements for parts 1 and 2 are described in the emissions inventory (II.A.), air quality modeling (II.B), and RACM/RACT (II.D) sect ions of this TSD. Requirements for parts 3 and 4 are described in the control strategy (II.F.) and contingency meas ures (II.I.) sections of this TSD, respectively. In this section, we evaluate how these parts taken together provide for attainment of the 1997 PM 2.5 NAAQS in the San Joaquin Valley as expeditiously as practicable but no later than the attainme nt date required by the CAA.

2. Attainment Demonstration in the SJV 2008 PM 2.5 Plan

The attainment demonstration in the 2008 PM 2.5 Plan is in Section 9.1 “Attainment Outlook.” It is summarized in Table G-1 below. Table G-2 s hows the contributions by the District and CARB to the control strategy in the 2008 PM 2.5 Plan. Since adoption and submittal of th e 2007 State Strategy and the 2008 PM 2.5 Plan, both CARB and the District have adopted most of the measures that they committed to adopt in their plans, and majority have been approved, propos ed for approval, or gr anted a CAA section 209 waiver by EPA. See Tables F-3 and F-6. In th e 2011 Progress Report, CARB and the District have updated the emissions reductions expected fr om their adopted measures and resulting from changes to inventory and the ec onomic recession. Tables G-3 show s the impact of these updates on the attainment demonstration, and Table G-4 show the effect of these updates and EPA’s proposed and final approvals on the level of commitments remaining in the attainment demonstration.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 110 Table G-1 

### Summary of the SJV’s PM 2.5 

### the Attainment Demonstration as Submitted June 2008 (tons per average a nnual day in 2014)

Direct PM 2.5 NO x SO 2
A 2005 baseline emissions level 86.0 575.4 26.4
B 2014 attainment target level 63.3 291.2 24.6

C Total reductions needed from 2005 baseline levels to attain in 2014 (A – B) 22.7 284.2 1.8

D Adjusted 2014 baseline emissions level 72.3 317.3 25.4

Reductions from baseline measures (A-D) 13.7 258.1 1.0

Percent of reductions needed for attainment from baseline measures 60.4% 90.8% 56%

Reductions needed from control strategy measures (B - D) 9.0 26.1 0.8

Percent of reductions needed for attainment from control strategy measures 39.6% 9.2% 44%

Source: Table F-9.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 111 Table G-2 

### Summary of Control Stra tegy Reductions by Agency in the SJV 2008 PM 2.5 

### Plan (tons per average a nnual day in 2014)

Direct PM 2.5 NO x SO 2

Total reductions needed from baseline and control strategy measures to attain 22.7 284.2 1.8

Total reductions from contro l strategy measures 11.7 85.0 0.9

District commitments 6.7 9.0 0.9

Percent of total control strategy reductions from District commitments 57.3% 10.6% 100%

State commitments 5.0 76.0 0

Percent of total control strategy reductions from State commitments 43.7% 89.4% 0%

Source: 2008 PM 2.5 Plan, Table 8-1.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 112 Table G-3 

### Summary of the SJV PM 2.5 

### Attainment Demonstra tion Updated April 2011 with Additional Adjustments
(tons per average annual day in 2014)

PM 2.5 NO x SO 2 A 2005 base year emissions level 86.0 575.4 26.4
B 2014 attainment target level 63.3 291.2 24.6

C Total reductions needed from 2005 base year levels to attain in 2014 (A – B) 22.7 284.2 1.8

D Unadjusted 2014 baseline emissions level 75.0 376.2 25.5
E Adjustment to 2014 baseline emissions level 2.7 63.1 0.1

F Uncreditable reductions from Rule 9510 in the 2014 baseline - 4.2 -

G Adjusted 2014 baseline emissions level (D– E+F) 72.3 317.3 25.4

Reductions from baseline measures (A-G) 13.7 258.1 1.0

Percent of reductions needed for attainment from baseline measures 60.4% 90.8% 56%

Reductions needed from control strategy measures (G-C) 9.0 26.1 0.8

Percent of reductions needed for attainment from control strategy measures 39.6% 9.2% 44%TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 113 Table G-4 

### Reductions Needed for Attainment Remaining as Commitments based on SIP-Creditable Measures

(tons per average a nnual day in 2014)

Direct PM 2.5 NO x SO x

A Total reductions needed from baseline and control strategy measures to attain 22.7 284.2 1.8

B Reductions from baseline measures (Table F9) 13.7 258.1 1.0

C Total reductions from approved/proposed for approval measures (Tables F-4 and F-9) 6.0 13.2 3.6

D Total reductions remaining as commitments (A-B-C) 1 3.0 12.9 0.0

Percent of total reducti ons needed remaining as commitments 13.2% 4.5% 0%

E Total District commitments 6.7 9.0 0.9

F Outstanding reductions from Rule 9510 – 4.2 –
G Total reductions from approved/proposed for approval District measures 4.3 11.1 3.6

H Total reductions remaining as District commitments (E+F-G) 2.4 2.1 0

Percent of District’s commitments remaining as commitments 35.8% 0% 0%TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 114 Table G-4 

### Reductions Needed for Attainment Remaining as Commitments based on SIP-Creditable Measures
(tons per average a nnual day in 2014)

Direct PM 2.5 NO x SO x

I Total CARB commitments 5.0 76.0 N/A

J Total reductions from approved/proposed for approval/waived measures & adjustments to baseline 4.5 65.2 0.1

K Reductions in excess of District’s commitments 0 0 2.7

L Total reductions remaining as CARB commitments (or excess reductions) 0.5 10.8 -2.8

Percent of CARB commitments remaining as commitments 10% 14.2% N/A

3. November 2010 Proposed Action on the A ttainment Demonstration in the SJV 2008 PM 2.5 Plan EPA proposed to disapprove the attain ment demonstration in the SJV 2008 PM 2.5 Plan based on its proposed disapproval of the air qu ality modeling and RACM/RACT demonstration and its proposal to deny the State’s request to extend the attainment date for the SJV until April 5, 2015. EPA also proposed to disapprove the attainment demonstration because, at the time of the 2010 proposal, the State’s and Dist rict’s unfulfilled commitments represented 41 percent of the direct PM 2.5 reductions, 28 percent of the NO x reductions, and 44 percent of the SO 2 emissions reductions required for attainme nt. These percentages were well above the roughly 10 percent figure generally acceptable in order for EPA to approve an attainment demonstration that relies in part on enforceable commitments. 75 FR 74518, 74536 and Section II.D. of the 2010 Draft TSD.

4. Evaluation and Conclusions In order to approve a SIP’s attainment de monstration, EPA must make several findings and approve the State’s re quested attainment date. First, we must find that the demonstration’ s technical bases—emi ssions inventories and air quality modeling—are adequate. As discusse d above in sections II.A. and II.B., we are proposing to find that the emissions inventorie s and the air quality modeling on which the SJV 2008 PM 2.5 SIP’s attainment demonstr ation is based meet appli cable EPA regulations and guidance and are an acceptable basis for the demonstration.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 115 Second, we must find that the SIP provides for expeditious attainment through the implementation of all RACM and RACT on sources of direct PM 2.5 and each PM 2.5 attainment plan precursor. As discussed above in s ection II.D., we are pr oposing to approve the RACM/RACT demonstration in the SJV PM 2.5 SIP. Third, EPA must find that the emissions reduc tions that are relied on for attainment are creditable. As discussed in section II.F., the 2008 PM 2.5 SIP relies principally on adopted and approved/waived rules to achieve the emissi ons reductions needed to attain the 1997 PM 2.5 standards in the SJV by April 5, 201 5. The balance of the reductions is currently in the form of enforceable commitments that account for 13.2 percent of the direct PM 2.5 and 4.5 percent of the NO x emissions reductions needed from 2005 le vels for attainment. See Table G-4. EPA has previously accepted enforceable commitments in lieu of adopted control measures in attainment demonstrations when the circumstances warrant it and the commitments meet three criteria. As discussed in above in se ction II.F.4., we believe that circumstances here warrant the consideration of enforceable commitmen ts and that the three cr iteria are met: 1) the commitments constitute a limited portion of the re quired emissions reductions, 2) both the State and the District have demonstr ated their capability to meet their commitments, and 3) the commitment are for an appropriate timeframe. Ba sed on these conclusions, we are proposing to allow the State to rely on these limited enforcea ble commitments in its attainment demonstration. Finally, for a PM 2.5 nonattainment area that cannot attain within five years of its designation as nonattainment, EPA must grant an extension of the attainment date in order to approve the attainment demonstr ation for the area. As discusse d above in section II.E., we believe that a five-year extension of the attainment date is appropriate gi ven the severity of the nonattainment problem in the SJV and availabili ty and feasibility of control measure. We, therefore, are proposing to grant the State’s request to extend the attainment date in the SJV to April 5, 2015. For the foregoing reasons, we are proposing to approve the attainme nt demonstration in the SJV 2008 PM 2.5 SIP.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 116 

### H. Reasonable Further Progress Demonstrations

1. Requirements for Reasonable Fu rther Progress Demonstrations Clean Air Act Section 172(c)(2 ) requires that plans for nonattainment areas shall provide for reasonable further progress (RFP). RFP is defined in section 171(1) as “such annual incremental reductions in emissions of the relevant air pollutant as are re quired by [Part D] or may reasonably be required by the Administrator for the purpose of ensuring attainment of the applicable [NAAQS] by the applicable date.”

The PM 2.5 implementation rule requires a state to submit a RFP plan at the same time as its attainment demonstration for any area for which the state requests an extension of the attainment date beyond 2010. The RFP plan must provide emissions reductions such that emissions in 2009 represent genera lly linear progress from the base line year to the attainment year. Where a state requests an extension of the attainment deadline to 2014 or 2015, the state must additionally provide emissi ons reductions such that emissions in 2012 represent generally linear progress from the baseline year to the attainment year. See 40 CFR § 51.1009(c). 72 FR 20586 at 20633. The RFP plan must describe the control meas ures that provide for meeting the reasonable further progress milestones for the area, the timi ng of implementation of those measures, and the expected reductions in emissions of direct PM 2.5 and all PM 2.5 attainment plan precursors. See 40 CFR § 51.1009(c). A state is also required to demonstrate in it s RFP plan that in each applicable milestone year, emissions will be at a level consistent with generally linear progress in reducing emissions between the base year and the attainment year. See 40 CFR § 51.1009(d). A state may demonstration this by showing that emissions for each milestone year are either 1) roughly equivalent to benchmark emission levels for direct PM 2.5 emission and each PM 2.5 attainment plan precursor addressed in the plan or 2) at levels included in an alternative scenario that is projected to result in a generally equivalent impr ovement in air quality by the milestone year as would be achieved under th e first option. See 40 CFR § 51.1009(g). 72 FR 20586 at 20639. The steps for determining the benchmark emissions levels are given in the PM 2.5 implementation rule in 40 CFR § 51.1009(f): (1) For direct PM 2.5 emissions and each PM 2.5 attainment plan precu rsor addressed in the attainment strategy, the full implementation redu ction is calculated by subtracting the full implementation inventory from the baseline year inventory. The full implementation inventory is the projected RFP emissi ons inventory for the year preceding the attainment date, representing a level of emissions that demonstrates attainment. The baseline year inventory is the emissions invent ory for the year used as the base year for the attainment demonstration (see 40 CFR § 51.1000). (2) For direct PM 2.5 emissions and each PM 2.5 attainment plan precu rsor addressed in the attainment strategy, a benchmark emissions re duction is calculated by multiplying the full implementation reduction by the milestone date fraction. The milestone date fraction is the ratio of the number of years from the ba seline year to the mile stone inventory year divided by the number of years from the base line year to the full implementation year.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 117 (3) The benchmark emissions level in the m ilestone year is calculated for direct PM 2.5 emissions and each PM 2.5 attainment plan precursor by subtracting the benchmark emissions reduction from the baseline year em ission level. The benchmark RFP plan is defined as a plan that achieves benc hmark emission levels for direct PM 2.5 emissions and each PM 2.5 attainment plan precursor addressed in the attainment strategy for the area. In comparing inventories between base line and future years for direct PM 2.5 emissions and each PM 2.5 attainment plan precursor, the invent ories must be derived from the same geographic area. The plan must include emissions estimates for all types of emitting sources and activities in the geographic area from whic h the emissions inventories for direct PM 2.5 emissions and each PM 2.5 attainment plan precursor addressed in the plan are derived. See 40 CFR § 51.1009(f)(5). The equivalence of an alternative scenario to the corresponding benchmark plan must be determined by comparing the expected air quality changes of the two scenarios at the design value monitor location. This comparison should use the information developed for the attainment plan to assess the relationship betwee n emissions reductions of the direct PM 2.5 emissions and each PM 2.5 attainment plan precursor addressed in the attainment strategy and the ambient air quality improvement for the associated ambient species. See 40 CFR § 51.1009(h).

2. RFP Demonstration in the SJV 2008 PM 2.5 Plan The RFP demonstration is in Chapter 8 of the 2008 PM 2.5 Plan and is updated and revised in Appendix C of 2011 Progress Report. Th e demonstration a ddresses direct PM 2.5 , NO x , and SO 2 and uses the 2005 annual average day inventory as the base year inventory and 2014 as the attainment year.

Table H-1 shows the calculation of the full im plementation reductions, the first step in determining the RFP benchmarks under the PM 2.5 implementation rule. Table H-2 provides the benchmar k calculations from the Plan. The State is requesting an extension of the attainment date until April 5, 2015 which means 2014 is the attainment year for the purposes of the RFP benchmark calculation. Th e 2014 attainment year is 9 years from the 2005 base year making the 2009 milestone date fr action 4/9 and the 2012 milestone date fraction 7/9.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 118 Table H-1 

### Full Implementation Reductions (tons per average annual day)

Direct PM 2.5 NO x SO 2 2005 base year inventory 86.0 575.4 26.4

2014 attainment target emissions level (full implementation inventory) 63.3 291.2 24.6

Full implementation reductions for attainment 22.7 284.2 1.8

Source: 2008 PM 2.5 Plan, Table 8-1

Table H-2 

### Benchmark Calculations (tons per average annual day)

Direct PM 2.5 NO x SO 2 A. Full implementation reductions 22.7 284.2 1.8 B. 2009 milestone date fraction (4/9) 0.44 0.44 0.44

C. 2009 benchmark emissions reductions (A * B) 10.1 126.3 0.8

D. 2009 benchmark emissions level (2005 baseline inventory – C) 75.9 449.1 25.6

E. 2012 milestone date fraction (7/9) 0.78 0.78 0.78

F. 2012 benchmark emissions reductions (A * E) 17.7 221.0 1.3

G. 2012 benchmark emissions level (2005 baseline inventory – F) 68.3 354.4 25.1

H. Annual reductions needed for linear progress ( 1 / 9 *A) 2.5 31.6 0.2

I. Percent annual reductions needed for linear progress ( 1 / 9 *A/2005 baseline inventory) 2.9% 5.5% 0.8%

Source: 2008 PM 2.5 Plan, Table 8-2TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 119 3. November 2010 Proposed Action on the RFP Demonstration in the SJV 2008 PM 2.5 Plan Based on its proposed disapproval of the air quality modeling analysis and attainment demonstration, EPA proposed to disapprove the RFP demonstra tion in the SJV PM 2.5 Plan. Air quality modeling establishes the emissions levels needed for attainment. These levels are also needed to determine what constitutes generally linear progress towards at tainment in an area. 75 FR 74518, 74537. Using data from the Plan, EPA evaluated how close the Plan’s projected controlled emissions levels came to the 2009 and 2012 benchmark emissions levels. This evaluation showed a general lack of linear progress in NO x emissions reductions, es pecially in 2012. See Table H-6 in the 2010 Draft TSD, p. 110. The Plan also lacked an RFP demonstration for VOC. In its 2010 proposal, EPA suggested that the Distri ct and State should address both these issues in any revisions to the SJV 2008 PM 2.5 Plan’s RFP demonstration. 75 FR 74518, 74537 and Section II.H. of the 2010 Draft TSD.

4. Evaluation and Conclusions Because California has requested an attain ment date of April 5, 2015 for the SJV, the Plan has addressed RFP for both 2009 and 2012 as required by 40 CFR § 51.1009(c)(2).

The SJV 2008 PM 2.5 Plan describes in Chapter 6 (tab les 6-2 and 6-3) the non-baseline control measures that are relied on to meet the reasonable further progress milestones for the area, the timing of implementation of these measur es, and the expected re ductions in emissions of direct PM 2.5 and the PM 2.5 attainment plan precursors, NO x and SO x , as required by 40 CFR § 51.1009(c). The District updated this information in supplemental documentation provided by the District to EPA. See SJVAPCD, Table 3-1 “Adjusted PM 2.5 Inventory,” Table 3- 21 “Adjusted NO x Inventory,” and Table 3-3 “Adjusted SO x Inventory,” no date. This supplemental documentation can be found in the docket for this proposal.

The RFP demonstration does not address VOC or ammonia controls or emissions reductions. Because EPA is proposing to fi nd that neither VOC nor ammonia is a PM 2.5 attainment plan precursor for attainment of the 1997 PM 2.5 standards in the SJV (see section II.C of this TSD), the Plan does not need to provi de an RFP demonstrati on for either precursor. 40 CFR § 51.1009(f). In comparing inventories between base line and future years for direct PM 2.5 emissions and each PM 2.5 attainment plan precursor, the invent ories are derived from the same geographic area. The Plan includes emissions estimates for all sources and activities in the SJV from which the emissions inventories for direct PM 2.5 emissions and each PM 2.5 attainment plan precursor addressed in the Plan are derive d as required by 40 CFR § 51.1009(f). In preparing its RFP demonstration, th e State followed the procedures in by 40 CFR § 51.1009(f) and correctly calculat ed the benchmark emissions levels. Using data from the 2011 Progress Report, we have evaluated the Plan’s past and projected controlled emissions levels agai nst the 2009 and 2012 benchmark emissions levels adjusted to remove currently uncreditable reducti ons. See Table H-3. As can be seen from this table, controlled emissions levels for direct PM 2.5 , NO x , and SO x were below the benchmarks for 2009, demonstrating that the SJV met its RFP ta rgets in that year. For 2012, the projectedTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 120 controlled emissions level for direct PM 2.5 is only slightly above (by less than 5 percent) the benchmark and the projected controlled levels for NO x and SO x are substantially below the benchmarks. We believe that, ove rall, these projected controlled emissions levels represent generally linear progress for 2012. Based on our evaluation summarized above, we propose to find that the SJV 2008 PM 2.5 SIP provides for reasonable further progre ss as required by CAA section 172(c)(2) and 40 CFR § 51.1009. We also propose to find that the SJV has met its 2009 RFP benchmarks.

Table H-3 

### RFP Demonstration Using Updated Control Measur es and Baseline Data (tons per annual average day)

Direct PM 2.5 NO x SO 2

2009

Benchmark emissions level 76 449 26 Projected controlled emissions level 73 381 23 Currently uncreditable reductions from Rules 9410, 9510, and 4320 (Table H-4) 0 5.5 0

Corrections to estimate d reductions from Rule 4692 (Table H-4) 0 0 0

Revised projected controlled emissions level 73 387 23

Emissions below benchmark emissions level -3 -62 -3

Percent above/below benchmark emissions level -4% -14% -12%

2012

Benchmark emissions level 68 354 25 Projected controlled emissions level 70 328 20 Currently uncreditable reductions from Rules 9410, 9510, and 4320 (Table H-4) 0 8.2 0

Corrections to estimate d reductions from Rule 4692 (Table H-4) 0.9 0 0

Revised projected controlled emissions level 71 336 20

Emissions above/below benchmark emissions level +3 -18 -5

Percent below benchmark emissions level +4% -5% -20%TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 121 Table H-4 

### Adjustments to Control Measures Re ductions for the RFP Demonstration (tons per annual average day)

2009 2012

NO x Direct PM 2.5 NO x Direct PM 2.5 Rule 9410 – Employer Based Trip Reduction Program 0 0 0.3 0

Rule 9510 – Indirect Source Review 5.5 0 6.3 0

Rule 4320 – AERO for Boilers 0 0 1.6 0

Rule 4692 – Commercial Charbroiling 0 0 0 0.9

Total Adjustment 5.5 0 8.2 0.9

Estimated Effect of Base Year Inventory Changes on the SJV 2008 PM 2.5 SIP’s RFP Demonstrations As discussed in section II.A. of this TSD, CARB has updated the inventories for several mobile source categories includ ing off-road equipment and h eavy duty diesel trucks and estimates that these updates reduce the 2005 base year inventory by approximately 6 percent for NO x and 5 percent for PM 2.5 . CARB Progress Report supplemen t, Attachment 1. The State, however, did not revise the RFP demonstration in the SJV 2008 PM 2.5 Plan to incorporate these adjustments. As shown in Tables H-5 and H-6 below, we have evaluated the effect on the RFP demonstration of making these minor adjustments to the 2005 base year inventory. As can be seen from these tables, the Plan still provides for RFP with these adjustments.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 122 Table H-5 

### Estimated Effect of Change s to the 2005 Base Year Inventory on the RFP Demonstr ation – Milestone Calculation (tons per average annual day)

Direct PM 2.5 NO x SO 2

A. Base year inventory 86.0 575.4 26.4

B. Adjusted base year inventory assuming 4.7% reduction in PM 2.5 and 6.1% reduction in NO x (no change to SO 2 ) 82.0 540.3 26.4

C. Attainment level 63.3 291.2 24.6 D. Adjusted full implementation reductions (B-D) 18.7 249.1 1.8

E. 2009 milestone date fraction (4/9) 0.44 0.44 0.44

F. Adjusted 2009 benchmark emissions reductions (D * E) 8.2 109.6 0.8

G. Adjusted 2009 benchmark emissions level (BF) 73.7 430.7 25.6

H. 2012 milestone date fraction (7/9) 0.78 0.78 0.78

I. Adjusted 2012 benchmark emissions reductions (D * H) 14.6 194.3 1.3

J. Adjusted 2012 benchmark emissions level (2005 baseline inventory – F) 67.4 346.0 25.1

K. Annual reductions need ed for linear progress ( 1 / 9 *D) 2.1 27.7 0.2

L. Percent annual reductions needed for linear progress ( 1 / 9 *D / 2005 baseline inventory) 2.5% 5.1% 0.8%TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 123 Table H-6 

### Estimated Effect of Change s to the 2005 Base Year Inventory on RFP Demonstration (tons per annual average day)

Direct PM 2.5 NO x SO 2

2009

Benchmark emissions level 73.7 430.7 26 Revised projected controlled emissions level (Table H-3) 73 387 23

Emissions below benchmark emissions level -0.7 -43.7 -3

Percent below/above benchmark emissions level -1.0% -10.1% -12%

2012

Benchmark emissions level 67.4 346.0 25 Revised projected controlled emissions level (Table H-3) 70.9 336 20

Emissions below/above benchmark emissions level 3.5 -10 -5

Percent below/above benchmark emissions level 5.1% -2.9% -20%

Earthjustice Petition on the PM 2.5 Implementation Rule In June 2007, a petition to the EPA Administ rator was filed on beha lf of several public health and environmental groups requesting reco nsideration of several provisions in the PM 2.5 implementation rule. See Earthjustice, “Petition fo r Reconsideration in the Matter of the Final Clean Air Fine Particulate Implementation Rule,” June 25, 2007. Among these provisions is allowing states to use emissions reductions from outside of the nonattainment area to demonstration RFP (out-of-area RFP) as di scussed in 72 FR 20586 at 20636. On May 13, 2010, EPA granted the petition with respect to this issue. See Letter, Gina McCarthy, Assistant Administrator for Air and Radiation, EPA, to David Baron and Paul Cort, Earthjustice, May 13, 2010. The updated SJV 2008 PM 2.5 plan does not rely on out-of-area emissions reductions to demonstrate RFP.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 124 

### I. Contingency Measures

1. Requirements for Contingency Measures Under CAA section 172(c)(9), all PM 2.5 attainment plans must include contingency measures to be implemented if an area fails to meet RFP (RFP contingency measures) and contingency measures to be implemente d if an area fails to attain the PM 2.5 NAAQS by the applicable attainment date (attainment contingency measures). See 40 CFR § 51.1012. The purpose of contingency measures is to continue progress in reducing emissions while the SIP is being revised to meet the missed RFP mile stone or correct con tinuing nonattainment. The principle requirements for contingency measures are:

• Contingency measures must be fully adopt ed rules or control measures that are ready to be implemented quickly upon failure to meet RFP or failure of the area to meet the standard by its attainment date.

• The SIP should contain trigger mechanisms for the contingency measures, specify a schedule for implementation, and indicate that the measures will be implemented without further action by the state or by EPA. In general, EPA will expect all actions needed to affect full implementation of the measures to occur within 60 days after EPA notifies the state of a failure.

• The contingency measures should consist of other control measures for the area that are not included in the control strategy for the SIP.

• The measures should provide for emi ssions reductions equivalent to approximately one year of reductions n eeded for RFP calculated as the overall level of reductions needed to demonstr ate attainment divided by the number of years from the base year to the attainment year.

