Technical Support Document 

for the 

Revised Proposed Rulemaking Action 

on the 

San Joaquin Valley 2008 PM2.5 Plan 

and the San Joaquin Valley Portions of the 

Revised 2007 State Strategy

Air Division 

U.S. EPA Region 9 

June 29, 2011 
For further information on this technical 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 support document may be found in the docket for this 

rulemaking, docket no. EPA-R09-OAR-2010-0516, which 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 (PM2.5) 1

1. The PM2.5 National Ambient Air Quality Standards 1

a. Level and Form of the Standard 1

b. Health Effects 2

c. Revisions to the 24-Hour PM2.5 Standards 2

2. Implementing the PM2.5 NAAQS 2

a. Designations 2

b. PM2.5 Planning Requirements 3

B. PM2.5 Air Quality in the San Joaquin Valley 5

1. PM2.5 Levels in the SJV 6

2. Seasonality and Chemical Composition of PM2.5 in the SJV 7

C. California’s Submittals Constituting the SJV PM2.5 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 PM2.5 SIP

A. Emissions Inventories 16

1. Requirements for Emissions Inventories 16

2. Emissions Inventories in the SJV PM2.5 SIP 17

3. November 2010 Proposed Action 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 PM2.5 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 PM2.5 Equivalency 46

5. Effect of Inventory Changes on the Air Quality Modeling and Attainment 

Demonstrations 47

C. PM2.5 Attainment Plan Precursors 50

1. Requirements for the Control of PM2.5 Precursors 50

2. Identification of PM2.5 Attainment Plan Precursors in the SJV 2008 PM2.5 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 PM2.5 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 PM2.5 Plan 78

3. November 2010 Proposed Action on the 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 PM2.5 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 Control Strategy Measures 98

i. Section 209 Waiver 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 PM2.5

SIP 108

v. Proposed Action on Enforceable Commitments 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 PM2.5 Plan 109

3. November 2010 Proposed Action on the Attainment Demonstration in the SJV 2008 

PM2.5 Plan 114

4. Evaluation and Conclusions 114

H. Reasonable Further Progress Demonstrations 116

1. Requirements for Reasonable Further Progress Demonstrations 116

2. RFP Demonstration in the SJV 2008 PM2.5 Plan 117

3. November 2010 Proposed Action on the RFP Demonstration in the SJV 2008 PM2.5 Plan

119

4. Evaluation and Conclusions 119

I. Contingency Measures 124

1. Requirements for Contingency Measures 124

2. Contingency Measures in the SJV 2008 PM2.5 Plan and 2011 Progress Report 125

a. New Commitment 125

b. General Surplus Reductions in the RFP Demonstration and Post-2014 125

c. Adopted or Scheduled for Adoption Rules/Incentive Funds 126

3. November 2010 Proposed Action on the Contingency Measures in the SJV 008 PM2.5 SIP

128

4. Evaluation and Conclusions 128

a. New Commitment 129

b. General Surplus Reductions in the 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 PM2.5 SIP 135

1. Requirements for Motor Vehicle Emissions Budgets 135

2. Motor Vehicle Emissions Budgets in the SJV 2008 PM2.5 SIP 136

a. MVEB Submitted in SJV 2008 PM2.5 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 PM2.5 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 PM2.5 or PM2.5 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 Rule, 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 Forecasting and Planning Inventory System 

CEIDARS: California Emissions Inventory Development and Reporting System 

CERR: Consolidated Emissions Reporting 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 Particulate 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: PM2.5

FMVCP: Federal motor vehicle control program 

FR: Federal Register 

FRM: Federal Reference Method 

FTA: Federal Transit Administration 

HNO3: nitric acid 

I/C: internal combustion 

IMS95: 1995 Integrated Monitoring Study (in the San Joaquin Valley) 

km: kilometer 

m: meter 

m3: cubic meter 

mb: millibars 

MCR: mid-course review 

MFB: mean fractional bias 

MFE: mean fractional error 

MM5: a mesoscale model 

MMPA: meteorological model 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 

NH3: ammonia 

NH4NO3: ammonium nitrate 

NO2: nitrogen dioxide 

NOx: oxides of nitrogen 

NSR: new source review 

NYQ: not yet quantified 

O3: ozone 

OC: organic carbon 

OH: hydroxyl radical 

OTAQ: EPA’s Office of Transportation and Air Quality 

PBL: planetary boundary layer 

PM: particulate matter 

PM10: particulate matter with a diameter of 10 μm or less, includes PM2.5

PM2.5: particulate matter with a diameter of 2.5 μm 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, derived water, inferred carbonaceous material balance 

approach 

SC: South Coast 

SIP: state implementation plan 

SJV: San Joaquin Valley 

SJVAPCD/SJVUAPCD: San Joaquin Valley (Unified) Air Pollution Control District 

SMAT: Speciated Modeled Attainment Test 

SO2: sulfur dioxide 

SOA: secondary organic aerosol 

STN: Speciation Trends Network 

SOx: 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 evidence 
EPA- Region 9 Page 1

Technical Support Document 

for the Revised Proposed Rulemaking Action on the 

San Joaquin Valley 2008 PM2.5 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 Valley Air Pollution Control District’s 2008 PM2.5 Plan

(adopted April 30, 2008 and revised on June 17, 2010) and the related portions 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 PM2.5 plans and EPA’s 

regulations and policies interpreting these requirements. It also describes the elements of the SJV 

2008 PM2.5 Plan and 2007 State Strategy, as revised and 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 November 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 (PM2.5)

1. The PM2.5 National Ambient Air Quality Standards

a. Level and Form of the Standard 

On July 18, 1997, EPA revised the primary and secondary national ambient air quality 

standards (NAAQS) for particulate matter (PM) to add new annual and 24-hour standards for 

PM2.5, 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 PM2.5 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 PM10) were established in 1987. 52 FR 24663 (July 1, 1987). In the 1997 PM 

NAAQS revision, EPA also revised the standards for PM10 but these revised PM10 standards were later vacated by 

the courts and the 1987 PM10 standards remained in effect. In the 2006 NAAQS revision, the 24-hour PM10

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 PM10 NAAQS. See 73 FR 66759 (November 12, 2009). 
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standards are set at a level of 15 micrograms per cubic meter (μ/m3), as determined by the 3-year 

average of annual mean PM2.5 concentrations. The 24-hour standards were set at a level of 

65 μ/m3, as determined by the 3-year average of the 98th percentile of 24-hour concentrations. 

40 CFR § 50.7. 

b. Health Effects 

EPA established primary air quality standards for PM2.5 based on substantial evidence 

from numerous health studies demonstrating that serious health effects are associated with 

exposures to elevated levels of the pollutant. Epidemiological studies have shown statistically 

significant correlations between elevated PM2.5 levels and premature mortality. Other important 

health effects associated with PM2.5 exposure include aggravation of respiratory and 

cardiovascular disease (as indicated by increased hospital admissions, emergency room visits, 

absences from school or work, and restricted activity days), changes in lung function and 

increased respiratory symptoms, as well as new evidence for more subtle indicators of 

cardiovascular health. Individuals particularly sensitive to PM2.5 exposure include older adults, 

people with heart and lung disease, 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 PM2.5 standards is estimated to lead to reductions in health 

impacts, including tens of thousands fewer premature deaths each year, thousands fewer hospital 

admissions and emergency room visits each year, hundreds of thousands fewer absences from 

work and school, and hundreds of thousands fewer respiratory illnesses in children annually. See 

72 FR 20586, 20587 (April 25, 2007). 

c. Revisions to the 24-Hour PM2.5 Standards 

In October 2006, EPA completed another review of the NAAQS for PM. With regard to 

the primary standards, the 24-hour PM2.5 standards are strengthened to a level of 35 μ/m3, 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). Attainment of the 2006 PM2.5 standards is 

estimated to lead to additional reductions in health impacts over the 1997 standard, including 

approximately 1,200 to 13,000 fewer premature 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 fewer respiratory illnesses in children annually. 

72 FR 20586, 20587. 

2. Implementing the PM2.5 NAAQS

a. Designations 

The process for designating areas either attaining or not attaining following promulgation 

of a new or revised NAAQS is found in CAA section 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 for 
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that NAAQS. In the case of the 1997 PM2.5 standards, however, Congress amended section 107 

to extend the schedule for EPA to initiate the designations process until three calendar years of 

air quality data, measured at Federal Reference Method monitors, were gathered. See 

section 6102(c)(1)(d) of the Transportation Equity Act for the 21st Century. EPA and state air 

quality agencies initiated the monitoring process for the PM2.5 NAAQS in 1999 and deployed all 

air quality monitors by January 2001. As a result, the designation process for the 1997 PM2.5

NAAQS did not begin until 2004. 

By no later than 120 days prior to promulgating 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 recommendation, EPA must promulgate the designation that it deems 

appropriate. 

In April 2003, EPA requested that California submit its designation recommendations, 

based on ambient air quality data from 2001 to 2003, and supporting documentation by 

February 15, 2004. California submitted its recommendations on February 11, 2004. See Letter, 

Catherine Witherspoon, CARB, to Wayne Nastri, EPA-Region 9, February 11, 2004. On 

December 17, 2004, EPA issued final PM2.5 designations for areas violating 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 effective on April 5, 2005. The designations are 

codified at 40 CFR part 81, subpart C.3

The designation of an area as nonattainment starts 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 PM2.5 , states have up to three years after final designations to submit 

their SIPs to EPA. The SIPs for the 1997 PM2.5 SIP were due on April 5, 2008, three years after 

the effective date of the designations. 

b. PM2.5 Planning Requirements 

In order to assist states in developing effective plans to address their PM2.5 nonattainment 

problem, EPA issued the Clean Air Fine Particulate Implementation Rule, also known as the 

PM2.5 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 PM2.5 implementation rule covers most CAA requirements for PM2.5 state 

implementation plans. A list of these CAA requirements, the corresponding provision in the 

PM2.5 implementation rule and preamble are given in Table IA-1 below. 

 3

 On November 13, 2009, EPA designated the SJV, along with other areas in the Country, as 

nonattainment for the 2006 24-hour PM2.5 standards. 74 FR 58688. California is now required to submit a plan 

demonstrating attainment of the 35 μg/m3 24-hour standards by December 14, 2012. 74 FR 58688, 58689. The 2008 

PM2.5 Plan we are reviewing in this TSD addresses only the 1997 24-hour PM2.5 standards of 65 μg/m3 and annual 

standards of 15 μg/m3

. 
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Table IA-1 

CAA Requirements for PM2.5 Attainment State Implementation Plans

CAA 

Section 

PM2.5 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 PM2.5 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. 
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In June 2007, a petition to the EPA Administrator was filed on behalf of several public 

health and environmental groups requesting reconsideration of four provisions in the PM2.5

implementation rule. See Earthjustice, “Petition for Reconsideration in the Matter of the Final 

Clean Air Fine Particulate Implementation 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 NOx and SO2 RACT requirements for electric generating 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 Air 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 (codified 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 analyzing 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 regulated entity to bear, in light of benefits. 