See 72 FR 20586 at 20643. The April 16, 1992 General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 (57 FR 13498, 13512) provides the following guidance on contingency measures which c ontinues to be applicable: States must show that their contingency m easures can be implemented without further action on their part and with no additional rulemaking actions su ch as public hearings or legislative review. In general, EPA will expect all actions needed to affect full implementation of the measures to occur within 60 days after EPA notif ies the State of its failure. Contingency measures can include both Fe deral, state and local measures already scheduled for implementation or already implem ented. The CAA requires contingency measures that provide for additional emissions reductions th at are not relied on for RFP or attainment and are not included in these demonstrations. In ot her words, contingency measures are intended to achieve reductions over and be yond those relied on in the RFP and attainment demonstrations. Nothing in the CAA precludes a state from implementing such measures before they are triggered. EPA has approved numerous SIPs unde r this interpretation. See, for example, 62 FR 15844 (April 3, 1997) (direct final ru le approving Indiana ozone SIP revision); 62 FR 66279 (December 18, 1997) (final rule ap proving Illinois ozone SIP revision);TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 125 66 FR 30811 (June 8, 2001) (direct final rule approving Rhode Island ozone SIP revision); 66 FR 586 (January 3, 2001) (final rule approving District of Columbia, Maryland, and Virginia ozone SIP revisions); and 66 FR 634 (January 3, 2001) (final rule approving Connecticut ozone SIP revision). A court has upheld this interpretation. See LEAN v. EPA , 382 F.3d 575, 5th Circuit, 2004.

2. Contingency Measures in the SJV 2008 PM 2.5 Plan and 2011 Progress Report Contingency measures in the 2008 PM 2.5 SIP are composed of several types: a newcommitment to an action by the SJVAPCD, surplus reductions in the RFP demonstration, post2014 emissions reductions, a contingency provision in an adopted rule, reductions from incentive funds, and reductions of specifica lly-identified implemented rules that are not ot herwise relied on in the attainment and RFP demonstrations. Contingency measures are discussed in S ection 9.2.2. of the Plan, on page 29 of the CARB Staff Report, and Appendix A of the CA RB Resolution 08-28 adopting the Plan. Updated information on both the RFP and attainment contingency measures for the SJV 2008 PM 2.5 Plan is provided in the 2011 Progress Report and Supple ment. This information includes revisions to the RFP demonstration that shows excess reductions and updated es timates of the reductions in 2015 from the State’s mobile source control pr ogram. See 2011 Progress Report, Appendix A, p. 2, Appendix C, Table C-1, and CARB Progr ess Report supplement, Attachment 2.

CARB also discusses the contingency measure provisi on in Appendix D of the 2007 State Strategy; however, this discussion addr esses the contingency measure provisions for California’s 8-hour ozon e plans and not the PM 2.5 plans.

a. New Commitment As a contingency measure, the District pr oposes to request that CARB accelerate the adoption and/or implementation of any remaining CA RB control measures that have not yet been adopted or fully implemented, to the extent f easible. This request would be made through a formal District Governing Boar d resolution adopted at a regular ly-scheduled Governing Board hearing to be held within two months after a finding by EPA of a failure to meet an RFP milestone. Potential emissions reductions from this proposed contingency measure are not quantified. See 2008 PM 2.5 Plan, p. 9-7.

b. General Surplus Reductions in the RFP Demonstration and Post-2014 Surplus Reductions in the RFP Demonstration – In the June 2008 versio n of the Plan, the method used to calculate emissions reductions needed to meet RFP benchmarks withheld a certain percentage of those reductions for continge ncy purposes: 1 percent of the baseline PM 2.5 inventory and 3 percent of the baseline NO x inventory. These percenta ges equated to roughly 1 tpd direct PM 2.5 and 17 tpd NO x being reserved for contingenc y. No reserve was included for SO x because SO x emissions levels were projected to be below the applicable benchmarks. See 2008 PM 2.5 Plan, p. 8-4. The 2011 Progress Report updates the RFP demonstrations in the 2008 PM 2.5 Plan. See 2011 Progress Report, Table C-1. The updated dem onstration does not in clude a contingency measure reserve but rather shows that controlled emissions levels of NO x and SO x are or will be below the required RFP benchmarks. SO x reductions that are in exce ss of those needed to meetTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 126 RFP and contingency are reserved for PM 2.5 contingency measures at an interpollutant trading ratio of 1 tpd SO x to 1 tpd direct PM 2.5 . See 2011 Progress Report, A ppendix A, p. 2 and (for the trading ratio), SJV PM 2.5 Progress Report, Table 2-2.

Post-2014 Emissions Reductions – The 2008 PM 2.5 Plan relies on the incremental emissions reductions that will occur in 2015 from CARB’s mobile sour ce program to provide for contingency measures for failure to attain. See p. 9-9. The Plan does not pr ovide an estimate of that these reductions. CARB initially estimated the NO x reductions at 21 tpd in 2015. See CARB Staff Report, p. 29. CARB updated the estimated incremental emi ssions reductions that will occur in 2015 from its mobile source program including the reduc tions expected from its In-use Truck and Bus and In-Use Off-Road Engine Rules. See CARB Progress Report supplement, Attachment 2. The updated 2015 reductions are: 3 tpd SO 2 and 21 tpd NO x . c. Adopted or Scheduled for Adoption Rules/Incentive Funds

Rule 3170 – This rule, Federally Mandated Ozone Nonattainment Fee, was adopted by the District in 2002 to meet the requirements of CAA section 185. 35 This CAA section requires each major stationary source of VOC or NO x located in the a severe or extreme ozone nonattainment that fails to attain the ozone st andard by the area’s appl icable attainment date to pay a fee to the state in each calendar year fo llowing the attainment year fo r all emissions above a baseline amount until the area attains the ozone standard. The CAA does not specify how states may sp end or allocate the f ees collected under a section 185 fee program; therefore, states have discretion on how to use them. EPA encourages states to use the fees to provide incentives fo r additional ozone precursor emissions reductions from stationary and/or mobile sources or fo r other purposes aimed at reducing ambient ozone concentrations in the affected area. 36 In the 2008 PM 2.5 Plan, the District in dicated that it would use any funds collected under Ru le 3170 (should the area fail to tim ely attain the 1-hour ozone standard and the rule be tri ggered) to implement other pollu tion control programs. See 2008 PM 2.5 Plan, p. 9-8. The District has recently revi sed its CAA section 185 program to create an equivalent fee program as allowed under EPA’s policy. See ft n. 36. The District’s section 185 equivalency program includes not only revisions to Rule 317 0 but also a vehicle re gistration surcharge of $12. The District expects to begi n collecting vehicle re gistration fees in late 2011 and Rule 3170 fees in 2012. See SJVAPCD, Final Draft Sta ff Report Draft Amendments to Rule 3170 (Federally Mandated Ozone Nonattainment F ee), April 21, 2011. No estimate of emissions reductions expected from the sectio n 185 equivalency program is given.

35 EPA approved Rule 3170 into the California SIP under CAA section 110(k) on January 13, 2010. At the same time, we disapproved the rule under CAA section 185 as failing to fully meet the requirements of that CAA section. 75 FR 1716.

36 For more information on requirements of CAA section 185, see Memorandum , Stephen D. Page, Director, Office of Air Quality Planning and Standard, EPA to Regional Air Division Directors, Regions I-X, “Guidance on Developing Fee Programs Required by Clean Air Act Section 185 for the 1-hour Ozone NAAQS,” January 5, 2010.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 127 Rule 4307 – On October 16, 2008, the SJVAPCD adopted revisions to Rule 4307–Boilers, Steam Generators, and Process Heaters (2 to 5 MMBTU). These revisions lowered NO x limits, added SO 2 and PM 10 limits, and removed certain exemptions. While the District committed to adopt revisions to Rule 4307 as part of the control strategy in the 2008 PM 2.5 Plan’s control strategy, it had not included emissions reductions from thes e revisions in either the original RFP or attainment demonstration. Because of this, the reductions could be considered excess to these demonstrations.

Rule 4901 – On October 16, 2008, the SJVAPCD adopted revisions to its wood burning rule, Rule 4901–Wood Burning Fireplace and Wood Burni ng Heaters, to incorporate a contingency provision in section 5.6.5. Th is provision states that: On or after sixty days following the effectiv e date of EPA final rulemaking that the San Joaquin Valley Air Basin has failed to attain the 1997 PM 2.5 National Ambient Air Quality Standards by the applicable deadline, the [air pollution control officer] shall notify the public of an Episodic Curtailm ent for a geographic region whenever a PM 2.5 concentration of 20 μg/m 3 or greater or a PM 10 concentration of 135 μg/m 3 is predicted for the geographic region. This provision lowers the trigger for calling an episodic curtailment from the existing 30 μg/m 3 . During an episodic curtailment, the operation of wood burning fireplaces, wood burning heater, or outdoor wood bur ning device (except when it is the sole source of heat) is prohibited. See Rule 4901, secti on 5.6.1. In its supporting document ations for this rule, the District did not quantify the em issions reductions expected shoul d this contingency provision be triggered.

Rule 4702 – The District is currently anticipating adoption of revisions to Rule 4702–Internal Combustion (I/C) Engines–Phase 2, in August, 2 011. Proposed revisions to this rule include lowering the applicability threshold of the rule to engines 25 hp and greater (from 50 hp) and lowering NO x , VOC, and carbon monoxide limits for all sp ark-ignition I/C engi nes that are used in non-agricultural operations and making th ese revisions effective January 1, 2014. See SJVAPCD, Draft Staff Report Fo r Draft Amendments To Ru le 4702 (Internal Combustion Engines–Phase 2), September 9, 2010. While the Dist rict committed to adopt revisions to Rule 4702 as part of the control strategy in the 2008 PM 2.5 Plan’s control strategy, it did not included emissions reductions from these revisions in either the original RFP or at tainment demonstration. Because of this, the reductions could be considered excess to these demonstrations.

Incentive Funds – The District has received and expect s to continue to receive significant funding for its incentive grant pr ograms from sources that include the State’s Carl Moyer Program, Proposition IB Goods Movement Emis sion Reduction Program, vehicle registration surcharges, its Indirect Source Review Rule (Rule 9510), and the federal Diesel Emissions Reduction Act. Through its incentive programs, th e District has funded and continues to fund numerous projects that reduce em issions in the Valley. See 2008 PM 2.5 Plan, Section 6.5 and SJV PM 2.5 Progress Report, section 2-3. For various reasons , mainly related to their SIP creditability, the emissions reductions generated from these in centive-funded projects are not included in either the RFP or attainment demonstration in the Plan. In April 2007, the District’s Governing Board adopted a resolution committing to implement various procedural, record keeping, an d reporting requirements to ensure that the all incentive-based reductions achieve d by the District meet EPA re quirements and guidance for SIPTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 128 creditability. 37 At the time the Plan was submitted in 2008, the District expected these requirements would be in place in time for th e 2009 and 2012 RFP milestone years so that the emissions reductions from its various incentive pr ograms could be used to meet the contingency measure requirement and for other SIP-related purposes. The District currently estimates that there ar e $112 million of incentive funds available to invest in the SJV for the 2010-2011 fiscal year. See SJV PM 2.5 Progress Report, p. 2-4. This is in addition to over $301 million received from 1998 until 2010. See SJV PM 2.5 Progress Report, Table 2-5. The progress report does not include an estimate of the emissions reductions achieved or anticipated from the use of these funds. 38

3. November 2010 Proposed Action on the C ontingency Measures in the SJV 008 PM 2.5 SIP In 2010, we proposed to disapprove the RFP and attainment contingency measures in the 2008 PM 2.5 Plan. We found that, although the Plan incl uded suggestions for several potentially approvable contingency measures as well as se veral measures that did not meet the CAA’s minimum requirements for contingency measures (e.g., no additional rulemaking, surplus to attainment and RFP needs), it did not provide sufficient information to determine if the emissions reductions from some of the approvable measures are SIP creditable or to quantify the expected emissions reductions. We, therefore, were unable to dete rmine if the Plan’s contingency measure provisions pr ovided reductions roughly equiva lent to one year’s worth of RFP. See 75 FR 74518, 74539 and Sec tion II.J of the 2010 Draft TSD.

4. Evaluation and Conclusions

Under the PM 2.5 implementation rule, a state must submit contingency measures that meet the requirements of CAA section 172(c)(9) and provide for the equi valent of roughly one year’s worth of RFP. One year’s worth of RFP is determined by dividing the emissions reductions from base year levels that are needed for attainment by the number of years between the base year (2005) and the attainment ye ar (2014). 72 FR 20586 at 20643. We show this calculation for SJV 2008 PM 2.5 Plan in Table I-1 below. We are not evaluating th e provisions in the 2008 PM 2.5 SIP that address contingency measures for failure to meet the 2009 RFP benc hmarks. Information available to EPA and the public shows that SJV met its 2009 benchmarks for direct PM 2.5 , NO x , and SO x . See 2011 Progress Report, Table C-1 and section II.H. of this TSD. As a result, contingency measures for failure to meet the 2009 RFP benc hmark no longer have any meaning or effect under the CAA and therefore do not require any re view or action by EPA. In addition, as noted above, the purpose of RFP contingency measures is to provide continued progress while the SIP is being revised to meet a missed RFP milest one. Failure to meet the 2009 benchmark would have required Californi a to revise the SJV PM 2.5 Plan to assure that the next milestone was met and that the Plan still provided for attainment. California has, in fact, prepared and submitted a

37 SJVUAPCD Governing Board Resolution 07-04-11B, “In the Matter of: Adopting Commitments to Enhance SIP Creditability of Incentive-Based Emissions Reductions,” April 30, 2007.

38 In the 2008 PM 2.5 Plan, the District estimated that the $90 million per year of incentive funds then available to the SJV could provide 3.6 tpd of NO x emissions each year, accumulating y ear to year (that is, after five years, for example, the cumulative redu ction would be 18 tpd). See 2008 PM 2.5 Plan, p. 9-9.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 129 revision to the SJV PM 2.5 SIP that shows that the SIP con tinues to provide for RFP in 2012 and for attainment by April 5, 2015.

Table I-1 

### Reductions Needed from Contingency Measures (tons per average annual day)

Direct PM 2.5 NO x SO x A 2005 baseline 86.0 575.4 26.4

B 2014 attainment level 63.3 291.2 24.6

C Emissions reductions needed for attainment (A-B) 22.7 284.2 1.8

D One year’s RFP (C/9) 2.5 31.6 0.2

E One year’s RFP as percent of 2005 baseline 2.9% 5.5% 0.8%

a. New Commitment CARB’s measures are primarily aimed at reducing emissions from mobile sources. Accelerating their implementation to correct sh ortfalls in RFP and attainment would be appropriate given the contribu tion of mobile sources to PM 2.5 standard exceedances in the SJV and the importance of mobile source measures to reducing and eliminating those exceedances. However, the process outlined in the 2008 PM 2.5 Plan would require multiple steps to implement including the adopting of a resolution by th e SJVUAPCD’s governing board and rulemaking by CARB. Such a process would likely take more than a few months to complete. Under CAA section 172(c)(9) and EPA’s long-st anding policies interpreting this section, contingency measures must require minimal add itional rulemaking by the state and take effect within a few months of a failure to meet an R FP target or to attain. The District’s proposed commitment to request accelerated implementati on of CARB’s measures meets neither of these requirements and thus does not qualify as a contingency measures under the CAA.

b. General Surplus Reductions in the RFP Demonstration and Post-2014 Surplus Reductions in the RFP Demonstration - As shown in Table I-2 below, emissions levels of NO x and SO x will be below the required RFP benchmarks in 2012. These surplus reductions are available use as NO x and SO x contingency measures for the 2012 RFP milestone. The 2011 Progress Report reserves the SO x reductions that are in exce ss of those needed to meet RFP and contingency as PM 2.5 contingency measures, using an interpollutant tr ading ratio of 1 tpd SO x to 1 tpd direct PM 2.5 to show equivalency. See 2011 Progress Report, Appendix A, p. 2. We do not, however, agree at th is time with the use of an interpollutant trading ratio of 1:1TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 130 SO x to direct PM 2.5 as the District has not provided an adequate technical justification for this ratio. See section II.B.4 above.

Post-2014 Emissions Reductions - Additional emissions reductions resulting from the implementation of adopted mobile source emissi on standards through fleet turnover in the 2015 and later may be used to meet the contingency measure requirement for failure to attain. CARB provides estimates for reductions in 2015 from its mobile source control program of 21 tpd NO x , and 3 tpd SO 2 . See CARB Progress Report supplement, Attachment 2.

Table I-2 

### Excess Reduction in Update d 2012 RFP Demonstrations Available for Use As Contingency Measures (tons per annual average day)

Direct PM 2.5 NO x SO x Benchmark emissions level 68 354 25 Revised projected controlled emissions level (Table H-3) 70.9 336 20

Emissions above/below benchmark emissions level 2.9 -18.0 -5

Excess SO x proposed to substitute for PM 2.5 4.8

1-Year’s worth of RFP 2.5 31.6 0.2

c. Adopted or Scheduled for Adoption Rules

Rule 3170 – The District expects to begin to colle ct fees under its CAA section 185 program in late 2011. It is the District’s inte nt to use the collected fees in its incentives gr ant program. See SJVUAPCD Governing Board Resolution, No. 10- 10-14, October 21, 2010, p. 5. We address the use of incentive funds as c ontingency measures below.

Rule 4307 – Reductions from Rule 4307 are now incl uded in the updated RFP and attainment demonstration contained in the 2011 Progress Report; therefore, reductions from this rule may no longer be used for contingency measures purposes. 39

Rule 4702 – The District has not yet adopted revisi ons to Rule 4702. Because this rule is not currently adopted or approved by EPA, it cannot be used for contingenc y measures purposes.

39 Reductions from the Rule, however, can be used for contingency measures purposes to the extent that they contribute to creating excess reductions in the RFP demonstration.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 131 Rule 4901 – We find that the contingency provisions in section 5.6.6 of Rule 4901 fully meet CAA requirements for contingency measures. The provision can be implemented with no additional rulemaking on the part of the District and must be imple mented within 60 days of an EPA finding that the area has failed to attain the PM 2.5 standards. We approved the October 2008 revision of Rule 4901, including the continge ncy provision, into the California SIP on November 10, 2009, 74 FR 57907.

Incentive Funds - As noted previously, the District ha s several incentive grant programs which use funds collected from a number of sources (including the Distri ct’s CAA section 185 program). These grant programs have the poten tial to generate considerable emissions reductions. While neither the CAA nor EPA polic y bar the use of emissions reductions from incentive programs to meet all or part of an area’s contingency measur e obligation, the incentive programs must assure that the re ductions are surplus, quantifiable, enforceable, and permanent in accordance with EPA’s guidance. See “Improvi ng Air Quality with Economic Incentive Programs,” EPA-452/R-01-001 (January 2001).

The 2008 PM 2.5 Plan does not identify the incentive grant programs expected to generate the emissions reductions nor the quantity of these emissions reductions that the District intended to use to meet the contingency measure requirem ent. Therefore, we are unable to determine if they are SIP creditable or suffi cient to provide in combination with other measures the roughly one-year’s worth of RFP needed. For these reas ons, this measure does not currently meet the CAA requirements for contingency measures.

d. Conclusion Table I-3 provides a summary of the contingency measures in the SJV PM 2.5 Plan.

The 2008 PM 2.5 Plan includes suggestions for severa l potentially approvable contingency measures as well as several measures that do not meet the CAA’s minimum requirements (e.g., no additional rulemaking, quick implementati on). For many of the potential approvable contingency measures, the Plan ne ither provides sufficient information for us to determine if the emissions reductions are SIP cred itable (e.g., those from incentive grant programs) nor quantifies the expected emissions reductions from them. The 2011 Progress Report, however, does show th at there are surplus reductions in the RFP demonstration for 2012. Appendix C, Table C-1. As shown on Table I-4, these surplus reductions do not provide emissions reductions e quivalent to approximately one-year’s worth of RFP when considered on a per-pollutant basis. EPA believes that these surplus reductions are insufficient to meet the CAA’s require ments for RFP contingency measures. 40
As also shown on Tables I-3 and I-4, the cont inuing implementation of the State’s mobile source program in combination with the Dist rict’s contingency m easure in Rule 4901, if triggered, will reduce emissions substantially in 2015 (the year after th e attainment year of

40 In the 2011 Progress Report, the St ate asserts that these reductions are equal to at least one-year’s worth of RFP when considered on a PM 2.5 equivalency basis; however, to make this showing, the State relies in part on an interpollutant trading ratio of 1 ton of SO x reductions to 1 ton of PM 2.5 reductions. As discussed in section II.B.4. of this TSD, there is insufficient technical support for this ra tio and EPA is proposing to not allow its use as part of the 2008 PM 2.5 Plan. EPA may consider additional technical information submitted by the State to support an appropriate trading ratio and will provide an opportunity for public comment on such new information before allowing its use to m eet a CAA requirement.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 132 2014). However, these reductions do not provide emissions reductions equivalent to one year’s worth of RFP when considered on a per-polluta nt basis. EPA believes that these surplus reductions are insufficient to meet the CAA’s re quirements for attainment contingency measures. Based on the above evaluation, EPA proposes to disapprove the RFP and attainment contingency measures in the SJV 2008 PM 2.5 SIP pursuant to CAA section 172(c)(9) and 40 CFR § 51.1012. Because we are proposing to approve the R FP and attainment demonstrations and the motor vehicle emission budgets, we are proposing to issue a protective finding under 40 CFR § 93.120(a)(3) should we finalize a disapproval of the contingency measures. Without a protective finding, final disappr oval would result in a conformity freeze, under which only projects in the first four year s of the most recent conforming Regional Transportation Plan and Transportation Improvement Programs can pro ceed. During a freeze, no new RTPs, TIPs or RTP/TIP amendments can be found to conform. See 40 CFR § 93.120(a)(2). Under a protective finding, however, final disapproval of the cont ingency measures would not result in a transportation conformity freeze in the San Joaquin PM 2.5 nonattainment area.TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 133Table I-3Summary of Approvability of Contingency Measures from the SJV 2008 PM2.5PlanMeasureRFP orAttainmentContingencyMeasure?Approvable as aContingencyMeasure?CommentTons per Average Annual DayYearDirectPM2.5NOxSOxRequest CARB to expediteimplementation of mobilesource controlsBoth NoRequires additional rulemaking,no short term reductionsN/A N/A N/AOzone Nonattainment AreaFee2012 RFPmilestone/AttainmentNoReductions are not SIPcreditable (see Incentivefunds—currently not SIPcreditable)Not quantifiedIncentives Funds –currently SIP creditableBoth YesNot quantifiedIncentive Funds – currentlynot SIP creditableBoth NoReductions are not SIPcreditableNot quantifiedExcess Reductions in RFPDemonstrationRFP Yes 2012 0 19.7 5“New” Post AttainmentYear ReductionsAttainment Yes 2015 0.0 21 3Revisions to Rule 43072012 RFPmilestone/AttainmentNoReductions assumed in RFPand attainment demonstrations2012 N/A N/A N/A2015 N/A N/A N/ARevisions to Rule 4702 Attainment No Rule not adopted 2015 – –– –Contingency provision inRule 4901Attainment Yes 2015 1.61Not quantified1Phone conversation, Jessi Fierro, SJVAPCD, and Frances Wicher, EPA, August26, 2010, value is average annual day.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 134 Table I-4 

### Summary of Reductions from Contingency Measures (tons per average annual day)

Direct PM 2.5 NO x SO x 2012 RFP contingency reductions (-2.9) 18 5
Attainment contingency reductions 1.6 21 3 1-year’s worth of RFP 2.5 31.6 0.2TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 135 

### J. Adequacy of the Motor Vehicle Emissions Budgets in the SJV 2008 PM 2.5 

### SIP

1. Requirements for Motor Vehicle Emissions Budgets CAA section 176(c) requires Federal actions in nonattainment and maintenance areas to conform to the SIP’s goals of eliminating or re ducing the severity and number of violations of the NAAQS and achieving expeditious attainment of the standards. Conformity to the SIP’s goals means that such actions wi ll not: (1) cause or contribute to violations of a NAAQS, (2) worsen the severity of an existing violation, or (3) delay timely attainment of any NAAQS or any interim milestone. Actions involving Federal Highway Admi nistration (FHWA) or Federal Transit Administration (FTA) funding or approval are subject to the EP A’s transportation conformity rule, codified at 40 CFR part 93, subpart A. U nder this rule, metropolitan planning organizations (MPOs) in nonattainment and main tenance areas coordinate with state and local air quality and transportation agencies, EPA, FHWA, and FTA to demonstrate that an area’s regional transportation plans (RTP) and transportation improvement programs (TIP) conform to the applicable SIP. This demonstrat ion is typically done by showing that estimated emissions from existing and planned highway and transit systems are less than or equal to the motor vehicle emissions budgets (budgets) contained in all contro l strategy SIPs. An attainment, maintenance, or RFP SIP should include budgets for the attainment year, each required RFP year or last year of the maintenance plan, as appropriate. Budgets are generally establishe d for specific years and specific pollutants or precursors.

PM 2.5 attainment and RFP plans shou ld identify budgets for direct PM 2.5 and PM 2.5 attainment plan precursors. All direct PM 2.5 SIP budgets should include direct PM 2.5 motor vehicle emissions from tailpipe, brake wear, and ti re wear. A state must also consider whether reentrained paved and unpaved road dust or highway and transit construction dust are significant contributors and should be in cluded in the direct PM 2.5 budget. See 40 CFR § 93.102(b) and § 93.122(f) and the conformity rule pr eamble at 69 FR 40004, 40031–40036 (July 1, 2004). MPO may use budgets in a submitted but not-y et approved SIP only if EPA has first determined that the budgets are adequate. To be found adequate and to be eventually approved, the submittal must meet the c onformity adequacy requirements of 40 CFR § 93.118(e)(4) and be approvable under all pertinent SIP requirements. In addition, the budge ts must reflect all of the motor vehicle control measures contained in the attainment and RFP demonstrations. See 40 CFR § 93.118(e)(4)(v).TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 136 2. Motor Vehicle Emissions Budgets in the SJV 2008 PM 2.5 SIP

a. MVEB Submitted in SJV 2008 PM 2.5 Plan (submitted June 2008)

The SJV 2008 PM 2.5 Plan included budgets for direct PM 2.5 and NO x for the attainment year of 2014 and the RFP years of 2009 and 2012. See 2008 PM 2.5 Plan, Section 7.2.2 and Appendix C. The direct PM 2.5 budgets included tailpipe, brake w ear, and tire wear emissions but did not include paved road, unpaved road, and road construction dust because these were determined to be insignificant contributors to PM 2.5 levels in the Valley. 2008 PM 2.5 Plan, p. 7-5. No budgets for SO x were included because on-road emissions of SO x were also considered insignificant. Id. No budgets were included for either VOC or ammonia because neither was considered a PM 2.5 attainment plan precursor in the 2008 PM 2.5 Plan. See section II.C of this TSD.

b. Updated MVEB Submitted in 2011 Progress Report CARB submitted updated MVEB for the San Jo aquin Valley and their documentation in Appendices D and A, respectively, of the 2011 Progr ess Report. See Tables J-1 and J-2 below. The updated MVEB are for direct PM 2.5 and NO x for the RFP year of 2012 and the attainment year of 2014. No budgets were included for th e RFP year of 2009 because it is no longer applicable as a conformity analysis year. Addi tional information associated with the motor vehicle emission budget calculations were provided in Attachme nt 4 of CARB Progress Report supplement. This submittal also includes a proposed trading mechanism for transportation conformity analyses that would allow future decreases in NO x emissions from on-road mobile sources to offset any on-road increases in PM 2.5 , using a NO x :PM 2.5 ratio of 9:1. Transportation conformity trading mechanisms are allowed under 40 CFR § 93.124. The basis for the trading mechanism is the SIP attainment modeling which establ ished the relative contribution of each PM 2.5 precursor pollutant. As proposed in the 2011 Progress Report, this trading mechanism would only be used, if needed, for conformity analyses for years after 2014 and, to ensu re that the trading mechanism does not impact the ability of the SJV to meet the NO x budget, the NO x emissions reductions available to supplement the PM 2.5 budget would only be those remaining after the 2014 NO x budget has been met. Clear documentation of th e calculations used in the trade would be included in the conformity analysis. See 2011 Progress Report, Appendix D, footnote to Table D-2.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 137 Table J-1 

### Updated PM 2.5 

### MVEB for the San Joaquin Valley (tons per average annual day) 1

County 2012 2014

PM 2.5 NO x PM 2.5 NO x Fresno 1.6 35.9 1.1 31.3 Kern (SJV) 2.0 49.3 1.3 43.6 Kings 0.5 10.6 0.3 9.3

Madera 0.5 9.2 0.3 8.0

Merced 0.9 19.9 0.6 17.4 San Joaquin 1.1 24.5 0.9 21.5

Stanislaus 0.8 16.7 0.6 14.6

Tulare 0.7 15.7 0.5 13.7

1. Budgets are rounded up to the nearest tenth ton (0.1).

Table J-2 below shows how the updated MVEBs were calculated. The baseline inventories are the initial SIP on-road mobile source inventory submitted in the Appendix C of the SJV 2008 PM 2.5 Plan. These baseline inve ntories continue to be based on the activity data (e.g. vehicle miles travelled) provided by the SJV 2008 PM 2.5 Plan as submitted in June 2008. The first adjustment, “State Strategy Adjustment,” incorporates the impa cts of both the recession and the reductions from the amended Truck and Bus regulations, the solid waste collection and public fleet vehicles regulations, heavy duty chip re-flash, and h eavy duty truck idling regulations, smog check improvements, reformulat ed gasoline and Distri ct Rule 9510 Indirect Source Rule (SJV ISR rule). The second adjustme nt, “Adjustments to Baseline,” include the reductions from Assembly Bill 1493 (Pavley – greenhouse gas motor vehicle emissions standards), benefits from the on -road portion of the Ca rl Moyer program and benefits from the SJV District’s Rule 9310 for School Buses.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 138 Table J-2 

### Calculation of the Updated PM 2.5 

### MVEB for the San Joaquin Valley
(tons per average annual day)

County 2012 2014

PM 2.5 NO x PM 2.5 NO x

Fresno Baseline Inventory 1.82 47.82 1.65 40.6 State Strategy Adjustment 0.29 11.61 0.54 9.07 Adjustment to Baseline 0.01 0.35 0.02 0.29 Budget 1.6 35.9 1.1 31.3

Kern (SJV) Baseline Inventory 2.98 81.58 2.63 70.28 State Strategy Adjustment 1.02 31.77 1.42 26.29 Adjustment to Baseline 0.01 0.57 0.01 0.40 Budget 2.0 49.3 1.3 43.6

Kings Baseline Inventory 0.59 16.00 0.51 13.52 State Strategy Adjustment 0.18 5.33 0.25 4.20 Adjustment to Baseline 0.00 0.12 0.00 0.09 Budget 0.5 10.6 0.3 9.3

Madera Baseline Inventory 0.50 12.30 0.46 10.62 State Strategy Adjustment 0.10 3.04 0.17 2.55 Adjustment to Baseline 0.00 0.10 0.01 0.09 Budget 0.5 9.2 0.3 8.0

Merced Baseline Inventory 1.19 29.15 1.05 24.67 State Strategy Adjustment 0.35 9.11 0.49 7.16 Adjustment to Baseline 0.01 0.23 0.01 0.18 Budget 0.9 19.9 0.6 17.4

San Joaquin Baseline Inventory 1.39 35.24 1.29 30.27 State Strategy Adjustment 0.32 10.51 0.45 8.58
Adjustment to Baseline 0.01 0.26 0.01 0.20
Budget 1.1 24.5 0.9 21.5TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 139 Table J-2 

### Calculation of the Updated PM 2.5 

### MVEB for the San Joaquin Valley
(tons per average annual day)

County 2012 2014

PM 2.5 NO x PM 2.5 NO x

Stanislaus Baseline Inventory 0.84 22.25 0.76 18.69 State Strategy Adjustment 0.13 5.42 0.22 4.04 Adjustment to Baseline 0.00 0.15 0.00 0.10 Budget 0.8 16.7 0.6 14.6

Tulare Baseline Inventory 0.75 20.87 0.69 17.88 State Strategy Adjustment 0.11 5.05 0.20 4.05 Adjustment to Baseline 0.00 0.16 0.01 0.14 Budget 0.7 15.7 0.5 13.7

Source: 2011 Progress Report, Appendix A, Table A-2

c. Revision to Updated MVEB to be Submitted by CARB

On June 3, 2011, we received a letter from CARB 41 indicating that they will revise the budgets to remove emissions reductions from the SJV ISR rule. The letter was in response to EPA’s action approving the SJV ISR rule as documented in Federa l Register Notices published on May 21, 2010 (75 FR 28509) and May 9, 2011 (76 FR 26609). In our approval of the SJV ISR rule, we indicated that the projected emi ssions reductions from the rule should not be credited in any attainment and rate of progre ss/reasonable further progress demonstrations. The letter from CARB stated that they intend to revise the budgets in the 2011 Progress Report by recalculating the budgets without re ductions from the SJV ISR rule. On June 20, 2011, CARB posted on its website technical revisions to the updated MVEB in the 2011 Progress Report. See CARB, “Propose d 8-Hour Ozone State Implementation Plan Revisions and Technical Revisions to the PM 2.5 State Implementation Plan Transportation Conformity Budgets for the South Coast and San Joaquin Valley Air Basins,” June 20, 2011, posted at www.arb.ca.gov/planning/sip/2007sip/2007s ip.htm. These revised updated MVEB are given in Table J-3 below. The technical revisi ons corrected data entr y errors in the budget calculations and removed the emission reductions attributed to SJV ISR rule. Table J-4 below shows how the revised updated MVEBs were calc ulated. Baseline and adjustments are the same as those for the updated MVEB in the 2011 pr ogress report, except for the exclusion of

41 See letter, James M. Goldstene, Executive Officer, CARB, to Deborah Jordan, Air Division Director, EPA Region 9, dated June 3, 2011.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 140 reductions from the ISR rule. CARB expects to a dopt these revised update d budgets at its July 21, 2011 board meeting. See CARB, “Notice of Pub lic Hearing to Consid er the Approval of Proposed State Implementation Plan Revisions for the 8-Hour Ozone and Minor Technical Revisions to the PM 2.5 SIP Transportation Conformity Budgets,” June 20, 2011.

Table J-3 

### Revised Updated PM 2.5 

### MVEB for the Sa n Joaquin Valley (tons per average annual day) 1

County 2012 2014

PM 2.5 NO x PM 2.5 NO x Fresno 1.5 35.7 1.1 31.4 Kern (SJV) 1.9 48.9 1.2 43.8 Kings 0.4 10.5 0.3 9.3

Madera 0.4 9.2 0.3 8.1

Merced 0.8 19.7 0.6 17.4 San Joaquin 1.1 24.5 0.9 21.6

Stanislaus 0.7 16.7 0.6 14.6

Tulare 0.7 15.7 0.5 13.8

Source: CARB, Proposed 8-Hour Ozone SIP Revision, June 20, 2011, p. A-6. Budgets are rounded up to the nearest tenth ton (0.1).TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 141 Table J-4 

### Calculation of the Revised Updated PM 2.5 

### MVEB for the San Joaquin Valley
(tons per average annual day)

County 2012 2014

PM 2.5 NO x PM2.5 NO x

Fresno Baseline Inventory 1.82 47.82 1.65 40.60 State Strategy Adjustment 0.36 11.99 0.56 9.07 Adjustment to Baseline 0.01 0.16 0.02 0.22 Budget 1.5 35.7 1.1 31.4

Kern (SJV) Baseline Inventory 2.98 81.58 2.63 70.28 State Strategy Adjustment 1.14 32.46 1.44 26.29 Adjustment to Baseline 0.01 0.23 0.01 0.28 Budget 1.9 48.9 1.2 43.8

Kings Baseline Inventory 0.59 16.00 0.51 13.52 State Strategy Adjustment 0.20 5.47 0.26 4.20 Adjustment to Baseline 0.00 0.05 0.00 0.06 Budget 0.4 10.5 0.3 9.3

Madera Baseline Inventory 0.50 12.30 0.46 10.62 State Strategy Adjustment 0.12 3.14 0.17 2.55 Adjustment to Baseline 0.01 0.05 0.01 0.07 Budget 0.4 9.2 0.3 8.1

Merced Baseline Inventory 1.19 29.15 1.05 24.67 State Strategy Adjustment 0.40 9.37 0.50 7.16 Adjustment to Baseline 0.01 0.11 0.01 0.14 Budget 0.8 19.7 0.6 17.4

San Joaquin Baseline Inventory 1.39 35.24 1.29 30.27 State Strategy Adjustment 0.36 10.73 0.46 8.58
Adjustment to Baseline 0.01 0.11 0.01 0.14
Budget 1.1 24.5 0.9 21.6TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 142 Table J-4 

### Calculation of the Revised Updated PM 2.5 

### MVEB for the San Joaquin Valley
(tons per average annual day)

County 2012 2014

PM 2.5 NO x PM2.5 NO x

Stanislaus Baseline Inventory 0.84 22.25 0.76 18.69 State Strategy Adjustment 0.16 5.58 0.23 4.04 Adjustment to Baseline 0.00 0.06 0.00 0.07 Budget 0.7 16.7 0.6 14.6

Tulare Baseline Inventory 0.75 20.87 0.69 17.88 State Strategy Adjustment 0.13 5.19 0.21 4.05 Adjustment to Baseline 0.00 0.07 0.01 0.10 Budget 0.7 15.7 0.5 13.8

Source: Source: CARB, Proposed 8-Hour Ozone SIP Revision, June 20, 2011, p. C-11. Budgets are rounded up to the nearest tenth ton (0.1).

3. Proposed Actions on the MVEB

a. April 23, 2010 Budget Adequacy/Inadequacy Finding On April 23, 2010, we notified CARB that we had found the budgets in the 2008 PM 2.5 Plan for the RFP milestone years 2009 and 2012 were adequate and that the MVEBs for the attainment year of 2014 were inadequate for transportation conformity purposes. We determined that the attainment year budgets were inadequate becau se they lacked specificity or enforceability of the emissions reductions relied on to demonstration a ttainment and therefore did not meet the requirements of our adequacy criteria at 40 CFR § 93.1 18(e)(4)). See letter Deborah Jordan, EPA Region 9, to James Goldst ene, CARB, “RE: Adequacy Status of San Joaquin Valley PM 2.5 Reasonable Further Progress and Attainment Plan Motor Vehicle Emissions Budgets,” April 23, 2010. We publishe d a notice of our findings at 75 FR 26749 (May 12, 2010). The finding is available at EPA’s transportation conformity website, www.epa.gov/otaq/stateresour ces/transconf/pastsips.htm.

b. 2010 Proposed Action on the MVEBs in the SJV 2008 PM 2.5 SIP The April 2010 adequacy determination was ba sed on our preliminary review of the plan. During our subsequent more in depth review of the Plan, we proposed to determined that the 2008 PM 2.5 Plan did not provide for reasonabl e further progress as required by CAA section 172(c)(2). 75 FR 74518, 74537. As a resu lt of this determination, we proposed toTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 143 disapprove the budgets for the RFP years. Specifi cally, the budgets, when considered together with all other emission sources, are inconsistent with applicable requ irements for reasonable further progress and attainment. 75 FR 74518, 74539. 42
We also proposed to disapprove the budgets for the attainment year of 2014, which we had already found to be inadequate, based on our initial proposed determination that the SJV 2008 PM 2.5 Plan does not provide for attainment. See 75 FR 74518, 74536.

c. Proposed Action on the Revised Update MVEB EPA has evaluated the revised updated budge ts against our ade quacy criteria in 40 CFR § 93.318(e)(4) as part of its review of the budgets’ approvability. The results of its this review are shown in the Table J-5 below. EPA is not required under its Transportation Conformity rules to find budgets adequate pr ior to proposing approval of them. We will, however, complete the adequacy review of these budgets which could occur when we take a final action on this SIP or it could ha ppen at an earlier date. We wi ll also post the revised updated budgets on EPA’s adequacy review web page. As discussed in sections II.G. and II.H, we have completed our detailed review of the 2008 SJV PM 2.5 SIP and supplemental submittals including the 2011 Progress Report. Based on this thorough review of these submittals, we are proposing to approve the attainment and RFP demonstrations in the 2008 SJV PM 2.5 SIP. As indicated above, we have received a letter from CARB indicating that they will revise the budgets to remove emissions reductions from the SJV ISR rule. EPA cannot approve the budgets curren tly included in the 2011 Progress Report or find them adequate since we have not approved SIP credit for the SJV ISR rule. CARB has now revised the updated budgets to remove the credit fo r the ISR rule as well as to corrected data entry errors in the budget calcula tions. Once adopted and a complete submittal made, the revised updated MVEB should be consistent with the atta inment and RFP demonstrations and meet all other applicable statutory and re gulatory requirements including mee ting the adequacy criteria in §93.118(e)(4). EPA proposes, therefore, to appr ove the revised updated MVEB contingent upon our receipt of a complete SIP submittal containing them. Note that if CARB is unable to adopt and submit these revisions, then EPA will fi nd inadequate and disapprove the updated MVEB contained in the 2011 Progress Report. If we di sapprove the updated MVEB, a conformity freeze would take effect upon the effective date of th e disapproval(usually 30 days after publication of the final action in the Federal Register ). A conformity freeze means that only projects in the first four years of the most recent conformi ng RTP and TIP can proceed. During a freeze, no new RTPs, TIPs or RTP/TIP amendments can be found to conform. See 40 CFR § 93.120.

42 Neither EPA’s November 30, 2010 proposed disapproval of the RFP budgets nor the proposed approval of the revised updated budgets affects the adequacy status of these budgets. They remain adequate for transportation conformity purposes until a final action finding them inad equate and disapproving them, a final action approving replacement budgets, or a final action disapprov ing replacement budgets becomes effective.TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 144Table J-2Evaluation of the Proposed Revised Updated Motor Vehicle Emissions BudgetJune 2011Adequacy Review Criteria(40 CFR part 93)Is CriterionSatisfied?Reference in SIP Document/CommentsSec.93.118(e)(4)(i)The plan was endorsed by theGovernor (or designee) and wassubject to a public hearing.YSee section I.C. and I.D. of this TSD. Proposed revised updated MVEB havebeen noticed for public hearing. See CARB, “Notice of Public Hearing toConsider the Approval of Proposed State Implementation Plan Revisions forthe 8-Hour Ozone and Minor Technical Revisions to the PM2.5SIPTransportation Conformity Budgets,” June 20, 2011.Sec.93.118(e)(4)(ii)The plan was developed throughconsultation with federal, state andlocal agencies; full implementationplan documentation was providedand EPA’s stated concerns, if any,were addressed.YThe 2008 PM2.5Plan was developed through consultation with federal, stateand local agencies which place withthe San Joaquin Valley interagencyconsultation working group (the Model Coordinating Committee). Members ofthe consultation group include: EPA,FHWA, FTA, CARB, Caltrans, the SanJoaquin Valley Unified Air Pollution Control District (SJVUAPCD), and eachcounty’s Metropolitan Planning Organization (MPO). The 2011 ProgressReport and its Appendices A and D which describe the revised MVEB weremade available to the MPOs and other agencies for review and commentduring the public comment period. EPAreceived a copy ofthe draft 2011Progress Report, the SJV 2008 PM2.5Plan and draft State Strategy butprovided no written comments. However, in response to EPA’s requests foradditional information, CARB provided Attachment A in the CARB ProgressReport supplement. CARB has now posted additional revisions to the updatedbudgets for public comment.Sec.93.118(e)(4)(iii)The motor vehicle emission budgetsare clearly identified and preciselyquantified.YThe updated MVEB for 2012 and 2014are clearly identified and preciselyquantified in Appendix A (Table A-2) of the 2011 Progress Report and furtherdescribed in Attachment A of the May 18, 2011 letter. These budgets reflectcontrol measures that were already adopted at the time the CARB adopted the2011 Progress Report on April 28, 2011. 2011 Progress Report, Appendix A,p. 3. CARB did not update the MVEB for 2009 because the 2009 budgets arelonger needed for any conformity determination in the SJV. 2011 ProgressReport, Appendix D.TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 145Table J-2Evaluation of the Proposed Revised Updated Motor Vehicle Emissions BudgetJune 2011Adequacy Review Criteria(40 CFR part 93)Is CriterionSatisfied?Reference in SIP Document/CommentsSec.93.118(e)(4)(iv)The motor vehicle emissionsbudget(s), when considered togetherwith all other emission sources, isconsistent with applicablerequirements for reasonable furtherprogress and attainment.YEPA has concluded that the updated budgets for the year 2012 whenconsidered together with all other emission sources are consistent with therequirement to demonstrate reasonable further progress for the 1997 annualand 24-hour PM2.5standards. This finding is based on review of the revisedRFP demonstrations in Appendix C (Table C-1) of the 2011 Progress Report.As documented in Section II.H. of this TSD, EPA is proposing to approve therevised RFP demonstration.EPA has concluded that the updated budgets for the year 2014 whenconsidered together with all other emission sources are consistent with therequirement to demonstrate expeditious attainment of the 1997 annual and 24-hour PM2.5standards. This finding is based on review of the revised attainmentdemonstrations in the 2011 Progress Report. As documented in Section II.G.of this TSD, EPA is proposing toapprove the revised attainmentdemonstration.The updated MVEBs for direct PM2.5do not include emissions from reentrained road dust (paved and unpaved) or road/transit construction activities.The 2008 SJV PM2.5plan, pp. 7-5 & 7-6, concluded that neither are significantcontributors to PM2.5emissions in the SJV. EPA agrees that re-entrained roaddust is not a significant contributor to PM2.5 emissions in the San JoaquinValley.The 2011 Progress Report does not include budgets for the PM2.5precursorSOxbecause on-road vehicles are projectedto be an insignificant contributor toPM2.5levels in the SJV in both 2012 and 2014. 2008 SJV PM2.5plan, pp. 7-5.The 2011 Progress Report also does not include budgets for the PM2.5precursors VOC and ammonia because they are not considered attainmentPM2.5precursors in the SJV and thus are not required to be controlled for PM2.5attainment. See SJV PM2.5plan, pp. 7-4 & 7-5 and section II.C. of this TSD.CARB will be submitting revisions to the updated MVEBs removing theemissions reductions associated with the SJV ISR Rule and to correct dataentry errors. Once revised the updatedMVEB’s will be consistent with thecreditable RFP and attainment demonstrations. CARB has posted for publiccomment the revisedupdated budgets.TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 146Table J-2Evaluation of the Proposed Revised Updated Motor Vehicle Emissions BudgetJune 2011Adequacy Review Criteria(40 CFR part 93)Is CriterionSatisfied?Reference in SIP Document/CommentsSec.93.118(e)(4)(v)The plan shows a clear relationshipamong the emissions budget(s),control measures and the totalemissions inventory.YThe emissions inventory for all stationary, area, on-road mobile, and non-roadmobile sources, and their relation to control measures and the reductions fromexisting measures are described in Appendix A of 2007 State Strategy andAppendix B of the SJV 2008 PM2.5Plan as updated by 2011 Progress Report.The final inventories incorporating the reductions from adopted measures aregiven in Tables B-1 and B-2 in Appendix B to the SJV 2008 PM2.5Plan andAppendix A, D and E of the 2011 Progress Report and Attachment A in theCARB Progress Report supplement.Sec.93.118(e)(4)(vi)Revisions to previously submittedcontrol strategy or maintenance plansexplain and document any changes toany previous submitted budgets andcontrol measures; impacts on pointand area source emissions; anychanges to established safety margins(see §93.101 for definition), andreasons for the changes (includingthe basis for any changes to emissionfactors or estimates of vehicle milestraveled).YCARB submitted revisions to the attainment and RFP demonstration in theSJV 2008 PM2.5Plan as part of the 2011 Progress Report. See Appendices A –D and Attachment A in CARB Progress Report supplement. Attachment Aspecifically documents the changes in theplanning factors, the new heavy dutytruck inventory and the revisions to the control measures included in theupdated budgets from the original budgets. EPA analyzed the informationincluded in these reports to confirm that the updated MVEB are consistentwith previous MVEB and revised as documentedNote that CARB did not update the MVEB for 2009 because the 2009 budgetsare longer needed for any conformity determination in the SJV. 2011 ProgressReport, Appendix D.CARB will be submitting revisions to the updated MVEB removing theemissions reductions associated with the SJV ISR Rule and to correct dataentry errors.TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page 147Table J-2Evaluation of the Proposed Revised Updated Motor Vehicle Emissions BudgetJune 2011Adequacy Review Criteria(40 CFR part 93)Is CriterionSatisfied?Reference in SIP Document/CommentsSec.93.118(e)(5)EPA has reviewed the State’scompilation of public comments andresponse to comments that arerequired to be submitted with anyimplementation plan.YThe 2008 PM2.5Plan contains public comments and SJVUAPCD responses inappendix J to the Plan. Additional verbal comments were received during theadoption public hearings held by the SJVUAPCD and CARB and are alsoincluded as attachments to the June 2008 SIP submittal. Additional written andverbal comments were received duringthe public comment period and publichearing on the 2011 Progress Report. See CARB Resolution 11-24, p. 3. Wehave reviewed the compilation of comments and responses and find theresponses (where provided) to be acceptable. No issues that might haveaffected our adequacy finding remain unanswered.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page 148 4. Proposed Action on Trading Mechanism As noted above, CARB included a trading m echanism to be used in transportation conformity analyses that use the proposed budgets as allowed for under 40 CFR § 93.124. This trading mechanism would allow future decreases in NO x emissions from on-road mobile sources to offset any on-road increases in PM 2.5 , using a NO x :PM 2.5 ratio of 9:1. As proposed by CARB, the trading mechanism would only be used, if n eeded, for conformity analyses for years after 2014. Also, to ensure that the trading mechanism doe s not impact the ability of the SJV to meet the NO x budget, the NO x emissions reductions available to supplement the PM 2.5 budget would only be those remaining after the 2014 NO x budget has been met. The trading mechanism will be implemented with the following criter ia. The trading applies only to:

• Analysis years after th e 2014 attainment year.