72 FR 20586 at 20619-20620. EPA granted the petition 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 granted the petition for this provision on 

May 13, 2010. Letter, Gina McCarthy, Assistant Administrator for Air and Radiation, 

EPA, to David Baron and Paul Cort, Earthjustice, May 13, 2010. 

The disputed provisions of the PM2.5 implementation rule are, for the most part, not 

relevant to today’s proposal because California did not rely on them in developing the PM2.5 plan 

for the San Joaquin Valley. We address each of these provisions later in this TSD: the first three 

in section II.D. (RACM/RACT) and the fourth in section II.H. (RFP). 

B. PM2.5 Air Quality in the San Joaquin Valley

The San Joaquin Valley PM2.5 nonattainment area is located in the southern part of 

California’s Central Valley. It is home to almost 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 Coast Mountain range to the west, the Tehachapi Mountains to the 

south, and the Sierra Nevada range to the east. In total, the SJV PM2.5 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 San Joaquin Valley (Unified) Air Pollution Control 

District (SJVAPCD, SJVUAPCD, or District). 
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1. PM2.5 Levels in the SJV

Annual and 24-hour PM2.5 levels in the urban Bakersfield area in the southern SJV are 

the highest recorded in the United States at 21.2 μg/m3 and 65 μg/m3 for the 2008-2010 period.4

Since comprehensive monitoring began for PM2.5 in the SJV in the late 1990, the area has seen a 

significant decline in ambient levels, especially in the 2000-2005 time period. See Figures IB-1 

and IB-2. Between 2005 and 2008, PM2.5 concentrations increased at many monitoring sites in 

the Valley but began to decline again in the 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 Database, June 2011. The level of 1997 annual PM2.5 NAAQS is 15 μg/m3 

 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 ambient concentration calculated using 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 PM2.5 NAAQS are found in 40 CFR 50, Appendix N, 

Sections 1(c)(1) and 1(c)(2), respectively. 
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Figure IB-2 

Source: EPA’s Air Quality Systems Database, June 2011. The level of 1997 24-hour PM2.5 NAAQS is 65 

μg/m3.

2. Seasonality and Chemical Composition of PM2.5 in the SJV

PM2.5 in the air is a complex mixture of components. Common components include: 

nitrate (NO3); sulfate (SO4); ammonium; elemental carbon; a great variety of organic 

compounds; and inorganic material (including metals, dust, sea salt, and other trace elements) 

generally referred to as crustal material, although it may contain material from other sources. 

Primary particles are emitted directly into the air as a solid or liquid particle (e.g., elemental 

carbon from diesel engines or fire 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 NOx, SO2, VOC, and ammonia. 

Understanding the compounds that make up an area’s PM2.5 problem is necessary in order to 

develop control strategies that are effective for attaining the NAAQS. 72 FR 20586 at 20589. 

In the SJV, the levels and nature of PM2.5 in the ambient air vary by season. See 

Figures IB-4 to IB-7; see also SJV 2008 PM2.5 Plan Progress Report, Figure A-7. Higher PM2.5

concentrations occur during the winter, between late November and February, when ambient 

PM2.5 is dominated by ammonium nitrate, formed from NOx and ammonia emissions, and 

directly-emitted particulates, such as wood smoke. During the winter, the SJV experiences 
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extended periods of stagnant weather with cold, damp, foggy conditions; conditions that are 

conducive to the formation of secondary ammonium nitrate particulates and encourage wood 

burning. During the summer, PM2.5 levels generally remain below 15 μg/m3

, 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. 

.
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Figures IB-4 

Source: 2008 PM2.5 Plan, Appendix H, Figure H-5.

Figure IB-5 

 Source: 2008 PM2.5 Plan, Appendix H, Figure H-4. 
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Figure IB-7 

 Source: 2008 PM2.5 Plan, Appendix H, Figure H-6. 

Figure IB-8 

 Source: 2008 PM2.5 Plan, Appendix H, Figure H-7. 
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C. California’s Submittals Constituting the SJV PM2.5 State Implementation 

Plan

Five submittals or parts of submittals comprise the SJV PM2.5 attainment state 

implementation plan. We will refer to these five submittals or parts of submittals collectively as 

the SJV PM2.5 [attainment] SIP: 

1. 2008 PM2.5 Plan, adopted on April 30, 2008 by the SJVUAPCD and on May 22, 2008 by 

CARB, submitted with the adopting resolutions 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 Joaquin Valley Unified 

Air Pollution Control District 2008 PM2.5 Plan, April 30, 2008; CARB Resolution 

No. 08-28, May 22, 2008; and letter, James N. Goldstene, Executive Officer, CARB to 

Wayne Nastri, Regional Administrator, EPA Region 9, June 30, 2008 with enclosures. 

This document will be referenced in this TSD and the Federal Register proposal as the 

2008 PM2.5 Plan, the SJV 2008 PM2.5 Plan, or simply the Plan. 

2. Proposed State Strategy for California’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, Regional Administrator, EPA Region 9, 

November 16, 2007, with enclosures. This document 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 Reflecting Implementation of the 2007 State 

Strategy, adopted on April 24, 2009 by CARB, submitted with the adopting resolution 

and other supporting documentation 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 Administrator, 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 PM2.5 Plan Amendment to Extend the Rule 4905 Amendment Schedule, adopted on 

June 17, 2010 by the SJVUAPCD, submitted with adopting resolution and other 

supporting documentation by CARB on September 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, Regional Administrator, EPA Region 9, 

September 15, 2010, with enclosures. 

5. Progress Report on Implementation of PM2.5 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, 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. 
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documentation by CARB on May 18, 2011.6 See CARB Resolution No. 11-24, 

April 28, 2009 and letter, James N. Goldstene, Executive Officer, CARB, to Jared 

Blumenfeld, Regional Administrator, EPA Region 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 PM2.5 Plan will be to the Strategy as revised in 2009 and 2011 and the Plan as 

revised in 2010 and 2011, respectively, unless explicitly stated otherwise. 

In addition to these plan submittals, the District and CARB have provided information on 

the implementation status of the SJV 2008 PM2.5 SIP’s control strategy. CARB also provided 

supplemental documentation of the air quality modeling and further analysis of the effectiveness 

of VOC controls for reducing PM2.5 levels in the Valley as well as further information supporting 

the 2011 Progress Report. This additional information is 

1. Letter, John DaMassa, Chief Modeling and Meteorology Branch, CARB to Frances 

Wicher, Office of Air Planning, EPA Region 9, January 28, 2011 providing supplemental 

air quality modeling documentation (CARB modeling supplement). 

2. 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 PM2.5 Precursor for the San Joaquin Valley 2008 PM2.5 State Implementation 

Plan (SIP).” (CARB VOC supplement) 

3. SJVAPCD, 2008 PM2.5 Plan Progress Report, Draft March 2011 (SJV PM2.5 Progress 

Report). 

4. Letter, Lynn Terry, Deputy Executive Office, CARB, to Elizabeth Adams, Deputy 

Director, Air Division, EPA–Region 9, May 18, 2011. (CARB Progress Report 

supplement). 

Finally, both CARB and the District have adopted and submitted numerous rules that 

reduce emissions in the San Joaquin Valley and contribute to progress in meeting the PM2.5

NAAQS in the area. See Appendices A and B of this TSD. 

 6

 Only Appendices B, C and D of the 2011 Progress Report are submitted as a SIP revision. The balance of 

the report is for informational purposes only. See May 18, 2011 Goldstene Letter. 
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D. Public Notice and Hearing Requirements 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 regulations in 40 CFR § 51.102. 

Both the District and CARB have satisfied applicable statutory and regulatory 

requirements for reasonable public notice and hearing prior to adoption and submittal of the 2008 

PM2.5 Plan. The District conducted public workshops, provided public comment periods, and 

held a public hearing prior to the adoption of the Plan on April 30, 2008. See SJVUAPCD 

Governing Board Resolution, page 3. CARB also provide the required 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 Consider the Approval of the SJV 2008 PM2.5 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 public 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) for the Federal 8-Hour Ozone and PM2.5 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 revisions to the Strategy. 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 the 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 PM2.5, 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 incomplete will become complete by operation of 

law six months after the day of submittal. A completeness review allows us to determine if the 

submittal includes all the necessary items and information we need to act on it. 

We make completeness determinations using criteria we have established in 

40 CFR part 51, Appendix V. These criteria fall into two categories: administrative information 

and technical support information. The administrative information provides documentation that 
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the state has followed basic administrative procedures during the SIP-adoption process and thus 

we have a legally-adopted SIP revision in front of us. The technical support information provides 

us the information we need to determine the impact 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 completeness 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 PM2.5 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 complete 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. 
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II. Evaluation of the San Joaquin Valley 2008 PM2.5 SIP 
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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 from all sources of the relevant 

pollutant.” Pursuant to this section, the PM2.5 implementation rule requires a state to submit, 

within three years of the designation of one of its areas as nonattainment, statewide emissions 

inventories of direct PM2.5 and PM2.5 precursors. These inventories should meet the data 

requirements of EPA’s Consolidated Emissions Reporting Rule (CERR, codified at 

40 CFR part 51 subpart A). 40 CFR § 51.1008(a)(1).7 Direct PM2.5 includes condensable PM. 

40 CFR § 51.1000. PM2.5 precursors are NOX, SO2, 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 PM2.5 implementation rule also requires a state to submit a baseline emissions 

inventory as part of the attainment and RFP demonstrations in its PM2.5 attainment plan. The 

base year for this inventory should be calendar year 2002 or other suitable year for areas initially 

designated nonattainment for the PM2.5 in 2004-2005. 40 CFR § 51.1008(b). The baseline 

inventory should be appropriate for the geographical area addressed by the PM2.5 attainment plan 

and consistent with applicable EPA guidance. 72 FR 20586 at 20648. A state is also required to 

submit any additional emissions inventory information 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 Quality Standards (NAAQS) 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 inventories for 8-hour 

ozone, PM2.5, and regional haze SIPs. 

The emissions inventories required under the PM2.5 implementation rule (as opposed to 

the CERR) are SIP provisions that must be approved by EPA under CAA section 110(k) and are 

subject to public hearing requirements pursuant to sections 110(a)(2) and (l). A state should 

include in its SIP submittal documentation explaining 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. See 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 consolidating and harmonizing new 

emissions reporting requirements with pre-existing sets of reporting requirements under the NOX SIP Call (which 

does not apply to California). Because this AERR was not finalized until after the submittal of the SJV PM2.5 Plan, 

its data requirements, in that they differ from the CERR requirements, do not apply to the Plan. 
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2. Emissions Inventories in the SJV PM2.5 SIP

Note: We discuss CARB’s statewide inventory to provide background to our evaluation of the 

emissions inventories in the SJV 2008 PM2.5 Plan. We are not proposing any SIP action on the 

statewide inventory here, only on the SJV inventories. EPA will address the statewide inventory 

in a separate rulemaking. 

CARB submitted statewide inventories for direct PM2.5 and PM2.5 precursors (except for 

ammonia) as part of the 2007 State Strategy. See Appendix A for the emissions inventory output 

tables and Appendix F for documentation of the emissions inventory. Inventories 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 California Emissions Inventory Development and 

Reporting System (CEIDARS) and the California Emission Forecasting and Planning Inventory 

System (CEFS) databases. Both systems are described in Appendix F. 

The inventories in Appendix A are summer season planning inventories on which the 

2007 State Strategy is based. Baseline inventories incorporate reductions from control measures 

adopted prior to December 2006. 2008 PM2.5 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 Appendix A and can also be found in 

Appendix B to the December 2007 draft of the SJV 2008 PM2.5 Plan. 

The planning inventories for direct PM2.5 and all PM2.5 precursors (including ammonia) 

for the SJV PM2.5 nonattainment area together with additional documentation for the inventories 

are found in Appendix B of the SJV 2008 PM2.5 Plan. Both average winter day and average 

annual day inventories are provided for the year 2005 (the base year for the attainment and RFP 

demonstrations) and each year from 2009 to 2014. A winter inventory is provided because the 

majority of high PM2.5 days in the SJV occur during the winter months between November and 

February. 2008 PM2.5 Plan, Figures H-4 and H-5. The inventories use EMFAC2007 for 

estimating on-road motor vehicle emissions. 2008 PM2.5 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 PM2.5 Plan’s inventories, the District used CARB’s 2002 

inventory. 2008 PM2.5 Plan, p. B-1. The 2002 inventory was projected to 2005 and future years 

using CEFSv 1.06. 2008 PM2.5 Plan, p. B-1. 

All inventories include emissions from point, area, on-road, and non-road sources. None 

specifically show emissions from non-anthropogenic sources (that is, natural sources) although 

inventories developed for input into the air quality modeling do include such sources. 2008 PM2.5

Plan, p. G-3. 

A summary of the planning inventories 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 PM2.5 standards; therefore, 

baseline inventories are given not only for years of importance for PM2.5 plans but also ones of importance for 8-

hour ozone plans. 
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3. November 2010 Proposed Action on Emissions Inventory

In our November 2010 proposed action on the SJV 2008 PM2.5 SIP, we proposed to find 

that the 2002 emissions inventory in the 2007 State Strategy and the 2008 PM2.5 Plan met the 

CAA section 172(c)(3) requirement for the State to submit a plan provision that includes a 

comprehensive, accurate, current, inventory of actual emissions from all sources of the relevant 

pollutant. We also proposed to find that the baseline inventories in the SJV 2008 PM2.5 Plan 

provided an adequate basis for the reasonably available control measure, reasonable further 

progress and attainment demonstrations in the Plan. See 2010 Draft TSD, section II.A. and 

75 FR 74518 at 74522. 

4. Evaluation and Conclusions

The emissions inventories were made available to the public for comment at the same 

time as the draft 2007 State Strategy and 2008 PM2.5 Plan and were subject to public hearing as 

part of final version of the Strategy and Plan. See CARB Resolution No. 07-28, p. 3 and 

SJVUAPCD Governing Board Resolution, p. 3. 

The SJV PM2.5 SIP uses a 2005 base year inventory. When considered together with the 

inventory documentation in Appendix F of the State 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 PM2.5 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-approved version of California’s mobile source emissions model, 

EMFAC2007), address comprehensively all source categories in the SJV, and meet the 

applicable requirements of EPA’s inventory guidance. For these reasons, EPA is proposing to 

approve the 2005 base year emissions inventory in the SJV PM2.5 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 PM2.5 SIP provide an adequate basis for the reasonably 

available control measure, reasonable further progress and attainment demonstrations. 

Post-Submittal Revisions to the Plan’s Base 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, Appendix E. As a result, current and projected 

emission levels from these categories are now substantially lower than were projected in 2008 

SJV PM2.5 Plan. At this time, California is reflecting 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, they do not affect the target level of overall emissions needed to 

demonstrate attainment) or the starting point for the reasonable further progress demonstration. 

Their principal effect is to reduce the reductions needed from the Plan’s control strategy to 

demonstrate RFP and attainment. 
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CARB also made technical changes to the inventory for diesel trucks and buses as part of 

its December 2010 rulemaking amending its In-Use 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 State of Reasons for Proposed Rulemaking, Proposed 

Amendments 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 revised the inventory for off-road equipment as 

part its December 2010 rulemaking amending the 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 State of Reasons for Proposed Rulemaking, Proposed 

Amendments to the Regulation for In-Use Off-Road Diesel-Fueled 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 NOx and 

PM2.5 inventory by approximately 6 percent of the NOx 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 effects of the revisions to the truck, bus, and offroad equipment emissions inventory categories on the approvability of the attainment and RFP 

demonstrations in the Plan and concluded they do not adversely affect them. See sections II.B.5. 

and II.H. of this TSD. We note that the State and District are currently working on a revisions to 

the SJV PM2.5 SIP to address the 2006 24-hour PM2.5 standard. These revisions are due to EPA 

in December 2012 and will include the latest updates to the emissions inventories. 
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Table A-1 

Emissions Inventory Summary for the San Joaquin Valley PM2.5 Nonattainment A

(tons per day) 

 Annual Average Day Winter Averag

2005 2009 2012 2014 2005 2009 

Direct PM2.5

Stationary Sources 13.3 13.8 14.2 14.4 12.8 13.3 Area Sources 51.5 46.8 45.8 45.2 54.6 51.2 On-Road Mobile Sources 12.1 11.3 9.9 8.9 12.2 11.4 Off-Road Mobile Sources 9.0 7.9 7.2 6.6 8.1 7.0 Total 86.0 79.8 77.0 75.0 87.6 82.9 

Nitrogen Oxides 

Stationary Sources 80.1 62.7 58.7 56.5 71.9 58.5 Area Sources 13.5 11.0 10.8 10.7 18.2 16.3 On-Road Mobile Sources 327.9 297.4 243.8 206.7 342.1 311.5 Off-Road Mobile Sources 153.9 129.7 111.1 102.2 141.0 118.4 Total 575.4 500.9 424.4 376.2 573.1 504.7 

Sulfur Dioxide 

Stationary Sources 20.4 20.6 21.5 22.0 19.6 20.0 Area Sources 0.9 0.9 0.9 0.9 0.8 0.8 On-Road Mobile Sources 2.6 0.7 0.7 0.7 2.5 0.7 Off-Road Mobile Sources 2.4 0.8 0.8 0.8 2.3 08 
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Table A-1 

Emissions Inventory Summary for the San Joaquin Valley PM2.5 Nonattainment A

(tons per day) 

 Annual Average Day Winter Averag

2005 2009 2012 2014 2005 2009 

Total 26.4 23.0 23.8 24.5 25.2 22.3 

Volatile Organic Compounds 

Stationary Sources 121.5 121.9 123.9 129.5 101.4 102.0 Area Sources 140.7 122.4 125.5 128.0 145.4 127.1 On-Road Mobile Sources 94.8 76.5 64.8 57.2 99.7 80.9 Off-Road Mobile Sources 62.7 54.3 50.8 48.5 55.7 48.6 

Total 419.8 375.2 365.0 363.2 402.2 358.6 

Ammonia 

Stationary Sources 19.8 21.0 22.2 23.0 19.8 21.0 Area Sources 355.9 381.9 405.8 423.1 356.9 382.9 On-Road Mobile Sources 6.2 5.3 5.0 4.8 6.2 5.3 Off-Road Mobile Sources 0 0 0 0 0 0 

Total 382.0 408.3 433.0 451.0 382.9 409.2 

Source: SJV 2008 PM2.5 Plan, Appendix B, Tables B-1 to B-5. 
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B. Air Quality Modeling 

1. Requirements for Air Quality Modeling

The PM2.5 implementation rule requires states to submit an attainment demonstration 

based on modeling results. Specifically, 40 CFR § 51.1007(a) states: 

For any area designated as nonattainment for the PM2.5 NAAQS, the State must 

submit an attainment demonstration showing that the area will attain the annual 

and 24-hour standards as expeditiously 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 emissions reduction analyses on which the 

State has based its projected attainment date. The attainment date justified by the 

demonstration must be consistent with the requirements of § 51.1004(a). The 

modeled strategies must be consistent 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 PM2.5 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 PM2.5 and PM2.5 precursors that the area can accommodate without exceeding the 

NAAQS, and to assess whether the proposed control 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 performance. Once the performance is determined 

to be acceptable, future year emissions inventory changes are simulated to determine the 

relationship between emissions reductions and changes in ambient air quality throughout the air 

basin. 

The procedures for modeling PM2.5 as part of an attainment SIP are contained in EPA's 

“Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air 

Quality Goals for the 8-Hour Ozone and PM2.5 NAAQS and Regional Haze.” 

2. Air Quality Modeling in the SJV 2008 PM2.5 Plan

The 2008 PM2.5 Plan uses multiple modeling analyses to demonstrate attainment of the 

PM2.5 NAAQS in the SJV. It mainly relies on several variants of an approach based on receptor 

modeling for the annual PM2.5 NAAQS. This approach begins with Chemical Mass Balance 

(CMB) modeling, which distinguishes the ambient PM2.5 contributions of several broad 

emissions source categories based on how they match the chemical species components of PM2.5

measurements. The CMB results are then refined with emissions inventory data to distinguish 

additional source categories, an area of influence analysis to better reflect particular sources 

affecting a monitor, and information from past photochemical modeling to assess how 

secondarily formed PM2.5 will respond to changes in precursor emissions. Several variants of this 

 9

 EPA’s November 9, 2005 final rule revising the “Guideline on Air Quality Models” in 40 CFR part 51, 

Appendix W is available at www.epa.gov/ttn/scram/guidance/guide/appw_05.pdf.
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approach are used, with CMB results from different locations and different base case years. This 

modeling only addresses the annual PM2.5 standard. 

The Plan also includes an attainment demonstration using photochemical modeling with 

the Community Multiscale Air Quality (CMAQ) model. This modeling incorporates data 

collected during 2000 California Regional Particulate Air Quality Study (CRPAQS) and 

addresses both the annual and 24-hour PM2.5 standards. It is considered the main attainment 

demonstration, with the receptor modeling 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 photochemical modeling focused primarily on the annual 

standard. The annual standard was viewed as controlling in the sense that any control strategy 

that provided for annual standard attainment would also provide sufficient emissions reductions 

for 24-hour standard attainment. At the time the Plan was prepared in 2006, ambient data for 

PM2.5 was consistent with attainment of the 24-hour NAAQS. See 2008 PM2.5 Plan, Appendix A, 

Table A-9. 