• On-road mobile emission sources.

• Trades using vehicle NO X emissions reductions in exce ss of those needed to meet the NO x budget.

• Trades in one direction from NO X to direct PM 2.5
.

• A trading ratio of 9 tpd NO X to 1 tpd PM 2.5
. Clear documentation of the calculations used in the trade would be included in the conformity analysis. See 2011 Progress Repor t, Appendix D, foot note to Table D-2.

EPA has reviewed the 9:1 NO x :PM 2.5 ratio as discussed in section II.D.4. of this TSD, and finds it appropriate ra tio for trading between NO x and direct PM 2.5 for transportation conformity purpose in the San Joaquin Valley for the 1997 PM 2.5 NAAQS. The method discussed in the documentation appears to be ade quate for purposes of assessing the effect of area-wide emissions changes, such as are used in conformity budgets.

EPA believes that the 2008 PM 2.5 Plan as revised by the 2011 Progress Report includes an approvable trading mechanism for determini ng transportation conform ity after 2014. EPA is proposing to approve the trading mechanism and a ll of the criteria included in the footnote to Table D-2 as enforceable components of the tran sportation conformity program for the SJV for the 1997 PM 2.5 NAAQS. EPA is also proposing to approve th e use of this ratio in transportation conformity determinations for the 2006 24-hour PM 2.5 NAAQS but only until such time EPA finds adequate or approves budgets deve loped specifically for the 2006 standard.

### Appendix A – CARB Rules and MeasuresTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-1 

### A. Complete List of State Measures

Appendix Table A-1 is a list of all measur es adopted by CARB from 1990 until the end of 2006. This period covers the 18 years prior to the development of the 2007 State Strategy and the SJV 2008 PM 2.5 Plan. The table should include any s ubstantive rules that would still be generating emissions reductions in the San Jo aquin Valley during the 2005-2014 period covered by the Plan and thus reflected in the baseline for the Plan. This list does not include the limits on pe sticide emissions adopted by the California Department of Pesticide Regulation nor the Stat e’s inspection and maintenance program adopted by the California Bureau of Automotive Repair. Measures that are categorized as Not Applicable are either solely administrative (e.g., permit fees, state ambient air qua lity standards), do not addr ess particulate matter or a PM 2.5 attainment plan precursor in the SJV (e.g., asbest os air toxic control me asure), or otherwise do not affect emissions in the SJV (e.g., test methods).

Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Antiperspirant/Deodorants. . T 17, CCR, 94500-94506 11/09/89 Consumer products

Transported Pollutants (Ozone). . T 17, CCR, 70500 12/04/89 Not applicable

Emission Control System Warranty. . T 13, CCR, 2035- 2041, 1977 12/14/89 On-road

Non-vehicular Test Methods. . T 17, CCR, 94002, 94003 17, &26, 94146-94149, 94132, 94135, 94139, 94140 01/11/90 Not applicable

Certification Procedure for Aftermarket Parts. VC 27156 & 38391 02/08/90 On-road

Airborne Toxic Control Measure for Asbestos in Surfacing Applications. . T 17, & 26, CCR, 93106 04/12/90 Not applicable

Test Method for Asbestos in Serpentine Aggregate. . T 17, & 26, CCR, 94147, Method 435 04/12/90 Not applicable

Air Toxics "Hot Spots" Fee Regulation. . T 17, & 26, CCR, 90700-90704, 93300-93347 05/10/90 Not applicable

Airborne Air Toxic Measure for Ethylene Oxide from Sterilizers & Aerators. . T 17, CCR, 93108 05/10/90 Not applicable

Permit Fee Regulations for Non-vehicular Sources. . T 17, CCR, 90800.1, 90800, 90802-90803 05/10/90 Not applicableTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-2 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Air Toxics "Hot Spots" Emissions Inventory Criteria and Guidelines. . T 17, & 26, CCR, 93300-93347 06/14/90 Not applicable

Consumer Products Regulations for the BAAQMD. . T 17, CCR, 94520-94526 06/14/90 Consumer products

Criteria for Area Designations for the State Ambient Air Quality Standard. . T 17, CCR, 70303 & 70304 06/14/90 Not applicable

Emission Standards for Medium Duty Vehicles. . T 13, CCR, 1900, 1956.8, 1960.1, 1968.1, 2061, 2112, 2139 06/14/90 On-road

Wintertime Limits for Sulfur in Diesel Fuel. . T 13, CCR, 2255 06/21/90 Fuels

Dioxins Airborne Toxic Control Measure for Medical Waste Incinerators. . T 17, CCR, 93104 07/12/90 Not applicable

Emissions Reduction Accounting Procedures for California Clean Air Act. . T 17, CCR, 70700-70704 07/12/90 Not applicable

Identification of Inorganic Arsenic as a Toxic Air Contaminant. . T 17, & 26, CCR, 93000 07/12/90 Not applicable

Evaporative Emission Standards. . T 13, CCR, 1976 08/09/90 On-road

Transport Mitigation Regulations. . T 17, CCR, 70600- 70601 08/09/90 Not applicable

Air Toxic Fee Schedule & Emissions Inventory Criteria and Guidelines. . T 17, & 26, CCR, 90700-90704, 93300- 93347 09/13/90 Not applicable

California Reformulated Gasoline (CaRFG), Phase I. . T 13, CCR, 2251.5 09/27/90 Fuels

Low Emission Vehicles and Clean Fuels. . T 13, CCR, 1900, 1904, 1956.8, 1960.1, 1960.1.5, 1960.5 and 2111, 2112, 2125, and 2139, 2061. 09/28/90 On-road

Identification of Trichlor oethylene as a Toxic Air Contaminant. . T 17, & 26, CCR, 93000 10/11/90 Not applicable

Phase I - Consumer Products. . T 17, CCR, 94507-94517 10/11/90 Consumer products

Controls for Abrasive Blasting. . T 17, CCR, 92000, 92200, 92400, 98500, 98510, 92520, 92530 11/08/90 Not applicableTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-3 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Heavy Duty Diesel Smoke Emission Testing. . T 13, CCR, 2180-2187 11/08/90 On-road

Revision to Designation Criteria. . T 17, CCR, 60200- 60204, 60208 11/08/90 Not applicable

Identification of Vinyl Chloride as a Toxic Air Contaminant. . T 17, & 26, CCR, 93000 11/13/90 Not applicable

Conflict of Interest Code. . T 17, CCR, 95001, et. seq. 12/13/90 Not applicable

Emission Standards for Utility and Lawn and Garden Engines. . T 17, CCR, 2400 et. seq. 12/13/90 Off-road

Identification of Chloroform as a Toxic Air Contaminant. . T 17, & 26, CCR, 93000 12/13/90 Not applicable

Limit on Aromatic Content of Diesel Fuel. . T 13, CCR, 2256 12/13/90 Fuels

Permit Fee Regulations for Non-vehicular Sources. . T 17, CCR, 90800.2, 90801, 90803 02/24/91 Not applicable

Acid Deposition Fee Regulations. . T 17, CCR, 90621.2, 90620, 90622 04/11/91 Not applicable

Non -Vehicular Test Methods. . T 17, CCR, 94131, 94132, 94142 04/11/91 Not applicable

Administrative Hearing Procedures. . T 17, CCR, 60075.1, 60075.47 05/09/91 Not applicable

Air Toxics "Hot Spots" Fee Regulation. . T 17, & 26, CCR, 90700 - 90705 06/13/91 Not applicable

Agricultural Burning Guidelines. T 17, 80130, 80150, 80250, 80260, 80290 07/11/91 Not applicable

Identification of Metallic & Inorganic Nickel Compounds as a Toxic Air Contamin ant. T 17, & 26, 93000 08/08/91 Not applicable

Onboard Diagnostics for Light-Duty Trucks and Light & Medium-Duty Motor Vehicles. T 13, CCR, 1977, 1968.1 09/12/91 On-road

Identification of Perchloroethylene as a Toxic Air Contaminant. T 17, & 26, CCR, 93000 10/10/91 Not applicable

State Ambient Air Quality Standard for SO 2 . T 17, CCR, 70100, 70200, 70201 10/10/91 Not applicable

Onboard Diagnostic, Phase II. T 13, CCR, 1968.1, 1977 11/12/91 On-roadTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-4 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Area Designations. T 17, CCR, 60200, 60209 11/14/91 Not applicable

Low Emission Vehicles amendm ents revising reactivity adjustment factor (RAF) provisions and adopting a RAF for M85 transitional low emission vehicles. T 13, CCR, 1960.1 11/14/91 On-road

California Reformulated Gasoline, Phase II. T 13, CCR, 2250, 2255.1, 2252, 2260 - 2272, 2295 11/21/91 Fuels

Wintertime Gasoline Program. T 13, CCR, 2258, 2298, 2251.5, 2296 11/21/91 Fuels

Specifications for Alternative Motor Vehicle Fuel. T 13, & 26, CCR, 2290, 2291, 2292.1, 2292.2, 2292.3, 229 2.5 , 2292.6, 2292.7, 1960.1(k), 1956.8(b), 1956.8(d) 12/12/91 Fuels

Heavy Duty Diesel Cycle Engines. T 13, CCR, 2420-2427 01/09/92 Off-road

Phase II - Consumer Products. T 17, CCR, 94501, 94502, 94505, 94514, 94503.5, 94506, 94507 - 94513, 94515 01/09/92 Consumer products

Identification of Formaldehyde as a Toxic Air Contaminant. T 17, & 26, CCR, 93000 03/12/92 Not applicable

Specifications for Alternative Motor Vehicle Fuels. T 13, & 26, CCR, 2290-2292.7, 1960.1(k), 1956.8(b), 1956.8(d) 03/12/92 On-road

Atmospheric Acidity Protection Fees. T 17, CCR, 90621.3 04/09/92 Not applicable

Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90800.3, 90803 04/09/92 Not applicable

Criteria for Area Designations. T 17, CCR, 70303, 70304 05/14/92 Not applicable

Standards and Test Procedures for Alternative Fuel Retrofit Systems. T 13, CCR, 2030, 2031 05/14/92 On-road

Transported Air Pollutants. T 17, CCR, 70500 05/28/92 Not applicable
Air Toxics "Hot Spots" Fee Regulation. T 17, & 26, CCR, 90701, 90704, 90705 07/09/92 Not applicable

Identification of 1.3 Butadiene as a Toxic Air Contaminant. T 17, & 26, CCR, 93000 07/09/92 Not applicable

Phase 2 RFG certification fuel specifications. T 13, CCR, 1960.1, 1956.8(d) 08/13/92 On-roadTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-5 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

CFC Refrigerants in Air Conditioning Systems. T 13, CCR, 2500 09/10/92 Not applicable

Substitute Fuel or Clean Fuel Incorporated Test Procedures. T 13, CCR, 1960.1(k), 2317 11/12/92 On-road

Notice of General Public Interest for Consumer Products. T 17, CCR, 94507 - 94517 11/30/92 Consumer products

Airborne Toxic Control Measure for Emission of Toxic Metals from Non-Ferrous Metal Melting. T 17, & 26, CCR, 93107 12/10/92 Not applicable

Criteria for Area Designations. T 17, CCR, 70303.5, 60200-60203, 60205, 70303 12/10/92 Not applicable

Smoke Self Inspection Program for Heavy Duty Diesel & Gasoline Engines. T 13, CCR, 2190-2194, 2180-2187, 1956.8(b) 12/10/92 On-road

Certification Requirements for Low Emission Passenger Cars, Light-Duty Trucks & Medium Duty Vehicles. T 13, CCR, 1960.1, 1976, 2061, 1900 01/14/93 On-road

Transport Mitigation Regulations. T 17, CCR, 70600, 70601 03/11/93 Not applicable

1-year Implementation Delay in Emission Standards for Utility Engines. T 13, CCR, 2400, 2403-2407 04/08/93 Off-road

Acid Deposition Fee Regulations. T 17, CCR, 90622, 90621.4 04/08/93 Not applicable

Identification of Federal Hazardous Air Pollutants as Toxic Air Contaminants. T 17, & 26, CCR, 93001, 39665, 39666 04/08/93 Not applicable

Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90800.4, 90803 04/08/93 Not applicable

Air Toxics "Hot Spots" Emissions Inventory Criteria and Guidelines. T 17, & 26, CCR, 93300-93347 06/10/93 Not applicable

Urban Transit Buses. T 13, CCR, 1956.8, 1965, 2112 06/10/93 On-road

Air Toxics "Hot Spots" Fee Regulation. T 17, & 26, CCR, 90700-90705 07/08/93 Not applicable

Onboard Diagnostic, Phase II. T 13, CCR, 1968.1 07/09/93 On-roadTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-6 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Mitigation Transport Polluta nts. T 17, CCR, 70500, 70600 08/12/93 Not applicable

Wintertime Oxygenate Program. T 13, CCR, 2258, 2251.5, 2263(b), 2267, 2298, 2259, 2283, 2293.5 09/09/93 Fuels

Airborne Toxic Control Measure for Perchloroethylene Dry Cleaning. T 17, & 26, CCR, 93109, 93110 10/14/93 Not applicable

Diesel Fuel Regulations - Emergency. T 13, CCR, 2281(h), 2282(1) 10/15/93 Fuels

Conflict of Interest. T 17, CCR, 90500 11/18/93 Not applicable

Criteria for Area Designations. T 17, CCR, 60200-60202, 60204, 60206, 60208, 70300-70306 11/18/93 Not applicable

Off-Highway Recreational Vehicles. T 13, CCR, 2410- 2414, 2111-2140 01/03/94 Off-road

Evaporative Emission Standard s and Test Procedures. T 13, CCR, 1976 02/10/94 On-road

SCAQMD's Reclaim Consideration 03/10/94 Not applicable
Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90800.5, 90803 04/14/94 Not applicable

Predictive Model for Phase II CaRFG. T 13, CCR, 2261, 2262-2270 06/09/94 Fuels

Small Refiner Diesel. T 13, CCR, 2282(e)(1) 07/24/94 Fuels
Air Toxics "Hot Spots" Fee Regulation. T 17, & 26, CCR, 90700-90705 07/28/94 Not applicable

Utility and Lawn and Garden Equipment Engines. T 13, CCR, 2403(c), 11(a)(1)(I )(ii), 4(a)(1)(I)(ii) 07/28/94 Off-road

Alternative Control Plan for Consumer Products. T 17, CCR, 94540-94555 09/22/94 Consumer products

Diesel Fuel Certification. T 13, CCR, 1956.8(b)&(d), 1960.1(k), 2292.6 09/22/94 Fuels

Area Designations. T 17, CCR, 60201, 60204 11/09/94 Not applicable
Self Inspection Program for Heavy Duty Diesel & Gasoline Engines. T 13, CCR, 2190-2194, 2180-2187, 1956.8(b) 11/09/94 On-roadTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-7 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Onboard Diagnostics, Phase II. T 13, CCR,1963.1, & Certification Procedures 12/08/94 On-road

Periodic Smoke Inspection Program. T 13, CCR, 2190 12/08/94 On-road

Specification for Alterna tive Motor Vehicle Fuels (M100). T 13 CCR, 2292.1 12/08/94 Fuels

Aerosol Coating Products and Alternative Control Plan. T 17, CCR, 94520-94528, 94540-94543, 94547. 03/23/95 Consumer products

Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90800.6, 90803 04/27/95 Not applicable

Employee-Based Trip Reductions Emission Formula. T 13, CCR, 2330, 2331, 2332 06/29/95 Not applicable

Gasoline Vapor Recovery Systems. T 17, CCR, 94010- 94015, 94150-94160, 94000-94004, 94007. 06/29/95 Vapor Recovery

Heavy Duty Vehicle Exhaust Emission Standards. T 13, CCR, 1956.8 and incorporate test procedures. 06/29/95 On-road

Onboard Refueling Vapor Recovery Standards. T 13, CCR, 1976, 1978 and incorporate test procedures 06/29/95 On-road

Test Method for Oxygen in Gasoline. T 13, CCR, 2251.5(c), 2258(c), 2263(b) 06/29/95 Fuels

Retrofit Emission Standards. T 13, CCR, 1956.9, 2030, 2031, and incorporate test procedures 07/27/95 On-road

Antiperspirants and Deodorants, Consumer Products, and Aerosol Coating Products. T 17, CCR, 94500-94506, 94508, 94521 09/28/95 Consumer products

Low Emission Vehicle Standards 3 (LEV 3). T 13, CCR, 1956.8, 1960.1, 1965, 2101, 2061, 2062, and incorporate test procedures 09/28/95 On-road

Test Methods for CaRFG 13, CCR, 2263(b) 10/26/95 Fuels
Required Additives in Gasoline (Deposit Control Additives). T 13, CCR, 2257 and incorporates testing procedures. 11/16/95 FuelsTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-8 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

CaRFG Housekeeping & CARBOB. T 13, CCR, 2263.7, 2266.5, 2260, 226 2.5 , 2264, 2265, 2272 12/14/95 Fuels

Exemption of Military Tactical Vehicles. T 13, CCR, 1905, 2400, 2420 12/14/95 On Road/Off Road

Air Toxics "Hot Spots" Fee Regulation. T 17, CCR, 90700-90705 and Appendix A 01/25/96 Not applicable

CaRFG Variance Requirements. T 13, CCR, 2271 (Emergency) 01/25/96 Fuels

Relaxation of Carbon Monoxide Emission Standards for Utility Engines. T 13, CCR, 2403 and incorporating test procedures 01/25/96 Off-road

Postpone Zero Emission Vehicle Requirements. T 13, CCR, 1900, 1960.1, 1976 03/28/96 On-road

Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90803, 90800.7 04/25/96 Not applicable

Basin Boundaries for Agricultural Burning (Mojave Desert, South Coast & Salton Sea). T 17, CCR, 60104, 60109, 60114, 80280, 80311 05/30/96 Not applicable

Regulation Improvement and Repeal. T 17, CCR, 93301- 93355, Appendix A-E (emissions inventory) 05/30/96 Not applicable

Regulation Improvements and Repeals (fuel additives). T 13, CCR, 2201, 2202 05/30/96 Fuels

Emissions Inventory Criteria & Guideline Report. T 17, CCR, 93300.5 07/25/96 Not applicable

Air Toxics "Hot Spots" Fee Regulation. T 17, CCR, 90701-90705 Appendix A to §§ 90700-90705 09/26/96 Not applicable

Stationary Source Test Methods. T 17, CCR, 94105, 94107, 94114, 94135, 94141, 94143, 94161 09/26/96 Not applicable

Wintertime Requirements for Utility Engines & OffHighway Vehicles. T 13, CCR, 2403 09/26/96 Off-road

Diesel Fuel Certification Test Methods . T 13, CCR, 1956.8(b), 1960.1(k), 2281(c), 2282(b), (c) and (g) 10/24/96 Fuels

Diesel Fuel Test Methods. T 13, CCR, 1956.8(b), 1960.1(k), 2281(c), 2282(b), (c) and (g) 10/24/96 Fuels

Antiperspirants and Deodor ants, Consumer Products, Aerosol Coating Products (ARB Test Method 310). T 17, CCR, 94506(a), 94515(a), 94526 11/21/96 Consumer productsTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-9 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Area Designations. T 17, CCR, 60201-60209 11/21/96 Not applicable

Consumer Products and Aerosol Coating Products Amendments. T 17, CCR, 94508-94515, 99517, 94321 11/21/96 Consumer products

Transport Pollutants. T 17, CCR, 70500, 70600 11/21/96 Not applicable
Onboard Diagnostics, Phase II, Technical Status. T 13, CCR, 1968.1, 2030, 2031 12/12/96 On-road

Consumer Products (Hair Spray) Amendments. T 17, CCR, 94509, 94513, 94514 03/27/97 Consumer products

Liquefied Petroleum Gas Propane Limit Specification Delay. T 13, CCR, 2292.6 03/27/97 Fuels

Portable Equipment Registration Program. T 13, CCR, 2450-2465 03/27/97 Off-road

Identification of Inorganic Lead as Toxic Air Contaminant (TAC). T 17, CCR, 93000 04/24/97 Not applicable

Interchangeable Emissions Reduction Credits. T 17, CCR, 91500 05/22/97 Not applicable

Postpone Enhanced Evaporative Emission Requirements for Ultra-Small Volume Vehicle Manufacturers. T 13, CCR, 1976 and incorporate test procedures 05/22/97 On-road

Consumer Products (Mid-Term Measures) Amendments. T 17, CCR, 94508, 94509, 94513 07/24/97 Consumer products

Off-Cycle Emissions Supplemental Federal Test Procedures (SFTPs). T 13, CCR, 1960.1, 2101 and incorporate test procedures 07/24/97 On-road

Air Toxics "Hot Spots" Fee Regulation. T 17, CCR 90701-90705 and Appendix A 11/13/97 Not applicable

Area Designations. T 17, CCR, 60201 & 60205 11/13/97 Not applicable
Consumer Products (Hairspray Credit Program). T 17, CCR, 94502, 94509, 94522, & 94548 11/13/97 Consumer products

Heavy Duty Vehicle Smoke Inspection Program/Periodic Smoke Inspection Program. T 13, CCR, 2180-2188 and 2190-2194 12/11/97 On-road

Permit Fee Regulations for Non-vehicular Sources. T 17,CCR 90800 01/29/98 Not applicable

Small Off-Road Engines (SORE). T 13, CCR, 2400,2410- 2414 03/26/98 Off-roadTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-10 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Classifying Minor Violations. T 17, CCR, 60090-60095 04/23/98 Not applicable

Heavy Duty Vehicle Regulations: 2004 Standards. T 13, CCR, 1956.8, 1965, 2036, 2112 and test procedures 04/23/98 On-road

Airborne Toxic Control Measure for Chrome Plating. T 17, CCR, 93102 05/21/98 Not applicable

Cleaner Burning Gasoline Model Flexibility. T 13, CCR, Sections 2260, 2262.1, 2262.3, 2262.4, 226 2.5 , 2262.6, 2262.7 and 2265 08/27/98 Fuels

Gasoline Vapor Recovery Systems. T 17, CCR, 94010- 94015 and 94150, 94156, 9415 7, 94158, 94159, 94160, 94162 08/27/98 Vapor Recovery

Identification of Diesel Exhaust as a Toxic Air Contaminant. T 17, CCR, 93000 08/27/98 Not applicable

Gasoline Deposit Control Additive Regulation. T 13, CCR, 2257, and incorporating test procedures 09/24/98 Fuels

Air Toxics “Hot Spots” Fee Regulations. T 17, CCR, 90701-90705 and Appendix A 10/22/98 Not applicable

Area Designations and Criteria for the National and State Ambient Air Quality Standards for Ozone. T 17, CCR, 60301, 60202, 60205, 6020 6, 70300-70306, 70303.1 10/22/98 Not applicable

Large Off-Road Spark-Ignition Engine Regulations. T 13, CCR, 2430 et seq., and 2411-2414 10/22/98 Off-road

Stationary Source Test Methods. T 17, CCR, 94101 - 94104, 94106, 94108 - 94113, 941T 17 - 94124, 94137 and revision of Method 12. 10/22/98 Not applicable

Low Emission Vehicles Standards (LEV 2) and Compliance Assurance Program (CAP 2000). T 13, CCR,1961 & 1962 (both new); 1900, 1960.1, 1965, 1968.1, 1976, 1978, 2037, 2038, 2062, 2101, 2106, 2107, 2110, 2112, 2114, 2119, 2130, 2137-2140, 2143-2148 11/05/98 On-road

Aftermarket Parts for Off-Road Engines. T 13, CCR, 2470-2476 11/19/98 Off-road

Consumer Products - LVP- VOC Definitions And Test Methods. T 17, CCR, 94506, 94506.5, 94508(a)(78), 94515 and 94526, and the amendment of ARB Method 310 11/19/98 Consumer productsTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-11 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Consumer Products, Aerosol Coatings & Antiperspirants and Deodorants. T 17, CCR, 9450 1, 94508, 94521, 94522, and 94524 11/19/98 Consumer products

1997 & Later Model Off-Highway Recreational Vehicles and Engines. T 13, CCR, 2410-2414, 2415 12/10/98 Off-road

Emission Standards and Test Procedures for 2001 Marine Engines. T 13, CCR, 2440 et seq 12/10/98 Off-road

Exhaust Standards for (On-Road) Motorcycles. T 13, CCR, 1958 12/10/98 On-road

Revisions to Statewide Portable Equipment Registration Program. T 13, CCR, 2450-2463 12/10/98 Off-road

Voluntary Accelerated Light Duty Vehicle Retirement Regulations. T 13, CCR, 2600-2610 12/10/98 On-road

Cleaner Burning Gasoline (Increasing the Oxygen Content). T 13, CCR, sections 226 2.5 (b) and 2265(a)(2) 12/11/98 Fuels

Specifications for Liquid Petroleum Gas Used as a Motor Vehicle Fuel. T 13, CCR, 2292.6 12/11/98 Fuels

Cleaner Burning Gasoline, Oxygen Requ irement for Wintertime In Lake Tahoe Area/Gas Pump Labeling for MTBE. T 13, CCR, 226 2.5 , and 2273 06/24/99 Fuels

Gasoline Vapor Recovery Systems. T 17, CCR, 94011, 94153, 94155, and incorporated test procedures, CP-201, TP- 201.4, and TP-201.6 06/24/99 Vapor Recovery