The 2008 PM2.5 Plan discusses air quality modeling in the “Executive Summary,” 

Chapter 3 “What is Needed to Demonstrate Attainment?,” Appendix E “District Additions to the 

Conceptual Model,” Appendix F “SJV PM2.5 SIP Modeling Protocol,” Appendix G “Regional 

Air Quality Modeling,” Appendix H “Weight of Evidence,” and the additional appendices “2014 

Receptor Modeling Documentation,” “Meteorological 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 PM2.5

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 PM2.5 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 considers the photochemical modeling to be the main 

basis for the PM2.5 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 PM2.5 plan precursor in SJV, found in the 

docket for this proposal. 
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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 identifying potential stakeholders and for developing 

a modeling protocol. It can also influence the choice of air quality model, modeling domain, grid 

cell size, priorities for quality assuring and refining emissions estimates, and the choice of initial 

diagnostic tests to identify potentially effective control strategies. In general, a conceptual 

description is useful for helping a state to identify priorities and allocate resources in performing 

a modeled attainment demonstration. 

The Guidance at pp. 128-130 lists 13 elements that should be addressed in the conceptual 

description. These are: 

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

2. relative importance of primary and secondary components of PM2.5

3. most prevalent components of measured PM2.5

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 indicators that have accompanied 

emissions changes 

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

11. past modeling results 

12. distinctive meteorological measurements coinciding with exceedances 

13. correlations of PM or components with each other and other pollutants 

The Plan contains ample discussion of the PM2.5 problem in the San Joaquin Valley. 

Much of the same material is covered in Chapter 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 PM2.5 concentrations of seasonal changes, the influence of 

meteorology including fog, dry deposition, and emissions variations. Analysis of data collected 

during the 2000 CRPAQS substantially added to the understanding of PM2.5 in the SJV. The 

cited chapters and appendices excerpt a number 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 conclusions 
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In brief, the PM2.5 problem in the San Joaquin Valley is mainly due to secondary 

particulates, especially in winter, with a substantial primary component throughout the year and 

during some winter episodes. PM2.5 concentrations are much higher in winter than in summer. 

Concentrations in April through September are generally less than 15 μg/m3

, the level of the 

annual NAAQS. Nonattainment of the annual NAAQS is driven by high wintertime 

concentrations, including episodes during stagnant, moist conditions. Stagnant conditions and 

surface radiation inversions restrict pollutant dispersion, allowing concentrations to build to high 

levels. The enclosure of the SJV by mountain ranges restricts air flow and 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 end and experiences stagnation during winter and 

recirculation of polluted air via the Fresno eddy during summer. 

The dominant component of PM2.5 in the SJV is ammonium nitrate, formed from the 

abundant ammonia emissions in this agricultural area and NOx 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 work, ammonia appears to be so abundant that 

formation of ammonium nitrate is limited by the rate of HNO3 (nitric acid) formation via 

oxidation of NOx, rather by the availability of ammonia. In addition to ammonium nitrate, 

organic carbon (OC) can also be a significant component of PM2.5. The main sources of OC are 

agricultural vegetative burning, residential wood combustion, other direct sources such as 

vehicles, and a smaller contribution from secondary organic aerosols. During CRPAQS it was 

found that organic carbon has a strong spatial gradient, being much higher in urban areas, 

especially during high PM2.5 episodes. This gradient was explained as being due to the greater 

vehicle emissions and residential wood combustion in cities. Ammonium sulfate is a relatively 

small component of secondary PM2.5 in the SJV unlike areas in the eastern part of the United 

States where it is the dominant component of secondary PM2.5. 

As discussed at 2008 PM2.5 Plan pages 3-32 and F-39, the annual standard is the focus of 

the modeling analysis because ambient concentrations of PM2.5 in the SJV were below the 24-

hour PM2.5 NAAQS during the development of the Plan. There were thus no 24-hour episodes 

suitable for speciated rollback in the receptor modeling approaches and little need to focus on the 

24-hour standard for the photochemical modeling, although 24-hour modeling was performed. 

EPA believes that the conceptual description of the PM2.5 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 formalize the procedures for conducting all phases 

of the modeling study, such as describing the background and objectives for the study, creating a 

schedule and organizational structure for the study, developing the input data, conducting model 

performance evaluations, interpreting modeling results, describing procedures for using the 

model to demonstrate whether proposed strategies are sufficient to attain the NAAQS, and 

 similar to those covered in the Plan sections listed above, although it is based on analysis of data collected during an 

earlier study, the 1995 Integrated Monitoring Study (or IMS95). 
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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 communication 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 quality, meteorological, and emissions models 

b. Modeling domain 

c. Horizontal and vertical 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 application 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 testing 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 weight 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 PM2.5 Plan’s modeling protocol is contained in Appendix F, with descriptions of 

both the receptor modeling approaches and the photochemical modeling. Many aspects of the 

photochemical modeling that are suitable for inclusion in a protocol are also covered in 

Appendix G and the “Regional Model Performance Analysis” appendix. 

The protocol covers all of the above topics, with the exception of identification of how 

modeling and other analyses will be archived. In the Plan there is no discussion of this topic, nor 

any description of how modeling data files may be accessed, should EPA or other interested 
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parties wish to replicate the results 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 for it to be a candidate for consideration in 

an attainment demonstration. Guidance, p.136. These general criteria are 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 demonstrations. At present, there is no single model which 

has been extensively tested and shown to be clearly superior to its alternatives. Thus, 40 CFR 

Part 51 Appendix W does not identify a preferred model for use in attainment demonstrations of 

the PM2.5 NAAQS. Based on the language in Appendix W, models used for these purposes 

should meet requirements in the Appendix for alternative models. 

States should use a non-proprietary model, that is, a model whose source code is 

available for free (or for a reasonable cost) and whose code can be revised by the state in order to 

perform diagnostic analyses and/or to improve the model’s ability to describe observations in a 

credible manner. A model should meet several additional prerequisites before being used to 

support an attainment demonstration. It should be: 

1. revised in response to a scientific peer review, 

2. appropriate for the specific application on a theoretical basis, 

3. used with a data base which is adequate 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 with a protocol on methods and procedures. 

2008 PM2.5 Plan’s model selection is discussed at p. F-80 and p. G-2, with the 

Community Multiscale Air Quality (CMAQ) model selected. CMAQ is a “state-of-the-science 

[model that]... has been extensively peer-reviewed, is well-documented, and ... has been applied 

successfully in a range of environments.” The Plan mentions certain California-specific updates 

to the model, but these are not described other than via a citation. However, the Californiaspecific updates are described in CARB modeling supplement, section 3.2, p.17. 

The California-specific updates included: 1) fixing a model bug involving overly large 

fine PM deposition velocities that caused negative concentrations, 2) accommodation of hourly 

average emissions instead of the CMAQS default instantaneous assumption, 3) incorporation of 

a time-varying fine PM size distribution, 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 stagnation in California’s Central Valley, 6) a cap on 

ionic strength used in activity coefficient calculations for the aqueous phase oxidation of 

(bi)sulfate, 7) the addition of dimethyl sulfide (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 recent 
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decades). For each of these changes, a brief description and rationale is presented; the changes 

appear to have a reasonable basis, and to have 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 models considered. EPA, however, 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 PM2.5 Plan’s chemical mechanism selection is also discussed at p. F-80 and p. G-2, 

with SAPRC-99 selected for the gas phase mechanism, 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 mechanisms considered. EPA, however, believes 

that the use of SAPRC is adequately justified because SAPRC is a well-known and widely-used 

mechanism. 

d. Episode Selection 

We recommend one of two possible approaches for the modeling the 24-hour PM2.5

NAAQS (Guidance, p. 147): 

1) Model every day for a full year (or multiple years). This is recommended for both 

dispersion modeling of primary PM2.5 components and photochemical modeling of 

secondary and primary components. Many areas that violate the 24-hour PM2.5

NAAQS will also violate the annual PM2.5 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 PM2.5 concentrations occur. Similar to modeling for the 

ozone NAAQS, episodes should be selected where PM2.5 concentrations are greater 

than the NAAQS (in this case, the 1997 standard of 65 μg/m3

) 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 

PM2.5 concentrations. In some cases, there may be very limited conditions which 

lead to high 24-hour average PM2.5 concentrations, and in other cases there may be a 

wide variety of cases. The specific situation in each nonattainment area will 

determine the number of episodes and the time periods which need to be modeled. 

For example, if exceedance-level PM2.5 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 PM2.5 Plan’s episode selection is not discussed, instead a full year of modeling was 

performed. As mentioned above, there was little need to focus on the 24-hour standard 

attainment since ambient concentrations were already consistent with attainment of the NAAQS 

at the time the Plan was developed. Therefore there was no selection of particular periods or 

episodes of interest for the 24-hour NAAQS, although 24-hour modeling was in fact performed. 
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EPA believes this is marginally adequate. Since nonattainment of the annual standard in 

the SJV is known to be driven by frequent particular episodes in winter, it would have been 

preferable to choose and examine these 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 demonstration, the design value already attaining the 24-hour standard would 

have been scaled by a modeled RRF that reflects emissions reductions, and so the predicted 24-

hour PM2.5 design value would also have 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 PM2.5 problem and 

the scale of the emissions which impact the nonattainment area. Isolated nonattainment areas that 

are not affected by regional transport of PM and its precursors may be able to use a relatively 

small domain. Some areas of the western U.S. may fall into this category. The modeling domain 

should be designed so that all major upwind source areas that influence the downwind 

nonattainment area are included in the modeling 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 implementing 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 cell 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 expect that modeling analyses for nonattainment 

areas will use grid cell sizes of 12 km or less. If a regional scale model is applied, most of the 

domain will likely cover rural/remote areas or locations 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 vertical layers needed in an attainment 

demonstration. The vertical resolution will vary depending on the application. Greater resolution 

allows more precise estimation of mixing heights and avoids unrealistic 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 applications 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 Planetary Boundary Layer 

(PBL). Guidance p. 159. 
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2008 PM2.5 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 uses a nested grid, with the inner domain 

containing the entire District and nonattainment area. The inner domain has a 4 km grid 

resolution and measures 320 by 356 km (80 by 89 grid cells). This inner domain 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 and southern California in the east, and from the 

Tehachapi Mountains in the south to the Sacramento 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 PM2.5 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 rationale 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 nonattainment area and all counties exceeding the PM2.5

NAAQS being located in the southern end of the San Joaquin Valley, well away from the 
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northern boundary. In addition, this inner domain is nested within an outer 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 specify initial and boundary concentrations for the 

attainment demonstration modeling. However, concentration fields derived from a larger domain 

regional or global chemistry model (i.e., the nesting approach) is considered more credible than 

the assumption of static concentrations, since the pollutant concentration fields reflect simulated 

atmospheric chemical and physical processes driven by assimilated meteorological observations. 

Therefore, EPA recommends using boundary conditions derived from a regional or global scale 

model, whenever possible. We also recommend using a ramp-up period by beginning a 

simulation prior to the period of interest to diminish the importance of initial conditions. The 

recommended ramp-up period is at least 5-10 days for PM2.5. Diagnostic testing which indicates 

a large impact on the model results from initial 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 boundary 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 from the 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 model simulation minimized the effect of uncertain 

initial conditions on the modeling. Page F-73 in the 2008 PM2.5 Plan has a table of annual 

average boundary conditions for the various chemical 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 conditions 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 procedure, and the ramp-up period appears adequate. 

g. Meteorological Model 

i. Meteorological Model Selection

A description of the methods used to generate the meteorological fields should be 

included in the modeling protocol. In cases in which standard meteorological modeling (e.g. 

MM5, RAMS, or WRF in a retrospective analysis mode) is not used, EPA recommends that a 

detailed description of the technique that will be used to generate the three-dimensional 

meteorological fields be shared with the appropriate EPA regional office(s) prior to conducting 

the air quality modeling analysis. Guidance, p. 161. 

2008 PM2.5 Plan’s meteorological model selection is discussed at p. F-81 and p. G-4, with 

MM5 selected. While there is no discussion of alternative meteorological models, since MM5 is 
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well-known and widely used and explicitly mentioned 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 upwind areas that can reasonably be expected to 

influence local concentrations of PM2.5. 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 boundary effects. For example, if 4 km grid cells are to be used in 

the fine portion of a nested regional air quality model, then the meteorological fields at this detail 

would need to extend 12-24 km beyond the bounds of the 4 km grid used for air quality 

predictions. In terms of grid resolution, EPA recommends that 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 feasible. 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 than meteorologically-driven and the costs do not 

warrant the generation of additional resolution in the meteorological data. In these specific 

situations it is recommended that the air quality 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 meteorological fields can be mapped to the more 

finely resolved air quality modeling domain. 

iii. Physics Options

Most meteorological models have a suite of physics 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 cumulus parameterization. In many situations, the 

optimal configuration cannot be determined without performing an initial series of sensitivity 

tests which consider various combinations of physics options over specific time periods and 

regions. While these tests may not ultimately conclude that any one configuration is clearly 

superior at all times and in all areas, it is recommended that these sensitivity tests be completed, 

as they should lead to a modeling analysis that is best-suited for the domain and period being 

simulated. Typically, the model configuration which yields predictions that 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 qualitative information can also be considered. 

Additionally, model configurations should be designed to account for the pollutants and time 

periods that are of most interest. As an example, a wintertime PM simulation in the Midwest 

(with high measured nitrate concentrations) may need a meteorological model configuration that 

employs a land-surface model that properly handles snow covered fields and their effects on 

boundary layer humidities and temperatures. 

2008 PM2.5 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 plus a month at either end), using 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 innermost 
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domain in the two figures does not match; the one on the map in Appendix G appears to be 

incorrect since it is square, whereas the horizontal dimensions are stated to be 94x85 grid cells in 

both appendices.) 

The meteorological model used 30 vertical layers, 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 resolve 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 meteorological model rather than the air quality model.) The 

MMPA goes on to state “Many sensitivity studies were conducted using various model options 

to gain better agreement with observations.” The optimal configuration included various physics 

options listed, e.g., Grell cumulus parameterization, Blackadar boundary layer scheme, Dudhia 

ice scheme, Dudhia cloud radiation scheme, and 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 PM2.5 Plan “Meteorological Model Performance Analysis,” p. 2. 
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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 substantial 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 model 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 occurred 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 predictions in order to allow for a downstream assessment of how 

the air quality modeling results are affected by issues associated with the meteorological data. 

This evaluation can be done via a more phenomenological 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 operational 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 statistical comparisons of the key meteorological 

parameters will include: comparisons of the means, mean bias, mean normalized bias, mean 

absolute error, mean absolute normalized error, root mean square error (systematic and 

unsystematic), and an index of agreement. For modeling exercises over large domains and entire 

seasons or years, it is recommended that the operational evaluation be broken down into 

individual segments such as geographic sub-regions and/or months/seasons to allow for a more 

comprehensive assessment of the meteorological strengths and weaknesses. 

Phenomenological Evaluation (Guidance, p. 167): Within the conceptual description of a 

particular modeling exercise, EPA recommends that 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 pollution formation and transport within the scope of a specific 

analysis. It is expected that this event-oriented 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 transport of emissions from one area to a downwind 

area with an intent to establish source-receptor relationships. For these types of modeling 

analyses, accurate transport wind trajectories are needed to properly establish these sourcereceptor linkages. In this type of model application, a useful event-based meteorological 

evaluation would be to compare model-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 Analysis” (MMPA). In addition, CARB modeling 
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supplement includes a phenomenological model 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 temperature, relative humidity, and wind components for each 

meteorological station, and also accumulated precipitation for some stations. Appendix B has 

some of the material that is in the “Meteorological Model Performance Analysis” in the Plan, but 

also many histograms showing occurrence frequency of simulated and observed wind speeds, 

temperature, and relative humidity for each month, 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 grid cell of the modeling domain. There is an 

operational evaluation using three methods for temperature, relative humidity, and horizontal 

wind components for the full year and by season. 

Evaluation Method 1 considers mean and standard deviation, correlation, root mean 

square error, mean bias, and index of agreement; this information is stated to be in Attachment 

A, which is not provided. Results are stated (MMPA 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 alternate months. This information is stated to 

be in Attachment B, which is not provided. The 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 hourly comparisons for wind speed, direction, 

and temperature over two five-day periods within each modeled month. This information is 

stated to be in Attachment C, which is not provided, 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 direction and temperature variations reasonably 

well,” despite the fact that “the estimates for the evolution of the wind speed and direction differ 

somewhat. However, the examination of all figures 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 performance, including an assessment of seasonal 

variation. It describes some the meteorological and topographic factors leading to high pollutant 

concentrations. It also describes some alternate MM5 model configurations that were evaluated, 

including analysis nudging 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 simulation of a one-week period; no one configuration was 

found to be superior to the others. The seasonal assessment evaluated 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 assessment concludes that sea breezes and slope flows 

are replicated well, although less so for the Sacramento delta region; wind speeds tended to be a 
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bit larger than observed, but acceptable; temperature gradients tended to be a bit smaller than 

observed; and overall flow patterns were replicated well. 

The overall conclusion in the Plan is that the MM5 simulations “reproduce the overall 

statistical characteristics of observed meteorological conditions”. There is some underestimate of 

maximum surface temperature, although the model is able to capture the large temperature 

variations that occur in some periods. 

EPA believes the meteorological model performance 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, rather than just overall annual 

statistics. The phenomenological evaluation also is adequate, with assessment. of how well 

phenomena important to PM2.5 formation in the SJV are adequately captured in the 

meteorological modeling, including for various locations and times of year. 

i. Emissions Inventory 

Air quality modeling requires emissions inputs for base case, baseline, and future 

modeling years. Preparation of emissions data for air quality models for the 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 anthropogenic and biogenic VOC (speciated), NOx, 

carbon monoxide, SO2, NH3, PM2.5 (speciated), and PM coarse (PMC). Second, modelers must 

collect ancillary data associated with the inventories, which prescribes the spatial, temporal, and 

chemical speciation information about the emissions inventory. Third, modelers use the ancillary 

data for emissions modeling. Emissions models spatially, temporally, chemically, and vertically 

allocate emissions inventories to the resolution needed by air quality model. 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, and then use an emissions model to prepare that 

future year inventory data for input to the air quality model. Fifth, emissions inventories that 

reflect the emissions reductions needed for attainment will have to be prepared for air quality 

modeling. 

2008 PM2.5 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 sources was generated using the California 

Emissions Forecasting System (CEFS) version 1.06 with offline adjustments. The 

inventory includes emissions estimates for gaseous and particulate species of 

anthropogenic and biogenic origin. Gridded hourly emissions were developed for 

the CMAQ modeling domain for the years 2000, 2005, and 2014 (baseline). 

The Plan does not include a discussion 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 distribution were performed at various steps.” 

There are no tables of modeling emissions totals for various pollutants, source groupings, 

subareas, or seasons. There are no maps of emission density or diurnal time series of emissions, 
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which could illustrate the spatial and temporal allocation, and help in understanding PM2.5

concentration variations over space and time. 

EPA believes the modeling emissions inventory preparation procedures were adequate 

but sparsely documented (the preceding excerpts are essentially the full description in the Plan). 

It is apparent that substantial effort 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 

PM2.5 consists of many components and is typically measured with a 24-hour averaging 

time. The individual components of PM2.5 should be evaluated individually. In fact, it is more 

important to evaluate the components of PM2.5 than to evaluate total PM2.5 itself. Apparent good 

performance for total PM2.5 does not indicate whether modeled PM2.5 is predicted for the right 

reasons (the proper mix of components). If performance of the major components is good, then 

performance for total PM2.5 should also be good. EPA recommends calculating statistics for 

components of PM2.5, and PM precursors. Useful metrics include mean fractional bias and mean 

fractional error, normalized mean bias, and normalized 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, correlation coefficients, etc. should also be calculated 

to the extent that they provide meaningful information. Since modeling for the PM2.5 NAAQS 

will likely require modeling different times of year, season-specific statistics and graphic 

displays are helpful for evaluating and diagnosing model performance. Statistics and graphics 

can be averaged for various time scales. For example, statistical metrics and scatter plots can 

show daily averaged ambient modeled pairs, monthly 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 different averaging times for annual or seasonal 

modeling. At a minimum, a state should examine daily averaged pairs and seasonal (or quarterly) 

averaged pairs. Because statistics and plots tend to look better as the averaging time increases 

from daily to monthly to quarterly to annual, daily pairs should always 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 convenient way to display a summary of model 

performance (including bias and error at the same time). Bugle plots12 have variable bias and 

error goals, based on ambient concentrations. This allows for a higher percentage error and bias 

at very low concentrations. This recognizes the fact that models often have difficulty in 

accurately predicting near background concentrations 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/m3

 for 1997 24-hour PM2.5). 

2008 PM2.5 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) contains 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 relatively slowly with concentration, 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. 
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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 extensive 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, that the study involved 

intensive metrological and air quality measurements, including measurements taken on towers 

and in aircraft and created a wealth of data useful for developing and evaluating model 

applications. 