Clean Fuels Regulation Requirements. T 13, CCR, sections 2300-2317, and 2303.5, 2311.5 07/22/99 On-road

Portable Container Spillage Control Measure. T 13, CCR, 2470-2478 09/23/99 Off-road

Administrative Hearing Procedures. T 17, CCR, 60040 and 60075.1-60075.45 10/22/99 Not applicable

California Consumer Products Regulation Mid-Term Measures II. T 17, CCR, 94508, 94509, and 94513 10/28/99 Consumer products

Area Designations for State Ambient Air Quality Standards. T 17, CCR, 60201 11/18/99 Not applicable

CaRFG Phase 3 Amendments (Phase out of MTBE, standards, predictive model). T 13, CCR, 2260, 2261, 2262.1, 226 2.5 , 2263, 2264, 2264.2, 2265, 2266 etc... 12/09/99 FuelsTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-12 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Off-Road Compression Ignition Engines. T 13, CCR, 2111, 2112, 2137, 2139, 2140, 2141, 2144, 2400, 2401, 2403, 2420, 2421, 2423-2427, & appendix A to article 2.1. 01/27/00 Off-road

Transit Bus Standards. T 13, CCR, 1956.1, 1956.2, 1956.3, 1956.4, 1956.8, 1965 02/24/00 On-road

Agricultural Burning Guidelines. T 17 Amendments 80145, 80T 179, 80100-80102, 80110, 80120, 80130, 80140, 80150, 80155, 80160, 80T 170, 80180, 80200, 80210, 80230, 80240, 8025 0, 80260, 80270, 80280, 80290, 80300, 80310, 80311, 80320, 80330 03/23/00 Not applicable

Enhanced Gasoline Vapor Rec overy Systems (Emergency Filing CP-201, section 18). T 17, CCR, 94011 03/23/00 Vapor Recovery

Enhanced Gasoline Vapor Recovery Systems (In Station Diagnostics and Onboard Refu eling Vapor Recovery). T 17, CCR, 94011 03/23/00 Vapor Recovery

Air Toxic Control Measure for Chlorinated Toxic Air Contaminants from Automotive Maintenance and Repair Facilities. T 17, CCR, 93111 04/27/00 Other

Consumer Products Aerosol Adhesives Control Measure. T 17, CCR, 94508, 94509, 94512, 94513 05/25/00 Consumer products

Aerosol (Paint) Coatings Products. T 17, CCR, 94700, 94701, 94521-94524, 94526 06/22/00 Consumer products

Air Toxic Control Measure for Asbestos Containing Serpentine. T 17, CCR, 93106 07/20/00 Not applicable

Conflict of Interest Code. T 17, CCR, 95001, 95002, 95005, and subchapter 9 09/28/00 Not applicable

Rice Straw Conditional Burn Permit Program. T 17, CCR, 80101, 80156-80158 09/28/00 Not applicable

Air Toxics "Hot Spots" Fee Regulations. T 17, CCR, 90705 tables 1, 2, 3a, 3b, 3c, and 4 10/26/00 Not applicable

Antiperspirant and Deodorant Regulations. T 17, CCR, 94502, 94504 10/26/00 Consumer products

Area Designations for the State Ambient Air Quality Standard for Ozone. T 17, CCR, 60201 11/16/00 Not applicableTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-13 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

CaRFG Phase 3 Follow-up Amendments. T 13, CCR, sections 2260, 2261, 2262.3, 226 2.5 , 2263, 2264, 2265, 2266, 2266.5, 2270, 2272, 2273, 2282, 2296, 2297, 2262.9 and incorporated test procedures 11/16/00 Fuels

CaRFG Phase 3 Test Methods. T 13, CCR, sections 2263(b) 11/16/00 Fuels

Heavy Duty Diesel Engines "Not-to-Exceed (NTE)" Test Procedures. T 13 CCR, 1956.8, 2065 12/07/00 On-road

Light-and Medium Duty Low Emission Vehicle Alignment with Federal Standards. Exhaust Emission Standards for Heavy Duty Gas Engines. T 13, CCR, 1956.8 &1961 12/07/00 On-road

Zero Emission Vehicle Regulation Update. T 13, CCR, 1900, 1960.1(k), 1961, 1962 & incorporated Test Procedure 01/25/01 On-road

Ozone Transport Assessment. T 17, CCR, 70500 & 70600 04/26/01 Not applicable

Zero Emission Vehicle Infrastructure and Standardization of Electric Vehicle Charging Equipment. T 13, CCR, 1900(b), 1962(b) 1962.1 06/28/01 On-road

Airborne Toxic Control Measure for Asbestos from Construction, Grading, Quarrying, and Surface Mining. T 17, CCR, 93105 07/26/01 Not applicable

Marine Inboard Engines. T 13, CCR, 2111, 2112, 2139, 2140, 2147, 2440-2442, 2443.1-2443.3, 2444, 2445.1, 2445.2, 2446, 2444.2 and incorporation of documents by reference 07/26/01 Off-road

Air Toxic Control Measures for Auto and Mobile Equip Refinishing Coatings containing Hexavalent Chromium and Cadmium Compounds. T 17, CCR, 93112 09/20/01 Not applicable

Air Toxics "Hot Spots" Fee Regulation. T 17, CCR, 90700-90705 10/25/01 Not applicable

Gasoline Vapor Recovery Systems Test Methods and Compliance Procedures. T 17, CCR, 94010, 94011, 94153, 94155, 94163, 94164, 94165 & incorporated procedures 10/25/01 Vapor Recovery

Heavy Duty Diesel Engine Standards for 2007 and Later. T 13, CCR, 1956.8 and incorporated test procedures 10/25/01 On-roadTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-14 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Distributed Generation Guidelines and Regulations. T 17, CCR, 94200-94214 11/15/01 Other

Gasoline Vapor Recovery Systems Defects. T 17, CCR, 94006 and incorporated document. 11/15/01 Vapor Recovery

Low Emission Vehicle Regulations. T 13, CCR, 1960.1,1960.5, 1961, 1962 and incorporate test procedures and guidelines 11/15/01 On-road

California Motor Vehicle Se rvice Information Rule. T 13&17, CCR, 1969 & 60060.1 - 60060.7 12/13/01 On-road

Airborne Toxic Control Measure for Outdoor Residential Waste Burning. T 17, CCR, 93113 02/21/02 Other

Voluntary Accelerated Light Duty Vehicle Retirement Regulations. T 13, CCR, 2601-2605, 2606 & appendices C & D, and 2607-2610 02/21/02 On-road

On-Board Diagnostic II Review Amendments. T 13, CCR, 1968.1, 1968.2, 1968.5 04/25/02 On-road

Diesel Retrofit Verification Pr ocedure, Warranty and InUse Compliance Requirements. T 13, CCR, 2700-2710 05/16/02 On-road

Review of California Ambient Air Quality Standards for Particulate Matter and Sulfates. T 17, CCR, 70100,70200, and 70100.1 06/20/02 Not applicable

CaRFG Phase 3 Amendments. T 13, CCR, 2261, 2262, 2262.4, 226 2.5 , 2262.6, 2262.9, 2266.5, 2269, 2271, 2272, 2265, and 2296 07/25/02 Fuels

Revision to Transit Bus Regulations Amendments. T 13, CCR, 1956.1, 1956.2, 1956.4,1956.8, and 2112, & documents incorporated by reference 10/24/02 On-road

Administrative Civil Penalties Program. T 17, CCR, 60065.1 - 60065.45 and 60075.1 - 60075.45 12/12/02 Not applicable

Airborne Toxic Control Measure for Diesel Particulate from School Bus Idling. T13, CCR, 2480 12/12/02 On-road

CaRFG Phase 3 Amendments (specifications for De Minimus Levels of Oxygenates and MTBE Phase Out Issues). T 13, CCR, 2261, 226 2.6, 2263, 2266.5, 2272, 2273, 2260, 2273.5 12/12/02 FuelsTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-15 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Gasoline Vapor Recovery Systems Test Procedures. T 17, CCR, 94010, 94011, 94163, 94164, and 94165 and procedures incorporated by reference, and 94166, 94167, and incorporation by reference. 12/12/02 Vapor Recovery

Low Emission Vehicles II. Align Heavy Duty Gas Engine Standards with Federal Standards; minor administrative changes. T 13, CCR, 1961, 1965, 1956.8, 1956.1, 1978, 2065 and documents incorporated by reference 12/12/02 On-road

Zero Emission Vehicle Amendments for 2003. T 13, CCR, 1960.1(k), 1961(a) and (d), 1900, 1962, and documents incorporated by reference 03/25/03 On-road

Ozone Transport Mitigation Regulations. T 17, CCR, 70600 and 70601 05/22/03 Not applicable

Off-Highway Recreation Vehicles. T13, CCR, 2415 07/24/03 Off-road
Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90800.75, 90800.9, 90804, 90800.8, 90801, 90802, and 90803 07/24/03 Not applicable

Specifications for Motor Vehicle Diesel Fuel. T 13 & T 17, CCR, 1961, 2281, 2282, 2701, 2284, 2285, 93114, and incorporated test procedure 07/24/03 Fuels

Solid Waste Collection Vehicles. T 13, CCR, 2020, 2021, 2021.1, 2021.2 09/24/03 On-road

Small Off-Road Engines (S ORE). T 13, CCR, 2400-2409, 2405.1, 2405.2, 2405.3, 2750-2754, 2754.1, 2754.2, 2755- 2767, 2767.1, 2768-2773 and the documents incorporated by reference 09/25/03 Off-road

Revised Tables of Maximum Incremental Reactivity Values. T 1, CCR, 94700. 12/03/03 Consumer products

Airborne Toxic Control Measure for Diesel Particulate for Transport Refrigeration Units. T 13, CCR, 2022 & 2477 12/11/03 On-road

Airborne Toxic Control Measure for Stationary Compression Ignition Engines. T 17, CCR 93115 & documents incorporate by reference 12/11/03 Other

Diesel Retrofit Verification Pr ocedure, Warranty and InUse Compliance Requiremen ts (Amendments). T 13, CCR, 2701-2707 & 2709 12/11/03 On-roadTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-16 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Area Designation Criteria and Area Designations for State PM 2.5 and Ozone Ambient Air Quality Standards. T 17, CCR, 60201, 60202, 60205, 60210 01/22/04 Not applicable

CA Motor Vehicle Service Information Rule. T 13, CCR, 1969 01/22/04 On-road

Airborne Toxic Control Measure for Diesel-Fueled Portable Engines. T 17, CCR,93116, 93116.1, 93116.2, 93116.3, 93116.4, and 93116.5 02/26/04 Off-road

Modifications to the Stat ewide Portable Equipment Registration Program (PERP) Regulations . T 13, CCR Amendments to 2450-2465, and repeal of 2466 02/26/04 Off-road

Heavy Duty Diesel Engine-Chip Reflash. T 13, CCR, 2011, 2180.1, 2181, 2184, 2185, 2186, 2192, and 2194 03/27/04 On-road

Engine Manufacturer Diagnostic System Requirements for 2007 and Subsequent Model Heavy Duty Engines. T 13, CCR, 1971 05/20/04 On-road

Consumer Products & Methods 310/ATCM for ParaDicholorobenzene. T 17, CCR, 94501, 94506, 94507, 94508, 94509, 94510, 94512, 94513, 94515, and 94526, and ARB Method 310, which is incorporated by reference 06/24/04 Consumer products

Urban Bus Engines/Fleet Rule for Transit Agencies. T 13, CCR, 1956.1, 1956.2, 1956.3, and 1956.4, 06/24/04 On-road

Airborne Toxic Control Measure for Diesel Particulate from Diesel Fueled Commer cial Vehicle Idling. T 13, CCR, 2485 07/22/04 On-road

Gasoline Vapor Recovery Systems at Dispensing Facilities. Emergency Filing. T 17, CCR, 94011 07/22/04 Vapor Recovery

Unihose Gasoline Vapor Recovery Systems. T17, CCR, 94011 07/22/04 Vapor Recovery

Gasoline Vapor Recovery System Equipment Defects List. T 17, CCR, 94006(b) & incorporated document 08/24/04 Vapor Recovery

Greenhouse Gas. T 13, CCR, 1961.1, 1900, 1961 and Incorporated Test Procedures 09/23/04 On-roadTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-17 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

California Reformulated Gasoline, Phase 3. T 13, CCR, 2260, 2262, 2262.4, 226 2.5 , 2262.6, 2262.9, 2263, 2265 (and the incorporated “California Procedures”), and 2266.5 11/18/04 Fuels

Diesel Fuel Standards for Ha rbor Craft & Locomotives. T 13, CCR, 2299, 2281, 2282, and 2284, and T 17, CCR, 93117 11/18/04 Fuels

Enhanced Gasoline Vapor Recovery Systems Extension. T 17, CCR, 94011 and certification procedure 11/18/04 Vapor Recovery

Permit Fee Regulations for Non-vehicular Sources. T17, CCR 90805 and 90806; and 90800.8 and 90803 11/18/04 Not applicable

Emergency Regulation for Temporary Delay of Diesel Fuel Lubricity Standard. T 13, CCR, 2284 11/24/04 Fuels

Airborne Toxic Control Measure for Hexavalent Chromium and Nickel from Thermal Spraying. T 17, CCR, 9310 2.5 12/09/04 Not applicable

Off-Road Compression Ignition Engines. T 13, CCR, 2420, 2421, 2423, 2424, 2425, 2427 12/09/04 Off-road

Area Designations. T 17, CCR, 60201, 60202, 60205, 60210 01/20/05 Not applicable

Transit Fleet Rule. T 13, CCR, 2023, 2023.1, 2023.2, 2023.3, 2023.4, 1956.1, 2020, 2021, repeal 1956.2, 1956.3, 1956.4 02/24/05 On-road

State Ambient Air Quality Standard for Ozone. T 17, CCR, 70100, 70100.1, and 70200 04/28/05 Not applicable

Airborne Toxic Control Measure for Stationary Compression Ignition Engines (amendments). T 17, CCR, 93115 05/26/05 Other

Definition of Large Confined Animal Facility. T 17, CCR 86500 and 86501 06/23/05 Not applicable

On-Board Diagnostic System Requirements for 2010 and Subsequent Model-Year Heavy-Duty Engines (HD OBD). T 13, CCR, 1971.1 07/21/05 On-road

Reid Vapor Pressure Limit. Emergency Rule. T 13, CCR, 2262 and 2262.4 08/08/05 FuelsTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-18 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

2007-2009 Model-Year Heavy Duty Urban Bus Engines and the Fleet Rule for Transit Agencies. T 13, CCR, 1956.1, 1956.2, and 1956.8 09/15/05 On-road

Portable Fuel Containers (PFC) [Part 2 of 2]. T 13, CCR 2467.2, 2467.3, 2467.4, 2467.5, 2467.6, 2467.7; repeal of 2467.8, and adoption of new 2467.8 and 2467.9. 09/15/05 Off road

Portable Fuel Containers (PFC) [Part 1 of 2]. T 13, CCR, 2467 and 2467.1 09/15/05 Off road

Requirements to Reduce Idling Emissions from New and In-Use Trucks, Beginning in 2008. T 13, CCR section1956.8 and the incorporated document 10/20/05 On-road

Airborne Toxic Control Measure for Cruise Ships Onboard Incineration. T 17, CCR, 93119 11/17/05 Off road

Marine Inboard Sterndrive Engines. T 13 CCR 2111, 2112, 2441, 2442, 2444.2, 2445.1, 2446, 2447, and incorporated document 11/17/05 Off-road

Auxiliary Diesel Engines and Diesel-Electric Engines Operated on Ocean-Going Vessels within California Waters and 24 Nautical Miles of the California Baseline. T 13, CCR, 2299.1 and T 17, CCR, 93118 12/08/05 Off-road

Diesel Particulate Matter Control Measure for On-Road Heavy-Duty Diesel-Fueled Ve hicles Owned or Operated by Public Agencies and Utilities. T 13, CCR, 2022 and 2022.1 12/08/05 On-road

Mobile Cargo Handling Equipment at Ports and Intermodal Rail Yards. T 13, CCR, 2479 12/08/05 Off-road

AB1009 Heavy-Duty Vehicle Smoke Inspection Program. T 13, CCR, 2180, 2180.1, 2181, 2182, 2183, 2184, 2185, 2186, 2187, and 2188, 2189 01/26/06 On-road

Identification of Tobacco Smoke as a Toxic Air Contaminant. T 17, CCR, 93000 01/26/06 Not applicable

Diesel Verification Procedure, Warranty & In-Use. T 13, CCR, 2702, 2703, 2704, 2706, 2707, and 2709. 03/23/06 On-road

Technical Amendments to Evaporative Exhaust and Evaporative Emissions Test Procedures. T 13, CCR, 1961,1976 and 1978. 05/25/06 On-roadTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-19 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Fork Lifts and Other Industrial Equipment. (Large OffRoad Spark Ignition Engines > 1 liter) T 13, CCR 2430, 2433, 2434. Adopt 2775, 2775.1, 2775.2, 2780, 2781, 2783, 2784, 2785, 2786, 2787, 2788, and 2789. 05/26/06 Off-road

California Motor Vehicle Serv ice Information Rule. T 13, CCR, 1969 and incorporated documents 06/22/06 On-road

Gasoline Vapor Recovery Systems. T 17 CCR 94011 and incorporated certification 06/22/06 Vapor Recovery

Portable Equipment Registration Program. T 13, CCR, 2450, 2451, 2452, 2453, 2454, 2455, 2456, 2457, 2458, 2459, 2460, 2461, 2462, 2463, 2464, and 2465 06/22/06 Off-road

Off-Highway Recreational Vehi cles and Engines. T 13, CCR, 2411-2413, 2415 & documents incorporated by reference 07/20/06 Off-road

Heavy-Duty In-Use Compliance Regulation. T 13, CCR, 1956.1, 1956.8, and documents incorporated by reference 09/28/06 On-road

On-Board Diagnostic II. T 13, CCR, 1968.2, 1968.5, 2035, 2037 and 2038 09/28/06 On-road

Distributed Generation Guidelines and Regulations. T 17, CCR, 94201, 94201.1, 94203, 94204, & 94207-942142 10/19/06 Other

Zero Emission Bus Regulation. T13, CCR, 2023.1, 2023.3, & 2023.4 10/19/06 On-road

Air Toxics "Hot Spots" Emissions Inventory Criteria and Guidelines. T 17, CCR, 93300.5 and document incorporated by reference 11/16/06 Not applicable

Airborne Toxic Control Measure for Cruise Ships and Ocean-Going Ships Onboard In cineration (amendments). T 17, CCR, 93119 11/16/06 Off-road

Airborne Toxic Control Measure for Stationary Compression Ignition Engines (amendments, Agricultural Eng. Exemption removal). T 17, CCR, 93115.1- 93115.15.t. 11/16/06 Other

Area Designations for State Ambient Air Quality Standards. T 17, CCR, 60201, 60202, 60205, & 60210 11/16/06 Not applicable

Consumer Products. T 17, CCR, 94508, 94509, 94510, 94513 & 94523 11/17/06 Consumer productsTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-20 Appendix Table A-1 

### Measures Adopted by the California Air Resource Board 1990 to 2006

Measure Hearing Date Category

Emergency Regulation for Portable Equipment Registration Program, Airborne Toxic Control Measures and Portable and Stationary diesel-Fueled Engines. T 13, CCR, 2452, 2455, 2456, 2461; T17 CCR 93115, 93116.2, 93116.3 12/06/06 Off-road

Airborne Toxic Control Measure for Chrome Plating and Chromic Acid Anodizing Operations. T 17, CCR, 93102.1-93102.16 12/07/06 Not applicable

Voluntary Accelerated Retirement Regulation. T 13, CCR, 2601-2610 and appendices A-D 12/07/06 On-road



### B. State Rules that Do Not Address Direct PM 2.5 

### or PM 2.5 

### Attainment Plan Precursors in the San Joaquin Valley

A substantial number of the measures adopted by CARB since 1990 do not affect direct PM 2.5 or a PM 2.5 attainment plan precursor emissions in the San Joaquin Valley. These types of measures include fee rules, id entification of toxic air contam inants, area boundary designations, and controls for pollutants other than direct PM 2.5 (or PM), NO x , VOC, or SO 2 . Appendix Table A-2 provides a list of these measures.

Appendix Table A-2 

### Measures Adopted by the California Air Resources Board That Do Not Address PM 2.5 

### in the San Joaquin Valley 1990 to 2006

Measure Hearing Date Comments

Transported Pollutants (Ozone). T 17, CCR, 70500 12/04/89 Not an emissions reduction

measure Non-vehicular Test Methods. T 17, CCR, 94002, 94003 17, &26, 94146-94149, 94132, 94135, 94139, 94140 01/11/90 Not an emissions reduction

measure Test Method for Asbestos in Serpentine Aggregate. T 17, & 26, CCR, 94147, Method 435 04/12/90 Not an emissions reduction

measureTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-21 Appendix Table A-2 

### Measures Adopted by the California Air Resources Board That Do Not Address PM 2.5 

### in the San Joaquin Valley 1990 to 2006

Measure Hearing Date Comments

Airborne Toxic Control Measure for Asbestos in Surfacing Applications. T 17, & 26, CCR, 93106 04/12/90 Not a PM emissions reduction

measure Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90800.1, 90800, 90802-90803 05/10/90 Not an emissions reduction

measure Air Toxics "Hot Spots" Fee Regulation. T 17, & 26, CCR, 90700-90704, 93300-93347 05/10/90 Not an emissions reduction

measure
Dioxins Airborne Toxic Control Measure for Medical Waste Incinerators. T 17, CCR, 93104 07/12/90 Not a PM emissions reduction

measure Air Toxics "Hot Spots" Emissions Inventory Criteria and Guidelines. T 17, & 26, CCR, 93300-93347 06/14/90 Not an emissions reduction

measure Criteria for Area Designations for the State Ambient Air Quality Standard. T 17, CCR, 70303 & 70304 06/14/90 Not an emissions reduction

measure Emissions Reduction Accounting Procedures for California Clean Air Act. T 17, CCR, 70700-70704 07/12/90 Not an emissions reduction

measure Identification of Inorganic Arsenic as a Toxic Air Contaminant. T 17, & 26, CCR, 93000 07/12/90 Not an emissions reduction

measure Transport Mitigation Regulations. T 17, CCR, 70600- 70601 08/09/90 Not an emissions reduction

measure Air Toxic Fee Schedule & Emissions Inventory Criteria and Guidelines. T 17, & 26, CCR, 90700-90704, 93300- 93347 09/13/90 Not an emissions reduction

measure

Identification of Trichlor oethylene as a Toxic Air Contaminant. T 17, & 26, CCR, 93000 10/11/90 Not an emissions reduction

measure Revision to Designation Criteria. T 17, CCR, 60200- 60204, 60208 11/08/90 Not an emissions reduction

measure Identification of Vinyl Chloride as a Toxic Air Contaminant. T 17, & 26, CCR, 93000 11/13/90 Not an emissions reduction

measure
Identification of Chloroform as a Toxic Air Contaminant. T 17, & 26, CCR, 93000 12/13/90 Not an emissions reduction

measure

Conflict of Interest Code. T 17, CCR, 95001, et. seq. 12/13/90 Not an emissions reduction

measure Permit Fee Regulations for Non -Vehicular Sources. T 17, CCR, 90800.2, 90801, 90803 02/24/91 Not an emissions reduction

measure Non - Vehicular Test Methods. T 17, CCR, 94131, 94132, 94142 04/11/91 Not an emissions reduction

measure.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-22 Appendix Table A-2 

### Measures Adopted by the California Air Resources Board That Do Not Address PM 2.5 

### in the San Joaquin Valley 1990 to 2006

Measure Hearing Date Comments

Acid Deposition Fee Regulations. T 17, CCR, 90621.2, 90620, 90622 04/11/91 Not an emissions reduction measure. Obsolete.
Administrative Hearing Procedures. T 17, CCR, 60075.1, 60075.47 05/09/91 Not an emissions reduction

measure Air Toxics "Hot Spots" Fee Regulation. T 17, & 26, CCR, 90700 - 90705 06/13/91 Not an emissions reduction

measure Agricultural Burning Guidelines. T 17, 80130, 80150, 80250, 80260, 80290 07/11/91 Not an emissions reduction

measure Identification of Metallic & Inorganic Nickel Compounds as a Toxic Air Contamin ant. T 17, & 26, 93000 08/08/91 Not an emissions reduction

measure State Ambient Air Quality Standard for SO 2 . T 17, CCR, 70100, 70200, 70201 10/10/91 Not an emissions reduction

measure Identification of Perchloroethylene as a Toxic Air Contaminant. T 17, & 26, CCR, 93000 10/10/91 Not an emissions reduction

measure

Area Designations. T 17, CCR, 60200, 60209 11/14/91 Not an emissions reduction

measure Identification of Formaldehyde as a Toxic Air Contaminant. T 17, & 26, CCR, 93000 03/12/92 Not an emissions reduction

measure Atmospheric Acidity Protection Fees. T 17, CCR, 90621.3 04/09/92 Not an emissions reduction

measure Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90800.3, 90803 04/09/92 Not an emissions reduction

measure

Criteria for Area Designations. T 17, CCR, 70303, 70304 05/14/92 Not an emissions reduction

measure

Transported Air Pollutants. T 17, CCR, 70500 05/28/92 Not an emissions reduction

measure Air Toxics "Hot Spots" Fee Regulation. T 17, & 26, CCR, 90701, 90704, 90705 07/09/92 Not an emissions reduction

measure
Identification of 1.3 Butadiene as a Toxic Air Contaminant. T 17, & 26, CCR, 93000 07/09/92 Not an emissions reduction

measure

CFC Refrigerants in Air Conditioning Systems. T 13, CCR, 2500 09/10/92 Not a PM or PM 2.5 attainment plan precursors emissions reduction

measure Criteria for Area Designations. T 17, CCR, 70303.5, 60200-60203, 60205, 70303 12/10/92 Not an emissions reduction

measureTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-23 Appendix Table A-2 