The Plan contains no speciated 24-hour PM2.5 data. It contains only 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 PM2.5

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 PM2.5 and four quarterly averages. Each of these has seven plots, one 

each for total PM2.5, nitrate, sulfate, ammonium, organic carbon, elemental carbon, and dust. (An 

example is included below and shows fourth quarter total PM2.5.) A paragraph on RMPA p. 6 

summarizes the plots, noting that nitrate formation follows the pattern expected from seasonal 

temperature and humidity, although third quarter nitrates appear too high. Sulfates are low for all 

quarters, while organic carbon (OC) and elemental carbon (EC) are higher in the first and fourth 

quarters, presumably due to enhanced wood burning during these periods. There is no discussion 

of the spatial variation of PM2.5 or its components and how it compares to expectations or to 

monitored values. 
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Fourth Quarter Average Concentrations for PM2.5

Source: 2008 PM2.5 Plan Appendix “Regional Model Performance Analysis,” Figure 7, p.11. 

Next the RMPA at pp. 12 - 14 discusses statistics for Mean Fractional Error (MFE) and 

Mean Fractional Bias (MFB), which are shown in the form of bugle plots. Each plot is for annual 

average PM2.5 total or a component, and shows MFE or MFB plotted against concentration. 

CARB modeling supplement (pp. 24 – 31) shows additional bugle plots, for each calendar 

quarter and each chemical species component of PM2.5 performance criteria were set at MFE ≤

75 percent and |MFB| ≤ 60 percent. The RMPA notes 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 protocol, at p. F-62, such as Mean Normalized Gross 

Error, but no values are presented. 
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Finally, time series plots are examined at RMPA pp. 14-16. Bakersfield and Fresno 

concentrations of PM2.5 total and components are plotted against 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 series plots showing all days of 

the simulation, for each of the 35 monitors, for each chemical species component of PM2.5; it 

also has combined bar & line graphs of the monthly average species components (pp. 66 - 99). 

The RMPA notes that the over-predicted of nitrate in the third quarter is apparent, as is the 

overestimation of dust. The CARB modeling supplement states that the cause of this is overestimation of specific humidity in the meteorological model in the summer (p. 23) EPA 

examination of the plots also suggests that many PM2.5 days are missed at both Bakersfield and 

Fresno, that organic carbon is under predicted (especially at Fresno), and that ammonium is 

under predicted. Sulfate is also often under predicted, but sulfate’s contribution to PM2.5 levels in 

the Valley is small. Since the plots show the entire year, it is hard to judge performance during 

particular months or seasons. 

No tables of numbers calculated for the performance statistics are presented, but the 

many bugle graphs give an excellent idea of performance for Mean Fractional Error and Mean 

Fractional Bias, including comparison to performance goals. 

Sensitivity, or diagnostic testing of the model, can check whether it responds to input 

changes in a physically reasonable way, whether alternative input assumptions could have 

improved model performance, and whether the predictions are subject to compensating errors in 

the inputs. These are discussed only briefly, in the CARB modeling supplement, p. 23, which 

mentions numerous simulations performed to assure the credibility of the simulation; these 

included changing boundary and initial conditions, varying lengths of time for 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 PM2.5 concentration and no 

assessment of spatial variation of model performance, but it is apparent that substantial effort 

went into evaluating the reasonableness of the simulation. 

EPA believes the air quality model performance is adequate, and adequately documented, 

though additional qualitative description 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 quality model is used to simulate 

current and future air quality. If future estimates PM2.5 concentrations are less than the NAAQS, 

then this element of the attainment test is satisfied. 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) predictions at monitors. We call these ratios, relative 

response factors, RRF. Future PM2.5 concentrations are estimated at existing monitoring sites by 

multiplying a modeled relative response factor at locations near each monitor by the observationbased, monitor-specific, baseline design value. The resulting predicted future concentrations are 

compared to NAAQS. 

The PM2.5 attainment test reflects the fact that PM2.5 is a mixture. In the test, ambient 

PM2.5 is divided into major species components, so EPA’s test is called the Speciated Modeled 

Attainment Test (SMAT). These are mass associated with sulfates, nitrates, ammonium, organic 
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carbon, elemental carbon, particle bound water, other primary inorganic particulate matter, and 

passively collected mass. Note that FRM monitors do not measure the same components and do 

not retain all of the PM2.5 that is measured by routine speciation samplers and therefore cannot be 

directly compared to speciation measurements from the STN. By design, the FRM mass 

measurement does not retain all ammonium nitrate and other semi-volatile materials (negative 

sampling artifacts) and includes particle bound water associated with sulfates, nitrates and other 

hygroscopic species (positive sampling artifacts). This results in concentrations (and percent 

contributions to PM2.5 mass) which may be different than the ambient levels of some PM2.5

chemical constituents. Therefore we recommend a SMAT technique which uses an FRM mass 

construction methodology which results in reduced nitrates (relative to the amount measured by 

routine speciation networks), higher 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 PM2.5 and its non-organic carbon components. 

This approach is sometimes called SANDWICH, for sulfate, adjusted nitrate, derived water, 

inferred carbonaceous material balance approach. Guidance, p. 47. 

A separate RRF is calculated for each of the PM2.5 components (except passive mass). 

We call each of these site-specific ratios, a component-specific RRF. Future PM2.5 design values 

are estimated at existing monitoring sites by multiplying modeled relative response factors near 

each monitor times the observed component specific design value. This latter quantity is 

estimated using measured site-specific design values for PM2.5 in concert with available 

measured composition data. Future site-specific PM2.5 design values at a site are estimated by 

adding the future year values of the seven PM2.5 components. If all future site-specific PM2.5

design values are less than or equal to the concentration specified in the NAAQS, the test is 

passed. Guidance, pp. 15-16. 

2008 PM2.5 Plan’s annual PM2.5 NAAQS attainment test is discussed in Chapter 3, pp. 3-

20 and 2-33, and in Appendix G on “Regional Air Quality Modeling”. Sections 4 and 5 of the 

CARB modeling supplement provides additional information on SMAT and on the development 

of the RRFs. 

A variation on EPA’s SMAT approach is used, to account for the SJV’s abundance of 

ammonia and the dominance of ammonium nitrate over ammonium sulfate. This variation is to 

assume that ammonium on the monitor filter is the measured STN NH4 minus any losses 

associated with fully neutralized nitrate (as NH4NO3) that may have volatilized off the FRM 

filter. 2008 PM2.5 Plan, p. G-10. Sections 4 and 5 of the CARB modeling supplement (pp. 100 – 

103) provide additional justification for the approach, with graphical 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 controls are shown in Chapter 3, Table 3-3 (p. 3-23) and Appendix 

G, Table 3 (p. G-21) of the 2008 PM2.5 Plan. The 2014 controlled design value is seen to be less 

than the annual NAAQS level of 15 μg/m3

 for every monitor, thus demonstrating attainment. 

The highest 2014 value is 14.7 μg/m3 at the Bakersfield Planz Road monitor. The RRFs, and 

details of their calculation are presented in section 5 of the CARB modeling supplement, pp. 103 

- 104, and RRF tables at pp. 104 -115. 

2008 PM2.5 Plan’s 24-hour PM2.5 NAAQS attainment test is discussed in the same place 

as the attainment test for the annual standard, with results in Appendix G, Table 4, p. G-22. 
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Appendix G, Table 4 shows the 2006 design values for Bakersfield and Fresno monitors 

and the projected 2014 design values for the controlled case. Since the 2006 design values are 

already below the 1997 24-hr NAAQS level of 65 μg/m3

, the controlled values are, too. The 

highest 2014 value is 46.2 μg/m3

 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 PM2.5 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 the CARB modeling supplement shows the 

approach is reasonable for the ammonium ion. The RRFs are presented for each monitoring 

station and calendar quarter. EPA believes the attainment demonstration is adequately 

documented, and that it projects attainment by 2014 for both the annual and 24-hour PM2.5

NAAQS. 

l. Unmonitored Area Analysis 

In addition to a modeled attainment demonstration, EPA recommends use of an 

unmonitored area analysis. This type of analysis is intended to ensure that a control strategy 

leads to reductions in ozone or PM2.5 at other locations which could have baseline (and future) 

design values exceeding the NAAQS were 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 potential problems within or near that nonattainment 

area. The analysis should include, at a minimum, all nonattainment counties and counties 

surrounding the nonattainment area (located 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 created for the base year. Future year estimates 

can then be created by applying gridded RRFs to the gradient adjusted 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 predicted to exceed the NAAQS in the future. 

2008 PM2.5 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 contour plot (Figure 3 on p. 

G-20), and the observation that “there are no areas with steep gradients that would result in 

higher design values than those measured at monitors”. 

In addition, section 6 of the CARB modeling supplement (pp. 139 - 182) contains an 

Unmonitored Area Analysis in the sense of the EPA Guidance, using EPA’s Model Attainment 

Test Software (MATS). It includes spatial contour plots of quarterly and annual average 
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concentrations for simulated PM2.5 components for the 2005 base year (pp. 141 - 147), and 

comparable plots for the 2014 attainment year, including concentrations adjusted by the gridded 

model output gradients from MATS. CARB examined locations where the gradient implied high 

values. In one case, Modesto 14th Street, the location already had a monitor, and modeled results 

there, and so did not strictly speaking need to pass the test. MATS and direct modeled results for 

the Bakersfield area appear to match, so CARB believes MATS results are reliable for that area, 

and MATS did not predict any unmonitored violation. 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 unmonitored location west of Fresno by that amount led CARB to believe 

that this area, too, will not have an unmonitored PM2.5 NAAQS violation. 

EPA believes that CARB has shown that SJV successfully passes the test in the 

Unmonitored Area Analysis. 

m. Weight of Evidence 

States should perform complementary analyses 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 modeled results which may be inconclusive. The further 

the attainment test is from being passed, the more compelling contrary evidence produced by 

corroboratory analyses must be to draw a conclusion differing from that implied by the modeled 

attainment test results. Guidance, p. 17. Supplemental 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 grid cells above the NAAQS), trends 

in ambient air quality, trends in emissions, receptor modeling, and indicator species approaches. 

2008 PM2.5 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 modeling, the Plan emphasizes a 

receptor modeling-based approach for the attainment demonstration, with photochemical 

modeling added later. However, EPA views the receptor modeling mainly as a supplemental 

analysis to corroborate the photochemical modeling as part of the weight of evidence 

determination. 

Chapter 3 describes three variants of a speciated rollback approach (p. 3-23). Method 1 is 

based on Chemical Mass Balance (CMB) modeling of PM10 speciated measurements from the 

year 2000; this was converted to 2005 PM2.5 values, which are in turn projected to 2014, with 

some adjustments described below. This method 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 Kern monitors only. The third method is based 

on a Positive Matrix Factorization (PMF) using speciated data from the years 2003-2006. This 

method is applied to the Fresno and Kern monitors only. Thus Fresno and Kern County monitors 

have all three methods applied, Kings and Tulare Counties have only Method 1 applied. 
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Table B-1 

Guidelines For Weight of Evidence Determinations

Results of Modeled Attainment 

Test Supplemental Analyses 

Annual PM2.5 24-Hour PM2.5

Future Design 

Value < 14.5 

μg/m3

, all monitor 

sites 

Future Design 

Value < 62 μg/m3

, 

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/m3

, at one or 

more sites/grid 

cells 

Future Design 

Value 62-67 

μg/m3, at one or 

more sites/grid 

cells 

A weight of evidence demonstration should be 

conducted to determine if aggregate 

supplemental analyses support the modeled 

attainment test 

Future Design 

Value > 15.5 

μg/m3

, at one or 

more sites/grid 

cells 

Future Design 

Value > 68 μg/m3

, 

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 projection to 2014 (and in 

some cases intermediate years). The adjustments included consideration of the emissions 

inventory in order to attribute PM2.5 in a more refined way than the CMB and PMF approaches 

could by themselves, as the latter cannot always distinguish between different 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 monitor 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 followed, other than a diagram and formula at 

RMD, p. 79, though the meaning of this diagram and formula is not clear. Another adjustment 

involved modeled sensitivity factors from CMAQ nitrate modeling (and linear nitrate projection 

and IMS95 modeling”) were used to estimate the response of the atmosphere to changes in NOx

emissions. This was an attempt to address the inability of straight speciated rollback to handle 

secondary particulates, as they are not directly associated with emitted species from sources. It is 

not clear exactly to which modeling exercises these refer. In addition there is discussion of 

variations on SMAT (p. 3-21), involving “approved alternate linear assumptions” on trapped 

water bonded to ammonium nitrate and ammonium sulfate and other 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 documentation on the spreadsheet and its formulas. The results from all these 

adjustments are in Table 3-2, p. 3-22, which lists for each county the 2005 design value, 
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“Receptor Modeled SMAT RRF 2005-2014” based on the methods just described, and a 

projected 2014 design value. For all counties the value is less than 15 μg/m3

 the level of the 

annual NAAQS. The highest 2014 value is 14.09 μg/m3, for Kern County based on the PMF 

method. 

EPA believes that the ideas used to refine the receptor modeling results are reasonable 

ways to address shortcomings of receptor modeling, especially for an area for which secondary 

particulates are so important. The results do support the attainment demonstration, and it is 

apparent that substantial thought and effort went into applying the methods. However, 

documentation for the approaches used is confusing, 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 regression trend test (p. H-5) and time 

series plots (p. H-6 and p. H-10), all showing a downward trend in 24-hour and annual PM2.5

concentrations. Monthly time series (pp. H-7 – H-8) comparing 2001 to 2006 for Bakersfield and 

Fresno show substantial decline in PM2.5 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 concentrations. This decrease is clearest for Fresno, which also 

shows increased occurrence of low concentrations. (Mid-range concentrations, between 15 and 

40 μg/m3 are more of a mixed picture.) Species and total PM2.5 trends (pp. H-14 – H-15) also 

show declines over 2001-2006, principally in carbonaceous 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 NOx and for reactive organic gases. 

An indicator species analysis plots the Angiola and Fresno winter 2000-2001 

concentrations of NH3 (ammonia) against that of HNO3 (nitric acid). It is the combination of 

these two that forms ammonium nitrate PM2.5. Ammonia concentrations are almost always far 

higher than those of nitric acid, and also vary over a much larger range than nitric acid. This is 

evidence that nitric acid is the limiting precursor, with some implications for the advisability of 

controls of NOx 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 the demonstration of attainment. 

3. Conclusions

The 2008 PM2.5 Plan with the CARB modeling supplement adequately document all the 

elements of a modeled attainment demonstration. Significant time, money, and effort by CARB, 

the District, and many others have gone into preparing the air quality modeling to support the 

attainment demonstration in SJV PM2.5 plan for the San Joaquin Valley, including the multi-
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million dollar CRPAQS study. EPA believes that the modeling is sound and provides an 

adequate basis for the reasonably available control measures, reasonable further progress, and 

attainment demonstrations in the Plan. 

4. Pollutant Ratios Used to Determine PM2.5 Equivalency

The 2011 Progress Report and the SJV PM2.5 Progress Report use a PM2.5 equivalency 

metric in a number of tables and demonstrations. Two ratios are used: 

• 9 tpd NOx to 1 tpd direct PM2.5

• 1 tpd SOx to 1 tpd direct PM2.5

The NOx:PM2.5 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 additional 10 percent reduction in modeling domain NOx 

emissions and in direct PM2.5 emissions. These PM2.5 effects were divided by the (unstated) 

emissions totals for each pollutant, to give a concentration per emissions change, or effectiveness 

for each pollutant, and finally the direct PM2.5 effectiveness was divided by the NOx

effectiveness to arrive at a NOx:PM2.5 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 estimate interpollutant equivalency ratios rests on 

the faulty assumption that ambient sensitivity to emissions reductions of a given precursor can be 

estimated as the ratio of concentration to emissions. This is the assumption of linear “rollback”, 

and inherently cannot address the complexities of PM2.5 formation chemistry, which is nonlinear. 

It is in contrast to the State’s approach for the NOx: PM2.5 ratio which used photochemical 

modeling results to take into account such nonlinearity. Even if the ambient PM2.5 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 connecting the curve's end points.) 

 13 EPA is proposing to approve the use of this NOx to PM2.5 interpollutant trading ratio to meet CAA 

planning requirements for the 1997 PM2.5 standards in the SJV. EPA is also proposing to approve the use of this 

ratio in transportation conformity determinations for the 2006 24-hour PM2.5 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 District’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 PM2.5 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 that the District intends to 

submit SJV-specific PM2.5 interpollutant trading ratios for EPA’s approval in a future SIP revision but will, in the 

interim, require project proponents to use the default ratios provided in the preamble to EPA’s PM2.5 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. 
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Ambient concentration might be very responsive initially and less responsive with greater 

reductions, or vice versa; both would appear as the same responsiveness under the faulty linear 

rollback assumption. 

Some strengths of the District's methodology are that it attempts to account for multiple 

monitors, the portion of each monitor's ambient concentration 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 the highest emissions and 

concentrations. See Ratio Documentation p.1; Ratio spreadsheet; 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 particular 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. Finally, 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 receptor modeling approach, but they 

cannot compensate for the faulty underlying assumption discussed above. 

Two other potential problems in the approach are worth noting. First, the sensitivity to 

direct PM2.5 emissions is based on organic carbon (OC), partly because OC is the main pollutant 

for which interpollutant offsets are sought in the 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 equivalency for air quality planning purposes including 

contingency measures, and whether the sensitivity to other types of direct PM2.5 emissions would 

result in different ratios. Second, it is not clear what emission level to use in the concentration 

per emissions sensitivity ratio. For SOx, the District uses 2.97 tpy, the average of the 1.337 and 

4.598 tpy for the “12-Ke” and “Kern” areas of influence, respectively. See ratio spreadsheet. The 

average may be reasonable to use within the confines 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 interpollutant 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 PM2.5 to emissions changes. 

EPA does not believe that the approach used by CARB and the District is adequate for 

determining interpollutant equivalency ratios. This issue would 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 inventories 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). 
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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 decreases in the base year 2005 emissions inventory 

due to the inventory updates are about 6 percent for NOx and 5 percent for direct PM2.5

emissions; the 2014 attainment year target emissions levels are unchanged. See Table B-2. 

Emissions decreases in the base year tend to reduce the relative effect of controls and increase 

the projected PM2.5 concentrations in the attainment year. We now know that base year 

emissions estimates were slightly too high, yet the 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 tendency to predict slightly lower concentrations 

than it should. To compensate for this model under-prediction, the predicted 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 emission inventory revisions, and predicted design 

values still attain the NAAQS. See Table B-4. EPA therefore concludes that the attainment 

demonstration remains valid, despite the emission inventory changes. 

Table B-2 

Changes to Base Year and Attainment Year Emissions Levels 

(tons per annual average day) 

 

2005 Base Year 2014 Attainment Year 

NOx

Direct 

PM2.5

NOx

Direct 

PM2.5

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 PM2.5 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 PM2.5 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. 
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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

NOx

Direct 

PM2.5

NOx

Direct 

PM2.5

NOx

Direct 

PM2.5

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 Value 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 PM2.5; the measured base year concentration was caused by emissions being lower than 

previously thought; effect is to make it harder to attain. 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 target year, but no effect in this case since target 

emissions are unchanged. 
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C. PM2.5 Attainment Plan Precursors 

1. Requirements for the Control of PM2.5 Precursors

EPA recognizes NOx, SO2, VOC, and ammonia as the main precursor gases associated 

with the formation of secondary PM2.5 in the ambient air. These gas-phase precursors undergo 

chemical reactions in the atmosphere to form secondary particulate matter. Formation of 

secondary PM2.5 depends on numerous factors including the concentrations of precursors; the 

concentrations of other gaseous reactive species; atmospheric conditions including solar 

radiation, temperature, and relative humidity; and the interactions of precursors with preexisting 

particles and with cloud or fog droplets. 72 FR 20586 at 20589. 

As discussed previously, states must include submit emissions inventories for each of the 

four PM2.5 precursor gases in order to assure the information on all pollutants and precursors that 

contribute to PM2.5 concentrations is available. 72 FR 20586 at 20589 and 40 CFR § 

51.1008(a)(1). However, the overall contribution of different precursors to PM2.5 formation, and 

the effectiveness of alternative potential control measures will vary by location. Thus the 

precursors a state should regulate for attaining the PM2.5 NAAQS will also vary to some extent 

from area to area. 72 FR 20586 at 20589. 

In the PM2.5 implementation rule, EPA did not make a finding that all potential PM2.5

precursors must be controlled in each specific nonattainment area. See 72 FR 20586 at 20589. 

Instead, for reasons explained in the rule, a state must evaluate control measures for sources of 

SO2 in addition to sources of direct PM2.5 in all nonattainment areas. 40 CFR § 51.1002(c) and 

(c)(1). A state must also evaluate control measures for sources of NOx unless the state and/or 

EPA determine that control of NOx emissions would not significantly reduce PM2.5

concentrations in the specific nonattainment area. 40 CFR § 51.1002(c)(2). By contrast, EPA has 

determined in the PM2.5 implementation rule that states do not need to address controls for 

sources of VOC and ammonia unless the state and/or EPA make a technical demonstration that 

such controls would significantly contribute to reducing PM2.5 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 reduction in emissions of 

the precursor from sources in the area would be projected to provide a significant reduction in 

PM2.5 concentrations in the nonattainment area. 72 FR 20586 at 20590. Although EPA did not 

establish a quantitative test for determining the significance of such a change, EPA noted that 

even relatively small reductions in PM2.5 levels are estimated to result in worthwhile public 

health benefits. Id. 