### Measures Adopted by the California Air Resources Board That Do Not Address PM 2.5 

### in the San Joaquin Valley 1990 to 2006

Measure Hearing Date Comments

Transport Mitigation Regulations. T 17, CCR, 70600, 70601 03/11/93 Not an emissions reduction

measure
Identification of Federal Hazardous Air Pollutants as Toxic Air Contaminants. T 17, & 26, CCR, 93001, 39665, 39666 04/08/93 Not an emissions reduction

measure

Acid Deposition Fee Regulations. T 17, CCR, 90622, 90621.4 04/08/93 Not an emissions reduction

measure Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90800.4, 90803 04/08/93 Not an emissions reduction

measure Air Toxics "Hot Spots" Emissions Inventory Criteria and Guidelines. T 17, & 26, CCR, 93300-93347 06/10/93 Not an emissions reduction

measure Air Toxics "Hot Spots" Fee Regulation. T 17, & 26, CCR, 90700-90705 07/08/93 Not an emissions reduction

measure Mitigation Transport Polluta nts. T 17, CCR, 70500, 70600 08/12/93 Not an emissions reduction

measure

Airborne Toxic Control Measure for Perchloroethylene Dry Cleaning. T 17, & 26, CCR, 93109, 93110 10/14/93 Not a PM or PM 2.5 attainment plan precursors emissions reduction

measure

Conflict of Interest. T 17, CCR, 90500 11/18/93 Not an emissions reduction

measure Criteria for Area Designations. T 17, CCR, 60200-60202, 60204, 60206, 60208, 70300-70306 11/18/93 Not an emissions reduction

measure SCAQMD's Reclaim Consideration 03/10/94 Not a SJV control measure
Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90800.5, 90803 04/14/94 Not an emissions reduction

measure Air Toxics "Hot Spots" Fee Regulation. T 17, & 26, CCR, 90700-90705 07/28/94 Not an emissions reduction

measure

Area Designations. T 17, CCR, 60201, 60204 11/09/94 Not an emissions reduction

measure Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90800.6, 90803 04/27/95 Not an emissions reduction

measure Employee-Based Trip Reductions Emission Formula. T 13, CCR, 2330, 2331, 2332 06/29/95 Not an emissions reduction

measure Air Toxics "Hot Spots" Fee Regulation. T 17, CCR, 90700-90705 and Appendix A 01/25/96 Not an emissions reduction

measureTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-24 Appendix Table A-2 

### Measures Adopted by the California Air Resources Board That Do Not Address PM 2.5 

### in the San Joaquin Valley 1990 to 2006

Measure Hearing Date Comments

Relaxation of Carbon Monoxide Emission Standards for Utility Engines. T 13, CCR, 2403 and incorporating test procedures 01/25/96 Carbon monoxide requirement

Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90803, 90800.7 04/25/96 Not an emissions reduction

measure Basin Boundaries for Agricultural Burning (Mojave Desert, South Coast & Salton Sea). T 17, CCR, 60104, 60109, 60114, 80280, 80311 05/30/96 Not applicable to SJV

Regulation Improvement and Repeal. T 17, CCR, 93301- 93355, Appendix A-E (emissions inventory) 05/30/96 Not an emissions reduction

measure Emissions Inventory Criteria & Guideline Report. T 17, CCR, 93300.5 07/25/96 Not an emissions reduction

measure Air Toxics "Hot Spots" Fee Regulation. T 17, CCR, 90701-90705 Appendix A to §§ 90700-90705 09/26/96 Not an emissions reduction

measure Stationary Source Test Methods. T 17, CCR, 94105, 94107, 94114, 94135, 94141, 94143, 94161 09/26/96 Not an emissions reduction

measure

Area Designations. T 17, CCR, 60201-60209 11/21/96 Not an emissions reduction

measure

Transport Pollutants. T 17, CCR, 70500, 70600 11/21/96 Not an emissions reduction

measure Identification of Inorganic Lead as Toxic Air Contaminant (TAC). T 17, CCR, 93000 04/24/97 Not an emissions reduction

measure Interchangeable Emissions Reduction Credits. T 17, CCR, 91500 05/22/97 Not an emissions reduction

measure Air Toxics "Hot Spots" Fee Regulation. T 17, CCR 90701-90705 and Appendix A §§ 90700-90705 11/13/97 Not an emissions reduction

measure

Area Designations '97 . T 17, CCR, §§ 60201 & 60205 11/13/97 Not an emissions reduction

measure Permit Fee Regulations for Non-vehicular Sources. T 17,CCR 90800 01/29/98 Not an emissions reduction

measure

Classifying Minor Violations. T 17, CCR, 60090-60095 04/23/98 Not an emissions reduction

measure Airborne Toxic Control Measure for Chrome Plating. T 17, CCR, 93102 05/21/98 Not an emissions reduction

measure
Identification of Diesel Exhaust as a Toxic Air Contaminant. T 17, CCR, 93000 08/27/98 Not an emissions reduction

measureTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-25 Appendix Table A-2 

### Measures Adopted by the California Air Resources Board That Do Not Address PM 2.5 

### in the San Joaquin Valley 1990 to 2006

Measure Hearing Date Comments

Stationary Source Test Methods. T 17, CCR, 94101 - 94104, 94106, 94108 - 94113, 941T 17 - 94124, 94137 and revision of Method 12. 10/22/98 Not an emissions reduction

measure

Administrative Hearing Procedures. T 17, CCR, 60040 and 60075.1-60075.45 10/22/99 Not an emissions reduction

measure Area Designations and Criteria for the National and State Ambient Air Quality Standards for Ozone. T 17, CCR, 60301, 60202, 60205, 6020 6, 70300-70306, 70303.1 10/22/98 Not an emissions reduction

measure

Air Toxics “Hot Spots” Fee Regulations. T 17, CCR, 90701-90705 and Appendix A 10/22/98 Not an emissions reduction

measure Area Designations for State Ambient Air Quality Standards. T 17, CCR, 60201 11/18/99 Not an emissions reduction

measure Agricultural Burning Guidelines. T 17 Amendments 80145, 80T 179, 80100-80102, 80110, 80120, 80130, 80140, 80150, 80155, 80160, 80T 170, 80180, 80200, 80210, 80230, 80240, 8025 0, 80260, 80270, 80280, 80290, 80300, 80310, 80311, 80320, 80330 03/23/00 Not an emissions reduction

measure

Air Toxic Control Measure for Asbestos Containing Serpentine. T 17, CCR, 93106 07/20/00 Not a PM or PM 2.5 attainment plan precursors emissions reduction

measure Conflict of Interest Code. T 17, CCR, 95001, 95002, 95005, and subchapter 9 09/28/00 Not an emissions reduction

measure

Rice Straw Conditional Burn Permit Program. T 17, CCR, 80101, 80156-80158 09/28/00 Not a SJV control measure (Sacramento Valley air basin only)
Air Toxics "Hot Spots" Fee Regulations. T 17, CCR, 90705 tables 1, 2, 3a, 3b, 3c, and 4 10/26/00 Not an emissions reduction

measure Area Designations for the State Ambient Air Quality Standard for Ozone. T 17, CCR, 60201 11/16/00 Not an emissions reduction

measure

Ozone Transport Assessment. T 17, CCR, 70500 & 70600 04/26/01 Not an emissions reduction

measure Air Toxics "Hot Spots" Fee Regulation. T 17, CCR, 90700-90705 10/25/01 Not an emissions reduction

measure Review of California Ambient Air Quality Standards for Particulate Matter and Sulfates. T 17, CCR, 70100,70200, and 70100.1 06/20/02 Not an emissions reduction

measure

Administrative Civil Penalties Program. T 17, CCR, 60065.1 - 60065.45 and 60075.1 - 60075.45 12/12/02 Not an emissions reduction

measureTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-26 Appendix Table A-2 

### Measures Adopted by the California Air Resources Board That Do Not Address PM 2.5 

### in the San Joaquin Valley 1990 to 2006

Measure Hearing Date Comments

Ozone Transport Mitigation Regulations. T 17, CCR, 70600 and 70601 05/22/03 Not an emissions reduction

measure Permit Fee Regulations for Non-vehicular Sources. T 17, CCR, 90800.75, 90800.9, 90804, 90800.8, 90801, 90802, and 90803 07/24/03 Not an emissions reduction

measure

Area Designation Criteria and Area Designations for State PM 2.5 and Ozone Ambient Air Quality Standards. T 17, CCR, 60201, 60202, 60205, 60210 01/22/04 Not an emissions reduction

measure

Permit Fee Regulations for Non-vehicular Sources. T17, CCR 90805 and 90806; and 90800.8 and 90803 11/18/04 Not an emissions reduction

measure Area Designations. T 17, CCR, 60201, 60202, 60205, 60210 01/20/05 Not an emissions reduction

measure State Ambient Air Quality Standard for Ozone. T 17, CCR, 70100, 70100.1, and 70200 04/28/05 Not an emissions reduction

measure Definition of Large Confined Animal Facility. T 17, CCR 86500 and 86501 06/23/05 Not an emissions reduction

measure
Identification of Tobacco Smoke as a Toxic Air Contaminant. T 17, CCR, 93000 01/26/06 Not an emissions reduction

measure Air Toxics "Hot Spots" Emissions Inventory Criteria and Guidelines. T 17, CCR, 93300.5 and document incorporated by reference 11/16/06 Not an emissions reduction

measure

Area Designations for State Ambient Air Quality Standards. T 17, CCR, 60201, 60202, 60205, & 60210 11/16/06 Not an emissions reduction

measureTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-27 

### C. State Fuel Measures

CARB has adopted a number of revisions to its reformulated gasoline program and clean diesel program since 1990, as well as measures addressing other motor vehicle fuels and fuel standards for off-road sources. Appendix Ta ble A-3 is a list of these revisions.

Appendix Table A-3 

### Fuel Measures Adopted by the California Air Resources Board 1990 to 2006

Measure Hearing Date Comments

Wintertime Limits for Sulfur in Diesel Fuel. T 13, CCR, 2255 06/21/90 Renumbered to section 2281. Approved 60 FR 43379 (8/21/95)

Limit on Aromatic Content of Diesel Fuel. T 13, CCR, 2256 12/13/90 Renumbered to section 2282. Approved 60 FR 43379 (8/21/95) (listed as 4/15/01 adoption in FR)
Diesel Fuel Regulations - Emergency. T 13, CCR, 2281(h), 2282(1) 10/15/93 Approved 60 FR 43379 (8/21/95)

Small Refiner Diesel. T 13, CCR, 2282(e)(1) 07/24/94 Approved 60 FR 43379 (8/21/95)
Diesel Fuel Test Methods. T 13, CCR, 1956.8(b), 1960.1(k), 2281(c), 2282(b), (c) and (g) 10/24/96 Approved 75 FR 26653 (5/12/10)

Specifications for Motor Vehicle Diesel Fuel. T 13 & T 17, CCR, 1961, 2281, 2282, 2701, 2284, 2285, 93114, and incorporated test procedure 07/24/03 Approved 75 FR 26653 (5/12/10)

Emergency Regulation for Temporary Delay of Diesel Fuel Lubricity Standard. T 13, CCR, 2284 11/24/04 Temporary delay of standard. Expired

Diesel Fuel Standards for Ha rbor Craft & Locomotives. T 13, CCR, 2299, 2281, 2282, and 2284, and T 17, CCR, 93117 11/18/04 NO x reductions estimated at 0.1 tpd for SJV. See CARB 6/29/09 Letter

California Reformulated Gaso line (CaRFG), Phase I. T 13, CCR, 2251.5 09/27/90 RVP standard for period between 1992 and 1996. Obsolete.
California Reformulated Gasoline, Phase II. T 13, CCR, 2250, 2255.1, 2252, 2260 - 2272, 2295 11/21/91 Approved 60 FR 43379 (8/21/95)

Wintertime Gasoline Program. T 13, CCR, 2258, 2298, 2251.5, 2296 11/21/91 Approved 60 FR 43379 (8/21/95)

Predictive Model for Phase II CaRFG. T 13, CCR, 2261, 2262-2270 06/09/94 Superseded by 11/18/04 & 6/14/07 rules

Test Method for Oxygen in Gasoline. T 13, CCR, 2251.5(c), 2258(c), 2263(b) 06/29/95 Section 2251.5 - obsolete; section 2258 wintertime; section 2263, supersededTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-28 Appendix Table A-3 

### Fuel Measures Adopted by the California Air Resources Board 1990 to 2006

Measure Hearing Date Comments

Wintertime Oxygenate Program. T 13, CCR, 2258, 2251.5, 2263(b), 2267, 2298, 2259, 2283, 2293.5 09/09/93 Carbon monoxide control measure

Test Methods for CaRFG 13, CCR, 2263(b) 10/26/95 Superseded by 11/18/04 & 6/14/07 rules
Required Additives in Gasoline (Deposit Control Additives). T 13, CCR, 2257 and incorporates testing procedures. 11/16/95 Superseded by 11/18/04 & 6/14/07 rules

CaRFG Housekeeping & CARBOB. T 13, CCR, 2263.7, 2266.5, 2260, 226 2.5 , 2264, 2265, 2272 12/14/95 Superseded by 11/18/04 & 6/14/07 rules
CaRFG Variance Requirements. T 13, CCR, 2271 (Emergency) 01/25/96 Superseded by 11/18/04 & 6/14/07 rules
Regulation Improvements and Repeals (fuel additives). T 13, CCR, 2201, 2202 05/30/96 Repealed sections

Cleaner Burning Gasoline Model Flexibility. T 13, CCR, Sections 2260, 2262.1, 2262.3, 2262.4, 226 2.5 , 2262.6, 2262.7 and 2265 08/27/98 Superseded by 11/18/04 & 6/14/07 rules

Gasoline Deposit Control Additive Regulation. T 13, CCR, 2257, and incorporating test procedures 09/24/98 Superseded by 11/18/04 & 6/14/07 rules

Cleaner Burning Gasoline (Increasing the Oxygen Content). T 13, CCR, sections 226 2.5 (b) and 2265(a)(2) 12/11/98 Wintertime gasoline for South Coast and Imperial County. Not applicable to the SJV area.
Cleaner Burning Gasoline, Oxygen Requ irement for Wintertime In Lake Tahoe Area/Gas Pump Labeling for MTBE. T 13, CCR, 226 2.5 , and 2273 06/24/99 Not applicable to the SJV/SC area/Obsolete

CaRFG Phase 3 Amendments (Phase out of MTBE, standards, predictive model). T 13, CCR, 2260, 2261, 2262.1, 226 2.5 , 2263, 2264, 2264.2, 2265, 2266 etc... 12/09/99 2262.1 renumber to 2262.4; 2264 (designation of alternative limits) not approved; otherwise superseded by 11/18/04 and 6/14/07 rules
CaRFG Phase 3 Test Methods. T 13, CCR, sections 2263(b) 11/16/00 Superseded by 11/18/04 & 6/14/07 rules
CaRFG Phase 3 Follow-up Amendments. T 13, CCR, sections 2260, 2261, 2262.3, 226 2.5 , 2263, 2264, 2265, 2266, 2266.5, 2270, 2272, 2273, 2282, 2296, 2297, 2262.9 and incorporated test procedures 11/16/00 Superseded by 11/18/04 & 6/14/07 rules

CaRFG Phase 3 Amendments. T 13, CCR, 2261, 2262, 2262.4, 226 2.5 , 2262.6, 2262.9, 2266.5, 2269, 2271, 2272, 2265, and 2296 07/25/02 Superseded by 11/18/04 & 6/14/07 rulesTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-29 Appendix Table A-3 

### Fuel Measures Adopted by the California Air Resources Board 1990 to 2006

Measure Hearing Date Comments

CaRFG Phase 3 Amendments (specifications for De Minimus Levels of Oxygenates and MTBE Phase Out Issues). T 13, CCR, 2261, 226 2.6, 2263, 2266.5, 2272, 2273, 2260, 2273.5 12/12/02 Superseded by 11/18/04 & 6/14/07 rule. Approved 75 FR 26653 (5/12/10) (except for section 2272 (CARFG3 standards for small refineries) and 2273.5 (requirement to identify gasoline containing ethanol when delivered to retail station))
California Reformulated Gasoline, Phase 3. T 13, CCR, 2260, 2262, 2262.4, 226 2.5 , 2262.6, 2262.9, 2263, 2265 (and the incorporated “California Procedures”), and 2266.5 11/18/04 Approved 75 FR 26653 (5/12/10)

Reid Vapor Pressure Limit. Emergency Rule. T 13, CCR, 2262 and 2262.4 08/08/05 Operative for September and October 2005 only. Obsolete.

Specifications for Liquid Petroleum Gas Used as a Motor Vehicle Fuel. T 13, CCR, 2292.6 12/11/98 No identifiable emissions reductions
Liquefied Petroleum Gas Propane Limit Specification Delay. T 13, CCR, 2292.6 03/27/97 Expired



### D. State On-Road Mobile Sources Measures

Appendix Tables A-4 and A-5 list measur es adopted by CARB since 1990 for on-road and off-road sources.

Appendix Table A-4 

### On-Road Mobile Source Measures Adopted by the California Air Resources Board

1990 to 2006

Measure Hearing Date Comments

Certification Procedure for Af termarket Parts. VC 27156 & 38391 02/08/90 Compliance provisionsTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-30 Appendix Table A-4 

### On-Road Mobile Source Measures Adopted by the California Air Resources Board

1990 to 2006

Measure Hearing Date Comments

Emission Standards for Medium Duty Vehicles. T 13, CCR, 1900, 1956.8, 1960.1, 1968.1, 2061, 2112, 2139 06/14/90 Waiver granted September 16, 1994 (59 FR 48625 (9/22/94))

Evaporative Emission Standards. T 13, CCR, 1976 08/09/90 Waiver granted August 25, 1994 (59 FR 46979 (9/13/94))
Low Emission Vehicles and Clean Fuels. T 13, CCR, 1900, 1904, 1956.8, 1960.1, 1960.1.5, 1960.5 and 2111, 2112, 2125, and 2139, 2061. 09/28/90 Waivers granted January 7, 1993 & April 6, 1998 (58 FR 4166 (1/13/93) & 63 FR 18403 (4/15/98))
Heavy Duty Diesel Smoke Emission Testing. T 13, CCR, 2180-2187 11/08/90 Inspection program

Onboard Diagnostics for Light-Duty Trucks and Light & Medium-Duty Motor Vehicles. T 13, CCR, 1977, 1968.1 09/12/91 Waiver granted October 2, 1996 (61 FR 53371 (10/11/96)) Onboard Diagnostic, Phase II. T 13, CCR, 1968.1, 1977 11/12/91

Low Emission Vehicles amendm ents revising reactivity adjustment factor (RAF) provisions and adopting a RAF for M85 transitional low emission vehicles. T 13, CCR, 1960.1 11/14/91 Confirm within the scope finding requested February 18, 1993

Alternative Motor Vehicle Fuel Certification Fuel Specification. T 13 & 26, CCR, 2290-2292.7, 1960.1(k), 1956.8(b), 1956.8(d) 3/12/92 Confirm within the scope finding requested February 17, 1994

Standards and Test Procedures for Alternative Fuel Retrofit Systems. T 13, CCR, 2030, 2031 05/14/92 Compliance provisions

Phase 2 RFG certification fuel specifications. T 13, CCR, 1960.1, 1956.8(d) 08/13/92 Confirm within the scope finding requested February 17, 1994
Substitute Fuel or Clean Fuel Incorporated Test Procedures. T 13, CCR, 1960.1(k), 2317 11/12/92 Confirm within the scope finding requested February 17, 1994
Smoke Self Inspection Program for Heavy Duty Diesel & Gasoline Engines. T 13, CCR, 2190-2194, 2180-2187, 1956.8(b) 12/10/92 Inspection program

Certification Requirements for Low Emission Passenger Cars, Light-Duty Trucks & Medium Duty Vehicles. T 13, CCR, 1960.1, 1976, 2061, 1900 01/14/93 Confirm within the scope finding requested February 21, 1994

Onboard Diagnostic, Phase II. T 13, CCR, 1968.1 07/09/93 Waiver granted October 2, 1996 (61 FR 53371 (10/11/96))

Urban Transit Buses. T 13, CCR, 1956.8, 1965, 2112 06/10/93 Found within the scope September 28, 2004 (69 FR 59920 (October 6, 2004))TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-31 Appendix Table A-4 

### On-Road Mobile Source Measures Adopted by the California Air Resources Board

1990 to 2006

Measure Hearing Date Comments

Evaporative Emission Standards and Test Procedures. T 13, CCR, 1976 02/10/94 Waiver granted July 28, 1999 (64 FR 42689 (8/5/99))
Diesel Fuel Certification. T 13, CCR, 1956.8(b)&(d), 1960.1(k), 2292.6 09/22/94 Confirm within the scope finding requested September 14, 1995
Self Inspection Program for H eavy Duty Diesel Engines. T 13, CCR, 2190-2194, 2180-2187, 1956.8(b) 11/09/94 Inspection program

Onboard Diagnostics, Phase II. T 13, CCR,1963.1, & Certification Procedures 12/08/94 Waiver granted October 2, 1996 (61 FR 53371 (10/11/96))
Periodic Smoke Inspection Program. T 13, CCR, 2190 12/08/94 Inspection program
Heavy Duty Vehicle Exhaust Emission Standards. T 13, CCR, 1956.8 and incorporate test procedures. 06/29/95 Found within the scope September 28, 2004 (69 FR 59920 (10/6/04))
Onboard Refueling Vapor Rec overy Standards. T 13, CCR, 1976, 1978 and incorporate test procedures 06/29/95 Waiver granted August 13, 2002 (67 FR 54180 (8/21/02))

Retrofit Emission Standards. T 13, CCR, 1956.9, 2030, 2031, and incorporate test procedures 07/27/95 Compliance provision

Low Emission Vehicle Standards 3 (LEV 3). T 13, CCR, 1956.8, 1960.1, 1965, 2101, 2061, 2062, and incorporate test procedures 09/28/95 Confirm within the scope finding requested October 8, 1996.

Postpone Zero Emission Vehicle Requirements. T 13, CCR, 1900, 1960.1, 1976 03/28/96 Found within the scope January 18, 2001 (66 FR 7751 (1/25/01))
Diesel Fuel Certification Test Methods. T 13, CCR, 1956.8(b), 1960.1(k), 2281(c), 2282(b), (c) and (g) 10/24/96 Confirm within the scope finding requested November 24, 1997
Onboard Diagnostics, Phase II, Technical Status. T 13, CCR, 1968.1, 2030, 2031 12/12/96 Initial notice 69 FR 5542 (February 5, 2004)
Postpone Enhanced Evaporative Emission Requirements for Ultra-Small Volume Vehicle Manufacturers. T 13, CCR, 1976 and incorporate test procedures 05/22/97 Found within the scope July 28, 1999 (64 FR 42689 (8/5/99))

Off-Cycle Emissions Supplemental Federal Test Procedures (SFTPs). T 13, CCR, 1960.1, 2101 and incorporate test procedures 07/24/97 Waiver granted September 30, 2004 (69 FR 60996 (10/14/04))

Heavy Duty Vehicle Smoke Inspection Program/Periodic Smoke Inspection Program. T 13, CCR, 2180-2188 and 2190-2194 12/11/97 Inspection program

Heavy Duty Vehicle Regulations: 2004 Standards. T 13, CCR, 1956.8, 1965, 2036, 2112 and test procedures 04/23/98 Confirm within the scope finding requested December 26, 2001TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-32 Appendix Table A-4 

### On-Road Mobile Source Measures Adopted by the California Air Resources Board

1990 to 2006

Measure Hearing Date Comments

Low Emission Vehicles Standards (LEV 2) and Compliance Assurance Program (CAP 2000). T 13, CCR,1961 & 1962 (both new); 1900, 1960.1, 1965, 1968.1, 1976, 1978, 2037, 2038, 2062, 2101, 2106, 2107, 2110, 2112, 2114, 2119, 2130, 2137-2140, 2143-2148 11/05/98 Waiver granted April 11, 2003 (68 FR 19811 (4/22/03))/found within the scope (1999 ZEV amendments) December 21, 2006 (71 FR 78190 (12/28/06))
Exhaust Standards for (On-Road) Motorcycles. T 13, CCR, 1958 12/10/98 Waiver granted July 27, 2006 (71 FR 44027 (8/3/06))

Voluntary Accelerated Light Duty Vehicle Retirement Regulations. T 13, CCR, 2600-2610 12/10/98 Establishes standards for a voluntary accelerated retirement program. Revised 2/21/06 and 12/7/06

Clean Fuels Regulation Requirements. T 13, CCR, sections 2300-2317, and 2303.5, 2311.5 07/22/99 Removal of obsolete provisions, streamlining and other minor changes to 9/1990 rule.

Transit Bus Standards. T 13, CCR, 1956.1, 1956.2, 1956.3, 1956.4, 1956.8, 1965 02/24/00 Combination of fleet requirements,emission standards, and zeroemission bus standards. Fleet requirements achie ve approximately 2 tpd NO x reductions statewide, so minimal effect in SJV. Federal & state emission standards are the same for 2010 MY buses.

Light-and Medium Duty Low Emission Vehicle Alignment with Federal Standards. Exhaust Emission Standards for Heavy Duty Gas Engines. T 13, CCR, 1956.8 &1961 12/07/00 Waiver granted for LDV & HDV April 11, 2003 (68 FR 19811 (4/22/03)) Initial notice on within-the-scope finding request for HDGE: 72 FR 27114 (May 14, 2007).
Heavy Duty Diesel Engines "Not-to-Exceed (NTE)" Test Procedures. T 13 CCR, 1956.8, 2065 12/07/00 Confirm within the scope finding requested December 26, 2001.
Zero Emission Vehicle Regulation Update. T 13, CCR, 1900, 1960.1(k), 1961, 1962 & incorporated Test Procedure 01/25/01 Found within the scope December 21, 2006 (71 FR 78190 (12/28/06))

Zero Emission Vehicle Infrastructure and Standardization of Electric Vehicle Charging Equipment. T 13, CCR, 1900(b), 1962(b) 1962.1 06/28/01 Found within the scope December 21, 2006 (71 FR 78190 (12/28/06))

Heavy Duty Diesel Engine Standards for 2007 and Later. T 13, CCR, 1956.8 and incorporate test procedures 10/25/01 Waiver granted August 19, 2005 (70 FR 50322 (8/26/05))TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-33 Appendix Table A-4 

### On-Road Mobile Source Measures Adopted by the California Air Resources Board

1990 to 2006

Measure Hearing Date Comments

Low Emission Vehicle Regulations. T 13, CCR, 1960.1,1960.5, 1961, 1962 and incorporate test procedures and guidelines 11/15/01 Found within the scope April 21, 2005 (70 FR 22034 (4/28/05))

California Motor Vehicle Se rvice Information Rule. T 13&17, CCR, 1969 & 60060.1 - 60060.7 12/13/01 Compliance provision. Very similar to EPA regulations at 40 CFR 86.1808.01
Voluntary Accelerated Light Duty Vehicle Retirement Regulations. T 13, CCR, 2601-2605, 2606 & appendices C & D, and 2607-2610 02/21/02 Establishes standards for a voluntary accelerated retirement program. Revised 12/7/06.
On-Board Diagnostic II Review Amendments. T 13, CCR, 1968.1, 1968.2, 1968.5 04/25/02 Initial notice 69 FR 5542 (2/5/04)

Diesel Retrofit Verification Proc edure, Warranty and In-Use Compliance Requirements. T 13, CCR, 2700-2710 05/16/02 Procedures to verify diesel retrofit technology.

Revision to Transit Bus Regulations Amendments. T 13, CCR, 1956.1, 1956.2, 1956.4,1956.8, and 2112, & documents incorporated by reference 10/24/02 Slight relaxation in requirements over 2000 rule.

Low Emission Vehicles II. Align Heavy Duty Gas Engine Standards with Federal Standards; minor administrative changes. T 13, CCR, 1961, 1965, 1956.8, 1956.1, 1978, 2065 and documents incorporated by reference 12/12/02 Waiver granted August 19, 2005 (70 FR 50322 (8/26/05)) for all but HDGE. HDGE standards adopted to harmonize with EPA’s. Initial notice on within-the-scope finding request for HDGE: 72 FR 27114 (5/14/07).

Airborne Toxic Control Measure for Diesel Particulate from School Bus Idling. T13, CCR, 2480 12/12/02 No emissions reductions claimed.

Zero Emission Vehicle Amendments for 2003. T 13, CCR, 1960.1(k), 1961(a) and (d), 1900, 1962, and documents incorporated by reference 03/25/03 Found within the scope December 21, 2005 (71 FR 78190 (12/28/06))

Solid Waste Collection Vehicles. T 13, CCR, 2020, 2021, 2021.1, 2021.2 09/24/03 Diesel reduction program. Minimal reductions. See CARB, “Staff Report: Initial Statement Of Reasons, Proposed Diesel ParticulateMatter Control Measure for OnRoad Heavy-Duty Residential and Commercial Solid Waste Collection Vehicles,” June 6, 2003, p. 53.

Airborne Toxic Control Measure for Diesel Particulate from Transport Refrigeration Units. T 13, CCR, 2022 and 2477 12/11/03 Waiver granted (non-road) January 9, 2009 (74 FR 3030 (1/16/2009))TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-34 Appendix Table A-4 

### On-Road Mobile Source Measures Adopted by the California Air Resources Board

1990 to 2006

Measure Hearing Date Comments

Diesel Retrofit Verification Proc edure, Warranty and In-Use Compliance Requirements (Amendments). T 13, CCR, 2701-2707 & 2709 12/11/03 Procedures to verify diesel retrofit technology.

CA Motor Vehicle Service Information Rule. T 13, CCR, 1969 01/22/04 Compliance provision. Very similar to EPA regulations at 40 CFR 86.1808.01
Heavy Duty Diesel Engine-Chip Reflash. T 13, CCR, 2011, 2180.1, 2181, 2184, 2185, 2186, 2192, and 2194 03/27/04 Compliance provision.

Engine Manufacturer Diagnostic System Requirements for 2007 and Subsequent Model Heavy Duty Engines. T 13, CCR, 1971 05/20/04 Waiver granted December 22, 2005 (71 FR 335 (1/4/06))

Urban Bus Engines/Fleet Rule for Transit Agencies. T 13, CCR, 1956.1, 1956.2, 1956.3, and 1956.4 06/24/04 Various modifications to urban/transit bus standards.

Airborne Toxic Control Measure for Diesel Particulate from Diesel Fueled Commercial Vehicle Idling. T 13, CCR, 2485 07/22/04 Diesel reduction program

Greenhouse Gas Standards. T 13, CCR, 1961.1, 1900, 1961 and Incorporated Test Procedures 09/23/04 Waiver granted June 30, 2009 (74 FR 32744 (July 8, 2009)
Transit Fleet Rule. T 13, CCR, 2023, 2023.1, 2023.2, 2023.3, 2023.4, 1956.1, 2020, 2021, repeal 1956.2, 1956.3, 1956.4 02/24/05 Diesel reduction program

On-Board Diagnostic System Requirements for 2010 and Subsequent Model-Year Heavy-Duty Engines (HD OBD). T 13, CCR, 1971.1 07/21/05 Waiver granted August 13, 2008 (73 FR 52042 (9/8/08))

2007-2009 Model-Year Heavy Duty Urban Bus Engines and the Fleet Rule for Transit Ag encies. T 13, CCR, 1956.1, 1956.2, and 1956.8 09/15/05 & 10/20/05 Aligns State emission standards with federal emission standards.

Requirements to Reduce Idling Emissions from New and InUse Trucks, Beginning in 2008. T 13, CCR section 1956.8 and the incorporated document 10/20/05 Confirm not pre-empted or within the scope finding requested. Initial notice 75 FR 43975 (7/27/2010)TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-35 Appendix Table A-4 

### On-Road Mobile Source Measures Adopted by the California Air Resources Board

1990 to 2006

Measure Hearing Date Comments

Diesel Particulate Matter Control Measure for On-Road Heavy-Duty Diesel-Fueled Vehi cles Owned or Operated by Public Agencies and Utilities. T 13, CCR, 2022 and 2022.1 12/08/05 Diesel reduction program. Minimal reductions. See CARB, “Staff Report: Initial Statement Of Reasons, Proposed Diesel ParticulateMatter Control Measure for OnRoad Heavy-Duty Diesel-Fueled Vehicles Owned or Operated By Public Agencies And Utilities,” October 21, 2005, p. 55.
AB1009 Heavy-Duty Vehicle Smoke Inspection Program. T 13, CCR, 2180, 2180.1, 2181 , 2182, 2183, 2184, 2185, 2186, 2187, and 2188, 2189 01/26/06 Requires trucks have emission control labels.

Diesel Verification Procedure, Warranty & In-Use. T 13, CCR, 2702, 2703, 2704, 2706, 2707, and 2709. 03/23/06 Procedures to verify diesel retrofittechnology, supporting rule for inuse control measures.
Technical Amendments to Evaporative Exhaust and Evaporative Emissions Test Procedures. T 13, CCR, 1961,1976 and 1978. 05/25/06 Within the scope finding July 22, 2010 (75 FR 44948 (July 27, 2010)).

California Motor Vehicle Serv ice Information Rule. T 13, CCR, 1969 and incorporated documents 06/22/06 Compliance provision. Very similar to EPA regulations at 40 CFR 86.1808.01
On-Board Diagnostic II. T 13, CCR, 1968.2, 1968.5, 2035, 2037 and 2038 09/28/06 Confirm within the scope finding requested.

Heavy-Duty In-Use Compliance Regulation. T 13, CCR, 1956.1, 1956.8, and documents incorporated by reference 09/28/06 Compliance provision. Compliance program "essentially identical to EPA's." See Updated Information Digest for the Rule.

Zero Emission Bus Regulation. T13, CCR, 2023.1, 2023.3, & 2023.4 10/19/06 Delays ZEB requirements due to high bus costs and unproven durability, reliability and ability to produce the number of buses required by the regulation. See Updated Information Digest.
Voluntary Accelerated Retirement Regulation. T 13, CCR, 2601-2610 and appendices A-D 12/07/06 Establishes standards for a voluntary accelerated retirement program.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-36 Appendix Table A-5 

### Off-Road Mobile Source Measures Adopted by the California Air Resources Board 1990 to 2006

Measure Hearing Date Comments

Emission Standards for Utility and Lawn and Garden Engines. T 17, CCR, 2400 et. seq. 12/13/90 Waiver granted July 5, 1995 (60 FR 37440 (7/20/95)) 1-year Implementation Delay in Emission Standards for Utility Engines. T 13, CCR, 2400, 2403-2407 04/08/93

Utility and Lawn and Garden Equipment Engines. T 13, CCR, 2403(c), 11(a)(1)(I )(ii), 4(a)(1)(I)(ii) 07/28/94 Within the scope finding November 9, 2000 (65 FR 69763 (11/20/00))

Utility and Lawn and Garden Equipment Engines. CO Standards 1/25/96 Within the scope finding November 9, 2000 (65 FR 69763 (11/20/00))

Small Off-Road Engines (SORE). T 13, CCR, 2400, 2410-2414 03/26/98 Within the scope finding November 9, 2000 (65 FR 69767 (11/20/00)), waiver granted (durability requirements), November 10, 2003 (65 FR 65702 (11/21/03)).
Small Off-Road Engines (S ORE). T 13, CCR, 2400-2409, 2405.1, 2405.2, 2405.3, 2750-2754, 2754.1, 2754.2, 2755-2767, 2767.1, 2768-2773 and the documents incorporated by reference 09/25/03 Waiver granted, December 11, 2006 (71 FR 75536 (12/15/2006))

Off-Highway Recreational Vehicles. T 13, CCR, 2410- 2414, 2111-2140 01/03/94 Waiver granted December 23, 1996 (61 FR 69093 (12/31/1996))

Wintertime Requirements for Utility Engines & OffHighway Vehicles. T 13, CCR, 2403 09/26/96 Within the scope finding November 9, 2000 (65 FR 69763 (11/20/00))

1997 & Later Model Off-Highway Recreational Vehicles and Engines. T 13, CCR, 2410-2414, 2415 12/10/98 Within the scope finding request March 4, 2000

Off-Highway Recreation Vehicles. T13, CCR, 2415 07/24/03 Addition to March 4, 2000 request November 19, 2004. Made changes to riding season restrictions.
Off-Highway Recreational Vehi cles and Engines. T 13, CCR, 2411-2413, 2415 & documents incorporated by reference 07/20/06 Adopted evaporative emission standards identical to EPA's.

Heavy Duty Diesel Cycle Engines. T 13, CCR, 2420- 2427 01/09/92 Waiver granted May 15, 1995 (60 FR 48981 (9/21/1995))TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-37 Appendix Table A-5 

### Off-Road Mobile Source Measures Adopted by the California Air Resources Board 1990 to 2006

Measure Hearing Date Comments

Exemption of Military Tactical Vehicles. T 13, CCR, 1905, 2400, 2420 12/14/95 Within the scope finding November 9, 2000 (65 FR 69763 (11/20/00))
Off-Road Compression Ignition Engines. T 13, CCR, 2111, 2112, 2137, 2139, 2140, 2141, 2144, 2400, 2401, 2403, 2420, 2421, 2423-2427, & appendix A to article 2.1. 01/27/00 Waiver granted, February 5, 2010 (75 FR 8056 (2/23/2010)

Off-Road Compression Ignition Engines. T 13, CCR, 2420, 2421, 2423, 2424, 2425, 2427 12/09/04 Waiver granted February 5, 2010 (75 FR 8056 (2/23/2010))

In-Use Off-Road Diesel Vehicles. T 13, CCR, 2449 07/26/07 Notice of opportunity for public hearing and comment (on waiver), 75 FR 11880 (3/12/2010).

Large Off-Road Spark-Ignition Engine Regulations. T 13, CCR, 2430 et seq., and 2411-2414 10/22/98 Waiver granted May 15, 2006 (71 FR 29623 (5/23/2006))
Fork Lifts and Other Industrial Equipment. (Large OffRoad Spark Ignition Engines > 1 liter) T 13, CCR 2430, 2433, 2434. Adopt 2775, 2775.1, 2775.2, 2780, 2781, 2783, 2784, 2785, 2786, 2787, 2788, and 2789. 05/26/06 Adopts EPA's Standards for 2007; adopts more stringent standards for 2010.

Emission Standards and Test Procedures for 2001 Marine Engines. T 13, CCR, 2440 et seq 12/10/98 Waiver granted March 22, 2007 (59 FR 14546 (March 28, 2007))

Marine Inboard Engines. T 13, CCR, 2111, 2112, 2139, 2140, 2147, 2440-2442, 2443.1-2443.3, 2444, 2445.1, 2445.2, 2446, 2444.2 and incorporation of documents by reference 07/26/01 Waiver granted in part March 22, 2007 (59 FR 14546 (March 28, 2007)) 2007 standards waiver granted April 26, 2011 (76 FR 24872 (5/3/11))

Marine Inboard Sterndrive Engines. T 13 CCR 2111, 2112, 2441, 2442, 2444.2, 2445.1, 2446, 2447, and incorporated document 11/17/05 Revision to year 2007 standards in 7/26/2001 marine inboard engine standards. Waiver requested February 7, 2008.

Portable Equipment Registration Program. T 13, CCR, 2450-2465 03/27/97 Revised by June 22, 2006 rule Waiver request withdrawn/replaced by favor of December 5, 2008 request
Revisions to Statewide Portable Equipment Registration Program. T 13, CCR, 2450-2463 12/10/98 Revised by June 22, 2006 rule

Modifications to the Stat ewide Portable Equipment Registration Program (PERP) Regulations . T 13, CCR Amendments to 2450-2465, and repeal of 2466 02/26/04 Revised by June 22, 2006 ruleTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-38 Appendix Table A-5 

### Off-Road Mobile Source Measures Adopted by the California Air Resources Board 1990 to 2006

Measure Hearing Date Comments

Airborne Toxic Control Measure for Diesel-Fueled Portable Engines. T 17, CCR,93116, 93116.1, 93116.2, 93116.3, 93116.4, and 93116.5 02/26/04 Notice of opportunity for public hearing and comment published February 9, 2011 (76 FR 7196) Within-the-scope finding/waiver requested March 28, 2005.

Portable Equipment Registration Program. T 13, CCR, 2450, 2451, 2452, 2453, 2454, 2455, 2456, 2457, 2458, 2459, 2460, 2461, 2462, 2463, 2464, and 2465 06/22/06 Notice of opportunity for public hearing and comment published February 9, 2011 (76 FR 7194) Within-the-scope finding/waiver requested December 5, 2008.
Emergency Regulation for Portable Equipment Registration Program Airborne Toxic Control Measures and Portable and Stationary diesel-Fueled Engines. T 13, CCR, 2452, 2455, 2456, 2461; T17 CCR 93115, 93116.2, 93116.3 12/06/06 Expired.

Portable Equipment Registration Program and Airborne Toxic Control Measure for Diesel-Fueled Portable Engines. T 13, CCR, 2451, 2452, 2456, 2458, 2459, 2460, 2461, and 2462, T 17, CCR, 93116.1, 93116.2, 93116.3 , 93116.3.1 03/22/07 Notice of opportunity for public hearing and comment published February 9, 2011 (76 FR 7194) Within-the-scope finding/waiver requested December 5, 2008.

Aftermarket Parts for Off-Road Engines. T 13, CCR, 2470-2476 11/19/98 Compliance measure

Portable Container Spillage Control Measure. T 13, CCR, 2470-2478 09/23/99 Similar federal regulation. 40 CFR part 59, subpart F.
Portable Fuel Containers (PFC) [Part 1 of 2]. T 13, CCR, 2467 and 2467.1 09/15/05 Similar federal regulation. 40 CFR part 59, subpart F.

Portable Fuel Containers (PFC) [Part 2 of 2]. T 13, CCR 2467.2, 2467.3, 2467.4, 2467.5, 2467.6, 2467.7; repeal of 2467.8, and adoption of new 2467.8 and 2467.9. 09/15/05 Similar federal regulation. 40 CFR part 59, subpart F.

Airborne Toxic Control Measure for Diesel Particulate for Transport Refrigeration Units. T 13, CCR, 2022 & 2477 12/11/03 Waiver granted (non-road) January 9, 2009 (74 FR 3030 (1/16/2009))

Mobile Cargo Handling Equipment at Ports and Intermodal Rail Yards. T 13, CCR, 2479 12/08/05 Notice of opportunity for public hearing and comment published February 1, 2011 (76 FR 5586) Within-the-scope finding and waiver request January 29, 2007TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-39 Appendix Table A-5 

### Off-Road Mobile Source Measures Adopted by the California Air Resources Board 1990 to 2006

Measure Hearing Date Comments

Airborne Toxic Control Measure for Cruise Ships Onboard Incineration. T 17, CCR, 93119 11/17/05 No emissions reductions. No cruise ships subject to rule call at SJV ports. See Initial Statement of Reasons for Rule, p. II-1.
Auxiliary Diesel Engines and Diesel-Electric Engines Operated on Ocean-Going Vessels within California Waters and 24 Nautical Miles of the California Baseline. T 13, CCR, 2299.1 and T 17, CCR, 93118 12/08/05 No emissions reductions claimed for SJV.

Airborne Toxic Control Measure for Cruise Ships and Ocean-Going Ships Onboard In cineration (amendments). T 17, CCR, 93119 11/16/06 No emissions reductions claimed for SJV.

Ocean-Going Vessels At Berth (Shore Power). T 13, CCR, 2299.3 and T 17, CCR, 93118.3 and documents incorporated by reference 12/06/07 No emissions reductions claimed

Commercial Harbor Craft. T 13, CCR, 2222 and incorporated "California Evaluation Procedures for New Aftermarket Catalytic Converters" 11/15/07 No emissions reductions claimed

Cleaner Fuels in Ocean-Going Vessel Main Engines and Auxiliary Boiler. T 13, CCR, 2299.2 and T 17, CCR, section 93118.2 07/24/08 Proposed approval signed June 29, 2011



### E. State Consumer Product Measures

California has been regulating the VOC cont ent of consumer products for 20 years and continues to tighten standards and regulate more products. Appe ndix Table A-6 is a list of CARB’s rulemaking actions on consumer products since 1990.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-40 Appendix Table A-6 

### Consumer Products Measures Adopted by the California Air Resources Board 1990 to 2006

Measure Hearing Date Comments

Antiperspirant/Deodorants. T 17, CCR, 94500-94 506 11/09/89 Approved 8/21/95 (60 FR 43379)
Consumer Products BAAQMD. T 17, CCR, 94520-9 4526 06/14/90 Not applicable to the SJV area
Phase I - Consumer Products. T 17, CCR, 94507-94517 10/11/90 Approved 8/21/95 (60 FR 43379)
Phase II - Consumer Products. T 17, CCR, 94501, 94502, 94505, 94514, 94503.5, 94506, 94507 - 94513, 94515 01/09/92 Approved 8/21/95 (60 FR 43379)

Notice of General Public Interest for Consumer Products. T 17, CCR, 94507 - 94517 11/30/92 Not a control measure

Alternative Control Plan for Consumer Products. T 17, CCR, 94540-94555 09/22/94 Voluntary compliance option. No action.
Aerosol Coating Products and Alternative Control Plan. T 17, CCR, 94520-94528, 94540-94543, 94547. 03/23/95 Superseded by 6/22/00 rule.

Antiperspirants and Deodorants, Consumer Products, and Aerosol Coating Products. T 17, CCR, 94500-94506, 94508, 94521 09/28/95 Superseded by 6/24/04 rule for antiperspirants and deodorants; superseded by 11/17/06 rule for consumer products; superseded by 11/17/06 rule for aerosol coating products.

Antiperspirants and Deodor ants, Consumer Products, Aerosol Coating Products (ARB Test Method 310). T 17, CCR, 94506(a), 94515(a), 94526 11/21/96 Superseded by 6/24/04 rule for antiperspirants and deodorants; superseded by 11/17/16 rule for consumer products; superseded by 11/17/06 rule for aerosol coating products.
Consumer Products and Aerosol Coating Products Amendments. T 17, CCR, 94508-94515, 99517, 94321 11/21/96 Superseded by 11/17/06 rule

Consumer Products (Hair Spray) Amendments. T 17, CCR, 94509, 94513, 94514 03/27/97 Voluntary compliance option. No action.
Consumer Products (Mid-Term Measures) Amendments. T 17, CCR, 94508, 94509, 94513 07/24/97 Superseded by 11/17/06 rule

Consumer Products (Hairspray Credit Program). T 17, CCR, 94502, 94509, 94522, & 94548 11/13/97 Voluntary compliance option. No action.
Consumer Products, Aerosol Coatings & Antiperspirants and Deodorants. T 17, CCR, 9450 1, 94508, 94521, 94522, and 94524 11/19/98 Superseded by 11/17/06 ruleTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-41 Appendix Table A-6 

### Consumer Products Measures Adopted by the California Air Resources Board 1990 to 2006

Measure Hearing Date Comments

Consumer Products - LVP- VOC Definitions And Test Methods. T 17, CCR, 94506, 94506.5, 94508(a)(78), 94515 and 94526, and the amendment of CARB Method 310 11/19/98 Superseded by 6/24/04 rule for test method 310 and 11/17/06 rule for rest.

California Consumer Products Regulation Mid-Term Measures II. T 17, CCR, 94508, 94509, and 94513 10/28/99 Superseded by 11/17/06 rule

Consumer Products Aerosol Adhesives Control Measure. T 17, CCR, 94508, 94509, 94512, 94513 05/25/00 Superseded by 11/17/06 rule

Aerosol (Paint) Coatings Products. T 17, CCR, 94700, 94701, 94521-94524, 94526 06/22/00 Approved 9/13/05 70 FR 53920; superseded by 11/17/06 rule
Antiperspirant and Deodorant Regulations. T 17, CCR, 94502, 94504 10/26/00 Superseded by 6/24/04 rule

Revised Tables of Maximum Incremental Reactivity Values. T 1, CCR, 94700. 12/03/03 Approved 9/13/05 70 FR 53920; superseded by 11/17/06 rule

Consumer Products & Methods 310/ATCM for ParaDicholorobenzene. T 17, CCR, 94501, 94506, 94507, 94508, 94509, 94510, 94512, 94513, 94515, and 94526, and CARB Method 310, whic h is incorporated by reference 06/24/04 Approved November 4, 2009 (74 FR 57074) (EO order date of 5/6/05)

Consumer Products. T 17, CCR, 94508, 94509, 94510, 94513 & 94523 11/17/06 Approved November 4, 2009 (74 FR 57074) (EO order date 9/16/07)



### F. State Vapor Recovery Measures

Under California State law (Health and Safe ty Code Sections 41954), CARB is required to adopt procedures and perfor mance standards for controlling gasoline emissions from gasoline marketing operations, including tran sfer and storage operations. Stat e law also authorizes CARB, in cooperation with the districts, to certify vapor recovery systems, identify defective equipment, and develop test methods. The installation a nd operation of CARB-certified vapor recovery equipment is required and enforced by SJVAP CD Rules 4621 and 4622. Appendix Table A-7 is a list of rulemaking actions take n by CARB since 1990 that addr ess vapor recovery equipment certification, defects, and/or test methods.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-42 Appendix Table A-7 

### Gasoline Vapor Recovery Measures Adopted by the California Air Resources Board 1990 to 2006

Measure Hearing Date Comments

Gasoline Vapor Recovery Systems. T 17, CCR, 94010- 94015, 94150-94160, 94000-94004, 94007. 06/29/95

CARB sets requirements for and certifies vapor recovery equipment. District rules establish requirements for the installation of CARB-certified equipment. See SJVAPCD Rules 4621 & 4622 Gasoline Vapor Recovery Systems. T 17, CCR, 94010- 94015 and 94150, 94156, 9415 7, 94158, 94159, 94160, 94162 08/27/98

Gasoline Vapor Recovery Systems. T 17, CCR, 94011, 94153, 94155, and incorporated test procedures, CP-201, TP- 201.4, and TP-201.6 06/24/99

Enhanced Gasoline Vapor Recovery Systems (In Station Diagnostics and Onboard Refu eling Vapor Recovery). T 17, CCR, 94011 03/23/00

Enhanced Gasoline Vapor Rec overy Systems (Emergency Filing CP-201, section 18). T 17, CCR, 94011 03/23/00

Gasoline Vapor Recovery Systems Test Methods and Compliance Procedures. T 17, CCR, 94010, 94011, 94153, 94155, 94163, 94164, 94165 & incorporated procedures 10/25/01

Gasoline Vapor Recovery Systems Defects. T 17, CCR, 94006 and incorporated document. 11/15/01

Gasoline Vapor Recovery Systems Test Procedures. T 17, CCR, 94010, 94011, 94163, 94164, and 94165 and procedures incorporated by reference, and 94166, 94167, and incorporation by reference. 12/12/02

Unihose Gasoline Vapor Recovery Systems. T17, CCR, 94011 07/22/04

Gasoline Vapor Recovery Systems at Dispensing Facilities. Emergency Filing. T 17, CCR, 94011 07/22/04

Gasoline Vapor Recovery System Equipment Defects List. T 17, CCR, 94006(b) & incorporated document 08/24/04

Enhanced Gasoline Vapor Recovery Systems Extension. T 17, CCR, 94011 and certification procedure 11/18/04

Gasoline Vapor Recovery Systems. T 17 CCR 94011 and incorporated certification 06/22/06TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-43 Appendix Table A-7 

### Gasoline Vapor Recovery Measures Adopted by the California Air Resources Board 1990 to 2006

Measure Hearing Date Comments

Vapor Recovery Aboveground Storage Tanks (AST). T 17, CCR, 94010, 94011, 94016 and 94168 and incorporated documents 06/21/07

Gasoline Vapor Recovery System Equipment Defects List. T 17, CCR, 94006 N/A



### G. Other State Measures

A number of CARB measures do not fall into on e of the categories of measures listed in Appendix Tables A-2 through A-7. These measures are listed below in Appendix Table A-8.

Appendix Table A-8 

### Other Not Previously Listed Measures Adopted by the California Air Resources Board

1990 to 2006

Measure Hearing Date Comments

Airborne Air Toxic Measure for Ethylene Oxide from Sterilizers & Aerators. T 17, CCR, 93108 05/10/90 Covered by District Rule 7021. Emissions in category are less than 0.01 tpd VOC
Controls for Abrasive Blasting. T 17, CCR, 92000, 92200, 92400, 98500, 98510, 92520, 92530 11/08/90 Small source category in SJV < 0.1 tpd PM 2.5
Airborne Toxic Control Measure for Emission of Toxic Metals from Non-Ferrous Metal Melting. T 17 & 26, CCR, 93107 12/10/92 Adopted as District Rule 7060.

Air Toxic Control Measure for Chlorinated Toxic Air Contaminants from Automotive Maintenance and Repair Facilities. T 17, CCR, 93111 04/27/00 Mainly addresses non-VOC

Airborne Toxic Control Measure for Asbestos from Construction, Grading, Quarrying, and Surface Mining. T 17, CCR, 93105 07/26/01 Controls equivalent to SJVAPCD Regulation VIII, approved 71 FR 8461 (2/17/06)TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-44 Appendix Table A-8 

### Other Not Previously Listed Measures Adopted by the California Air Resources Board

1990 to 2006

Measure Hearing Date Comments

Air Toxic Control Measures for Auto and Mobile Equipment Refinishing Coatings Containing Hexavalent Chromium and Cadmium Compounds. T 17, CCR, 93112 09/20/01 Air toxic control measures prohibit additives with hexavalent chromium. Total emissions CA are less than 300 lb per year. ISOR, p. V-2.

Distributed Generation Guidelines and Regulations. T 17, CCR, 94200-94214 11/15/01 Minimal impact, few units certified. See ISOR for 9/28/06 rule amendment

Airborne Toxic Control Measure for Outdoor Residential Waste Burning. T 17, CCR, 93113 02/21/02 Regulated by Rules 4103 & 4106. Rule 4103 revised 5/17/07, approved 75 FR 74 FR 57907 (11/10/09). Rule 4106 (revised 6/21/01), approved 67 FR 8894 (2/27/02); additional revision in 2010.

Airborne Toxic Control Measure for Stationary Compression Ignition Engines. T 17, CCR 93115 & documents incorporate by reference 2/26/04 PM control measure. NO x regulated by Rule 4702. (approved 73 FR 1819 (1/10/08)). PM reductions are expected to be achieved primarily by replacement of existing engines as a result of District rule.

Airborne Toxic Control Measure for Hexavalent Chromium and Nickel from Thermal Spraying. T 17, CCR, 93102.5 12/09/04 Air toxic control measures. Total emissions (chromium & nickel in CA are less than 200 lb per year. ISOR, p. IV-6 to 8.

Airborne Toxic Control Measure for Stationary Compression Ignition Engines (amendments). T 17, CCR, 93115 05/26/053/17/05 Revisions to 2/26/04 rule. PM control measure. NO x regulated by Rule 4702. (approved 73 FR 1819 (1/10/08)). PM reductions are expected to be achieved primarily by replacement of existing engines as a result of District rule.

Airborne Toxic Control Measure for Stationary Compression Ignition Engines (amendments, In-Use Agricultural Eng. Exemption removal). T 17, CCR, 93115.1-93115.15.t. 11/16/06 PM control measure. NO x regulated by Rule 4702. (approved 73 FR 1819 (1/10/08)) PM reductions are expected to be achieved primarily by replacement of existing engines as a result of District rule.TSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page A-45 Appendix Table A-8 

### Other Not Previously Listed Measures Adopted by the California Air Resources Board

1990 to 2006

Measure Hearing Date Comments

Distributed Generation Guidelines and Regulations. T 17, CCR, 94201, 94201.1, 94203, 94204, & 94207- 942142 10/19/06 Addition of 2013 standards NO x and VOC standard s for DG units which burn waste gas.
Airborne Toxic Control Measure for Chrome Plating and Chromic Acid Anodizing Operations. T 17, CCR, 93102.1-93102.16 12/07/06 Air toxic control measures. Total emissions in CA are 14.4 lb per year. ISOR, p. 49.

### Appendix B – SJVAPCD RulesTSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-1Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments4101 Visible Emissions 2/17/2005 2/17/2005 2/17/200570 FR 46770(8/11/05)Baseline measure4103 Open Burning 4/15/2010 4/15/20104/15/20105/17/2007NPR: signed6/29/1174 FR 57907(11/10/09)Control strategy measure.4104Reduction of AnimalMatter12/17/1992 12/17/1992 12/17/199275 FR 10691(3/9/10)Baseline measure4105Commercial OffsiteMulti-User Hazardousand Non-HazardousWaste DisposalFacilities12/17/1992 N/A N/A N/A Odor rule only4106 Prescribed Burning 6/21/2001 6/21/2001 6/21/200167 FR 8894(2/27/02)Feasibility study completed in 2008. Noadditional rulemaking.4201Particulate matterconcentrations12/17/1992 12/17/1992 12/17/199267 FR 16026(4/4/02)Baseline measure4202Particulate matteremission rates12/17/1992 12/17/1992 12/17/199265 FR 21347(4/21/00)Baseline measureTSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-2Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments4203Particulate MatterEmissions fromIncineration ofCombustible Refuse12/17/1992 12/17/1992 N/A no action Baseline measure4204 Cotton Gin 2/17/2005 2/17/2005 2/17/200571 FR 65740(11/08/06)Baseline measureFeasibility study measure, PM2.5, (2009)4301Fuel BurningEquipment12/17/1992 12/17/1992 12/17/199264 FR 26876(5/18/1999)Baseline measure4302 Incinerator Burning 12/16/1993 12/16/1993 12/16/199364 FR 45170(8/19/1999)Baseline measure4303 Orchard Heaters 12/16/1993 12/16/1993 12/16/199364 FR 45170(8/19/1999)Baseline measure4304Equipment TurningProcedures for Boilers,Steam Generators, andProcess Heaters10/19/1995 10/19/1995 10/19/199566 FR 5766(11/16/01)Baseline measure4305Boilers, SteamGenerators, and ProcessHeaters - Phase 28/21/2003 8/21/2003 8/21/200369 FR 28061(5/18/04)Baseline measure4306Boilers, SteamGenerators, and ProcessHeaters - Phase 310/16/2008 10/16/2008 10/16/200875 FR 1715(1/13/10)Control strategy measureTSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-3Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments4307Boilers, SteamGenerators, and ProcessHeaters - 2.0 MMBTU/hr to 5.0MMBTU/hr5/19/2011 10/16/2008 10/16/200875 FR 1715(1/13/10)Control strategy measure4308Boilers, SteamGenerators, and ProcessHeaters - 0.75 MMBTU/hr to 2.0MMBTU/hr12/17/2009 12/17/2009 12/17/200976 FR 5276(1/31/11)Control strategy measure4309Dryers, Dehydrators andOvens12/15/2005 12/15/2005 12/15/200572 FR 29887(5/30/07)Baseline measureFeasibility study measure, PM2.5& ozone(2011)4311 Flares 6/18/20096/18/20096/15/20066/20/2002NPR - 72 FR65283 (11/20/07)68 FR 8835(2/26/03)Control strategy measure.2009 revisions submitted January 10, 2010(complete February 4, 2010)4313 Lime Kilns 3/27/2003 3/27/2003 3/27/200368 FR 52510(9/4/2003)Baseline measureFeasibility study measure, PM2.5& ozone(2011)TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-4Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments4320Advanced EmissionReduction Option forBoilers10/16/2008 10/16/2008 10/16/200876 FR 16696(3/25/11)Control strategy measures. No emissionsreductions credit allowed.4351Boilers, SteamGenerators, and ProcessHeaters - RACT8/21/2003 8/21/2003 8/21/200369 FR 28061(5/18/04)Baseline measure4352Solid Fuel Fired Boilers,Steam Generators, andProcess Heaters5/18/2006 5/18/2006 5/18/200675 FR 60623(10/1/10)Limited approval/disapprovalS-COM-4 - Feasibility study measure, ozone& PM2.5(2009)4354 Glass Melting Furnaces4/19/2011 9/16/20109/16/20108/17/200676 FR 37044,(6/24/11)72 FR 41894(8/01/07)Control strategy measure.4401Steam-Enhanced CrudeOil Production Wells6/16/201112/14/200612/14/200675 FR 3996(1/26/10)VOC measureLimited approval/disapproval4402Crude Oil ProductionSumps12/17/1992 12/17/1992 N/A76 FR 298(1/04/11)VOC measureLimited approval/disapproval4403Components ServingLight Crude Oil orGases at Light CrudeOil and Gas Production4/20/2005 4/20/2005 4/20/200571 FR 14652(3/23/06)VOC measureTSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-5Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments4404Heavy Oil Test Station– Kern12/17/1992 12/17/1992 12/17/199275 FR 10691(3/9/10)VOC measure4405Oxides of NitrogenEmissions from ExistingSteam Generators(Central and WesternKern County)12/17/1992notsubmittedN/A N/A4406Sulfur Compounds fromOilfield SteamGenerators - Kern12/17/1992notsubmittedN/A N/A4407In-situ CombustionWell Vents5/19/1994 5/19/1994 5/19/199460 FR 12121(3/6/95)VOC controls4408Glycol DehydrationSystems12/19/2002 12/19/2002 12/19/200268 FR 51187(8/26/03)4409Components at LightCrude Oil or Gases atLight Crude Oil and GasProduction4/20/2005 4/20/2005 4/20/200571 FR 14653(3/23/06)VOC measureTSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-6Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments4451Valves, Pressure ReliefValves, Flanges,Threaded Connectionsand Process Drains atPetroleum Refineriesand Chemical Plants4/20/2005 4/20/2005 4/20/200571 FR 14652(3/23/06)VOC measureRule incorporated into Rule 44554452Pump and CompressorSeals at PetroleumRefiners4/20/2005 4/20/2005 4/20/200571 FR 14653(3/23/06)VOC measureRule incorporated into Rule 44554453Refinery VacuumProducing Devices orSystems12/19/1992 12/19/1992 N/A73 FR 48(1/02/08)withdrawnVOC measure4454Refinery ProcessTurnaround12/19/1992 12/19/1992 N/A73 FR 48(1/02/08)withdrawnVOC measure4455Components atRefineries4/20/2005 4/20/2005 4/20/200571 FR 14652(3/23/06)VOC measure4501Alternate Compliancefor BARCT6/17/1999 6/17/1999 N/A no action4550ConservationManagement Practices8/19/2004 8/19/2004 8/19/200471 FR 7683(2/14/06)Baseline measureFeasibility study measure, PM2.5(2012)TSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-7Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments4565Biosolids, AnimalManure, and PoultryLitter Operations3/15/20073/15/2007N/A no action VOC measure4566 Organic Waste N/AN/AN/A N/A New rule for green waste.4570Confined AnimalFacilities10/21/20106/18/5/20096/18/200975 FR 2079(1/14/10)VOC measureLimited approval/disapproval.4601 Architectural Coatings 12/17/2009 12/17/200912/17/200910/31/2001NPR 76 FR 35167(6/16/11)69 FR 34(1/02/04)VOC measureLimited approval/disapproval - no sanctionclock (disapproved elements expired)4602Motor Vehicle andMobile EquipmentCoating Operations9/17/2009 9/17/20099/17/200912/20/2001NPR: 76 FR 3214(6/3/11)67 FR 42999(6/26/02)VOC measure4603Surface Coating ofMetal Parts andProducts9/17/2010 9/17/20109/17/201010/16/2008NPR: 76 FR 3214(6/3/11)75 FR 4612(1/19/10)VOC measure4604Can and Coil CoatingOperations9/20/2007 9/20/2007 9/20/200775 FR 4612(1/19/10)VOC measureTSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-8Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments4605Aerospace Assemblyand Component Coating6/16/2011 9/20/2007 9/20/200775 FR 3996(1/26/10)VOC measureLimited approval/disapproval4606Wood Products CoatingOperations10/16/2008 10/16/2008 10/16/200874 FR 52849(10/15/09)VOC measure4607 Graphic Arts 12/18/2008 12/18/2008 12/18/200874 FR 52849(10/15/09)VOC measure4610Glass CoatingOperations4/17/2003 4/17/2003 4/17/200369 FR 60962(10/14/04)VOC measure4612Motor Vehicle andMobile EquipmentCoating Operations –Phase 210/21/2010 10/21/2010 9/20/200775 FR 4612(1/19/10)VOC measure4621Gasoline Transfer intoStationary StorageContainers12/20/2007 12/20/2007 12/20/200774 FR 33397(7/13/09)VOC measure4622Gasoline Transfer intoMotor Vehicles12/20/2007 12/20/2007 12/20/200774 FR 33397(7/13/09)VOC measure4623Storage of OrganicLiquids5/19/2005 5/19/2005 5/19/200570 FR 53937(9/13/05)VOC measureTSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-9Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments4624Transfer of OrganicLiquids12/20/2007 12/20/2007 12/20/200774 FR 52894(10/15/09)VOC measure4625 Wastewater Separators 12/17/1992 12/17/1992 N/A73 FR 48(1/02/08)withdrawnVOC measure4641Cutback, Slow Cure,and Emulsified AsphaltPaving and MaintenanceOperations12/17/1992 12/17/1992 12/17/199275 FR 10691(3/9/10)VOC measure4642Solid Waste DisposalSite4/16/1998 4/16/1998 4/16/199866 FR 38939(7/26/01)VOC measure4651Soil DecontaminationOperations9/20/2007 9/20/2007 9/20/200774 FR 52894(10/15/09)VOC measure4652Coatings and InkManufacturing12/17/1992notsubmittedN/A N/A No sources4653 Adhesives 9/16/2010 9/16/2010 9/20/200774 FR 52894(10/15/09)VOC measure4661 Organic Solvents9/20/20079/20/2007 9/20/200775 FR 24406(5/5/2010)VOC measureTSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-10Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments4662Organic SolventDegreasing Operations9/20/2007 9/20/2007 9/20/200774 FR 37948(7/30/09)VOC measure4663Organic SolventCleaning, Storage, andDisposal9/20/2007 9/20/2007 9/20/200774 FR 37948(7/30/09)VOC measure4672Petroleum Solvent DryCleaning Operations12/17/1992 12/17/1992 12/17/199275 FR 10691(3/9/10)VOC measure4681Rubber TireManufacturing12/16/1993 12/16/1993 12/16/199363 FR 43881(8/17/98)VOC measure4682Polystyrene,Polyethylene, andPolypropylene ProductsManufacturing9/20/2007 9/20/2007 199460 FR 31086(6/13/95)VOC measure4684Polyester ResinOperations6/16/2011 9/17/2009 9/20/200775 FR 3996(1/26/10)VOC measureLimited approval/disapproval4691(461.02)Vegetable OilProcessing Operations12/17/1992 12/17/1992 12/17/199259 FR 2535(1/18/94)VOC measureTSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-11Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments4692CommercialCharbroiling9/17/2009 9/17/20099/17/20093/21/2002NPR: signed6/9/1168 FR 33005(6/03/03)Control strategy measure.4693 Bakery Ovens 5/16/2002 5/16/2002 5/16/200269 FR 22441(4/26/04)VOC measure4694Wine Fermentation andStorage Tanks12/15/2005 12/15/2005 N/A no action VOC measure4695 Brandy and Wine Aging 9/17/2009 9/17/2009 9/17/2009NPR: 76 FR33181 (6/8/11)VOC measure4701 I/C Engines - Phase 1 8/21/2003 8/21/2003 8/21/200369 FR 28061(5/18/04)Baseline measure4702 I/C Engines - Phase 2 1/18/2007 1/18/2007 1/18/200773 FR 1819(1/10/08)Control strategy measureScheduled adoption August 20114703 Stationary Gas Turbines 9/20/2007 9/20/2007 9/20/200774 FR 53888(10/21/09)Control strategy measure4801 Sulfur Compounds 12/17/1992 12/17/1992 12/17/1992 no action4802 Sulfuric Acid Mist 12/17/1992 12/17/1992 12/17/199264 FR 30396(6/08/99)Baseline measureLimited approval/disapproval -No sanctionclockTSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-12Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments4901Wood BurningFireplaces and WoodBurning Heaters10/16/2008 10/16/2008 10/16/200874 FR 57907(11/10/09)Control strategy measure4902Residential WaterHeaters3/19/2009 3/19/2009 3/19/200975 FR 24408(5/5/10)Control strategy measure4905Natural Gas-fired, fantype, residential centralfurnaces10/20/2005 10/20/2005 10/20/200572 FR 29886(5/30/07)Additional revisions scheduled for 2014 perPM2.5plan commitment8011Fugitive Dust GeneralRequirements8/19/2004 8/19/2004 8/19/200471 FR 8461(2/17/06)Baseline measures8021Construction,Demolition, Excavation,Extraction, and otherEarthmoving Activities8/19/2004 8/19/2004 8/19/200471 FR 8461(2/17/06)Baseline measures8031 Bulk Materials 8/19/2004 8/19/2004 8/19/200471 FR 8461(2/17/06)Baseline measures8041 Carryout and Trackout 8/19/2004 8/19/2004 8/19/200471 FR 8461(2/17/06)Baseline measures8051 Open Areas 8/19/2004 8/19/2004 8/19/200471 FR 8461(2/17/06)Baseline measures8061Paved and UnpavedRoads8/19/2004 8/19/2004 8/19/200471 FR 8461(2/17/06)Baseline measuresTSD for the Revised Proposalon the SJV 2008 PM2.5SIPJune 29, 2011EPA- Region 9Page B-13Appendix Table B -1Status of San Joaquin Valley AirPollution Control District RulesJune 16, 2011Rule No. RuleDate of MostRecent RuleAdopted/RevisedDate ofMost RecentRuleSubmittedDate ofMost RecentRuleApprovedFederal RegisterCiteComments8071Unpaved Vehicle/Equipment TrafficAreas9/16/2004 9/16/2004 9/16/200471 FR 8461(2/17/06)Baseline measures8081 Agricultural Sources 9/16/2004 9/16/2004 9/16/200471 FR 8461(2/17/06)Baseline measures9310 School Bus 9/21/2006 9/21/2006 9/21/200675 FR 10420(3/8/10)Baseline measure9410Employer Based TripReduction12/17/2009 12/17/2009 N/A no actionControl strategy measure. Submitted May 17,2010 (complete June 8, 2010)9510 Indirect Source Review 12/15/2005 12/15/2005 12/15/200576 FR 26609(5/9/11)No emissions reduction credit allowed.

### Appendix C -List of Document ReferencesTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page C-1 72 FR 20586 Clean Air Fine Particle Im plementation Rule; Final Rule (April 25, 2007)

75 FR 74518 2010 Proposal: Approval and Pr omulgation of Implementation Plans; State of California; 2008 San Joaquin Valley State Implementation Plan for Fine Particulate Ma tter; 2007 State Strategy; PM 2.5 ; Proposed Rule (November 30, 2010)

2007 State Strategy Proposed State Strategy for Cali fornia’s 2007 State Implementation Plan , as amended and adopted on September 27, 2007 by CARB as amended in Status Report on the State Strategy for California’s 2007 State Implementation Plan (SIP) an d Proposed Revisions to the SIP Reflecting Implementation of the 2007 State Strategy , adopted on April 24, 2009 by CARB and Progress Report on Implementation of PM 2.5 State Implementation Plans (S IP) for the South Coast and San Joaquin Valley Air Basins and Proposed SIP Revisions , adopted on April 28, 2011 by CARB

2008 PM 2.5 Plan 2008 PM 2.5 Plan, adopted on April 30, 2008 by the SJVAPCD as amended in 2008 PM 2.5 Plan Amendment to Extend the Rule 4905 Amendment Schedule and Progress Report on Implementation of PM 2.5 State Implementation Plans (SIP ) for the South Coast and San Joaquin Valley Air Basins and Proposed SIP Revisions , adopted on April 28, 2011 by CARB

2009 State Strategy Status Report Status Report on the State Strategy for California’s 2007 State Implementation Plan (SIP) and Prop osed Revisions to the SIP Reflecting Implementation of the 2007 State Strategy , adopted on April 24, 2009 by CARB

2010 Draft TSD Air Division, U.S. EPA, Regi on 9, “Draft Technical Support Document for the Revised Proposed Action on the San Joaquin Valley 2008 PM 2.5 Plan and the San Joaquin Valley Po rtions of the Revised 2007 State Strategy,” November 8, 2010

2010 Proposal Approval and Promulgation of Implementation Plans; State of California; 2008 San Joaquin Valley St ate Implementation Plan for Fine Particulate Matter; 2007 State Strategy; PM 2.5 ; Proposed Rule. 75 FR 74518 (November 30, 2010)

2011 Progress Report Progress Report on Implementation of PM 2.5 State Implementation Plans (SIP) for the South Coast and San Joaquin Valley Air Basins and Proposed SIP Revisions , adopted on April 28, 2011 by CARBTSD for the Revised Proposal on the SJV 2008 PM 2.5 SIP Ju ne 29, 2011

EPA- Region 9 Page C-2 CARB modeling Supplement Letter, John DaMassa, Chief Mode ling and Meteorology Branch, CARB to Frances Wicher, Office of Air Planning, EPA Region 9, January 28, 2011

CARB Progress Report supplement Letter, Lynn Terry, Deputy Executive Office, CARB, to Elizabeth Adams, Deputy Director, Air Di vision, EPA–Region 9, May 18, 2011

CARB VOC supplement Letter, James N. Goldstene, Executive Officer, CARB, to Frances Wicher, Office of Air Planning, EPA Region 9, January 28, 2011, Attachment 4, “Air Resources Board comments on U.S. EPA’s November 30, 2010 proposal that VOC be considered a significant PM 2.5 Precursor for the San Joaquin Valley 2008 PM 2.5 State Implementation Plan (SIP).”

Plan Same as 2008 PM 2.5 Plan

PM 2.5 Implementation Rule 40 CFR part 51, subpart Z promulga ted at 72 FR 20586 (April 25, 2007)

Revised 2007 State Strategy Same as 2007 State Strategy

SJV 2008 PM 2.5 Plan Same as 2008 PM 2.5 Plan

SJV 2008 PM 2.5 SIP 2008 PM 2.5 Plan and 2007 State Strategy (as it applies to the SJV)