EPA further explained that a technical demonstration to reverse the presumption for NOx, 

VOC, or NH3 in any area could consider the emissions inventory, speciation data, modeling 

information, or other special studies such as such as monitoring of additional compounds, 

receptor modeling, or special monitoring studies. 72 FR 20586 at 20596-20597. These factors 

could indicate that the emissions or ambient concentration contribution of a precursor, or the 

sensitivity of ambient concentrations to changes in precursor emissions, differs in the specific 

nonattainment area from the presumption for that precursor in the PM2.5 implementation rule. 
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2. Identification of PM2.5 Attainment Plan Precursors in the SJV 2008 PM2.5 Plan and 

EPA’s Evaluation

The 2008 PM2.5 Plan does not explicitly identify the pollutants that have been selected as 

PM2.5 attainment plan precursors as this term is defined in 40 CFR § 51.1000. The Plan addresses 

only NOx and SO2 in the RFP and attainment demonstrations and the District’s RACM/RACT 

analysis and thereby implicitly identifies NOx and SO2, but not VOC and ammonia, as attainment 

plan precursors. It does include supporting documentation for the inclusion of NOx as an 

attainment plan precursor and for the exclusion of ammonia. As discussed below, it has 

conflicting information about the impact of controlling VOC as a precursor for PM2.5 attainment. 

However, supplemental information provided by CARB makes clear that the State does not 

consider VOC to be a PM2.5 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?”, Chapter 7 “Local, State, and Federal Controls”, 

Chapter 8 “Reasonable Further Progress”, Appendix F “SJV PM2.5 SIP Modeling Protocol”, 

Appendix G “Regional Air Quality Modeling”, Appendix J “Comments and Responses”, and the 

additional appendix “2014 Receptor Modeling Documentation” (“RMD”). The most detailed 

discussion is in Appendix F, p. F-53ff, with the main points repeated in Chapter 3, p. 3-8ff. The 

RMD presents additional evidence regarding precursors. 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 the presumption for an attainment plan precursor 

should be reversed. The 2008 PM2.5 Plan contains numerous qualitative statements that San 

Joaquin Valley’s ambient PM2.5 is dominated by ammonium nitrate (NH4NO3), and that NOx

reductions are more effective at reducing ambient PM2.5 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 cited 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 PM2.5 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 website http://www.arb.ca.gov/airways”. 2008 PM2.5 Plan, p. 

F-59 

For the annual and 24-hour PM2.5 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 term 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 PM2.5

concentration could be attributed to a high PM2.5 period occurring from 
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November to January. At non-urban sites, the elevated PM2.5 was driven by 

secondary NH4NO3.

15

There is also quantitative data in Appendix 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 projected 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 Factorization (PMF) modeling results. Ammonium 

nitrate for 2000 monitored data ranges from 24-36 percent of total PM2.5, and if projected to 

2014 ranges from 36-51 percent, confirming the importance of NOx, one source of nitrate, as a 

precursor that significantly contributes to annual PM2.5 levels in the SJV. 

In addition to composition data, ambient sensitivity to emissions changes can also be a 

consideration in determining which species should be regulated in the SIP for an area as 

attainment plan precursors. For ammonium nitrate PM2.5, which is formed from both ammonia 

and NOx, a key issue is the effectiveness of emissions reductions of either or both precursors at 

reducing PM2.5 concentrations. Among the findings cited by the Plan that address this issue are: 

“Particulate NH4NO3 concentrations are limited by the rate of HNO3

formation, rather than by the availability of NH3” 

and 

“Comparisons of ammonia and nitric acid 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 NOx emissions will be more effective 

in reducing secondary ammonium nitrate aerosol concentrations than reductions 

in ammonia emissions. Reductions in VOC emissions will reduce secondary 

organic aerosol concentrations and may reduce ammonium nitrate.... The results 

indicate ammonium nitrate formation is ultimately controlled by NOx emission 

rates and the other species, including VOCs and background ozone, which control 

the rate of NOx oxidation in winter, rather than by ammonia emissions. 

2008 PM2.5 Plan p. 3-10. 

These findings are based on the relative amounts of ammonia and nitrate: there is so 

much ammonia present that even substantial reductions of ammonia emissions would still leave 

ample ammonia for forming ammonium nitrate. On the other hand, NOx is scarce (relative to 

ammonia), so reducing it will reduce ammonium nitrate significantly. 

Finally, sensitivity results from photochemical modeling were used in conjunction with 

the CMB results mentioned above, though it is not clear which particular modeling was used. 

The 2008 PM2.5 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. 
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The first regional assessment used the 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 monitored event of nitrate 

particulate formation. Regional modeling was also conducted for the later 2000-

2001 CRPAQS data, providing an update to the PM10 receptor modeling 

projections in 2006. A third round of regional modeling with the Community 

Multiscale Air Quality (CMAQ) model has 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 strategy effectiveness supported by CMAQ 

nitrate particulate evaluation” shows the projected result of a 50 percent reduction in NOx

emissions on the annual PM2.5 concentration and on PM2.5 concentrations in shorter episodes in 

several seasons. For the annual concentration, the NOx reduction gave a predicted 5 μg/m3 PM2.5

reduction, while for the winter episode the predicted reduction was 28 μg/m3

 for the 24-hour 

period RMD, p. 80. A similar evaluation is also done for to analyze the effect of a 50 percent 

reduction in ammonia emissions: the corresponding PM2.5 predicted reductions for annual and 

winter were only 0.1 μg/m3 and 0.3 μg/m3, respectively. See RMD, p. 81. When compared to the 

annual and 24-hour NAAQS of 15 and 65 μg/m3

, respectively, the effect of NOx reductions 

appear to be significant while the effect of ammonia reductions do not. Thus the data and 

modeling results presented in the 2008 PM2.5 Plan, as well as the results of the cited studies, 

support the identification of NOx as an attainment plan precursor, and the exclusion of ammonia, 

consistent with the EPA presumption in the PM2.5 implementation rule. 

As to VOC, EPA presumption in the PM2.5 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 may not be technically justified for a particular nonattainment 

area, i.e., this presumption may be incorrect where emissions of VOC significantly contribute to 

PM2.5 concentrations in the nonattainment area. 72 FR 20586 at 20590-93, 20596-97. States or 

EPA may conduct a technical demonstration to reverse the presumptive exclusion of VOC as a 

PM2.5 attainment plan precursor based on the weight of evidence of available technical and 

scientific information. Id. 

The 2008 PM2.5 Plan contains conflicting information on whether, for the SJV 

nonattainment area, VOC should be considered as a potential PM2.5 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 PM2.5. This organic PM2.5 can be 

further divided into vegetative burning (9-19 percent of total annual PM2.5), direct VOC PM2.5

emissions (also 9-19 percent of total annual PM2.5), and secondary organic aerosols (2-5 percent 

of total annual PM2.5). RMD, p. 19. This SOA contribution to overall PM2.5 levels appears to be 

non-negligible. 

The Plan states: “Secondary organic aerosols (SOA) contribute to a significant fraction of 

PM2.5. SOA is organic carbon particulate formed in the photochemical oxidation of 

anthropogenic and biogenic VOC precursor gases. Aromatic compounds are believed to be 

efficient SOA producers contributing to this secondary particulate.” 2008 PM2.5 Plan, p.3-8. On a 

24-hour episodic basis, the contribution of SOA could 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 decreased 
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photochemical activity when fog and clouds partially block sunlight. The chemistry of SOA is 

less well understood than the chemistry of other chemical species, so overall these considerations 

are not enough to overcome the negative presumption for VOC. 

But as noted in the preamble to the PM2.5 implementation rule at pp. 20592 - 20593, the 

lightest organic molecules can participate in atmospheric chemistry processes resulting in the 

formation of ozone and certain 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 PM2.5 precursor not just via formation of SOA, but also via its 

participation in the oxidant chemistry that leads to nitrate formation, a necessary step in the 

formation of ammonium nitrate PM2.5. NOx emissions must be oxidized to nitric acid (HNO3) 

before they form particulate ammonium nitrate. Two pathways for this to occur are 1) daytime 

oxidation by OH, which VOC radicals help create, and 2) nighttime oxidation by ozone, with 

N2O5 as an intermediary.16

The discussion in the 2008 PM2.5 Plan regarding ammonium nitrate (at p. 3-10, quoted 

above) also refers to VOC, which is identified as one of the controlling factors in NOx oxidation, 

the key process in the formation of nitrate and then ammonium nitrate PM2.5. The Plan also 

stated: “Relatively low non-methane organic compounds (NMOC)/NOx 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 PM2.5 reductions. 

Finally, the RMD at page 82 contains sensitivity analyses for VOC, similar to the ones 

described above for NOx and ammonia. According to the sensitivity analysis, the effect of a 50 

percent reduction in VOC emissions was predicted reductions in PM2.5 levels of 1.3 μg/m3

 for on 

annual basis, and 8.7 μg/m3 for the (24-hour) winter episode. When compared to the annual 

PM2.5 NAAQS of 15 μg/m3 and the 1997 24-hour NAAQS of 65 μg/m3, these projected 

reductions appear significant. The RMD concludes with “Finding: VOC reduction is effective for 

the annual standard and the winter episode for reduction of total carbon secondary particulates.” 

In addition, NOx and VOC reductions may have a synergistic effect, such that the ambient PM2.5

benefit would be more than expected from looking 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 PM2.5 Plan would not be suitable for such evaluations. 

Despite the above portions of the Plan implicating VOC as an attainment plan precursor, 

the Plan also contains statements explicitly rejecting 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 PM2.5 as NOx or SO2

reductions,” and “[a]ll of the technical evaluations for CRPAQS and prior assessments of 

regional particulate models have indicated that NOx is the dominant factor and VOC and 

ammonia are not.” 2008 PM2.5 Plan, pp.J-9 and p. J-19. These statements do not cite the specific 

modeling and technical evaluations they are based on, but do reflect the District’s conclusion 

after completing the analyses in the Plan, namely that VOC should not be considered an 

attainment plan precursor. Supplemental information provided by CARB confirmed this 

conclusion: “VOC emission reductions are ineffective in reducing PM2.5 at current ambient 

 16 Lurmann, F. et. al., 2006, op cit., p. 1688. 
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concentrations in the San Joaquin Valley... VOC should not be considered a significant PM2.5

precursor in this instance”. CARB VOC supplement. p.1. 

As explained above, although EPA’s presumption in the PM2.5 implementation rule is 

that VOC need not be a PM2.5 attainment plan precursor, this presumption may not be technically 

justified for certain nonattainment areas. Indeed, technical information in the 2008 PM2.5 Plan 

strongly suggests that VOC reductions can significantly reduce ambient PM2.5 concentrations 

and contribute to expeditious attainment of the PM2.5 NAAQS in the SJV. 

The above statements from the PM2.5 Plan indicating VOC is a significant precursor may 

not constitute a technical demonstration sufficient to reverse the PM2.5 implementation rule 

presumption against VOC. Clearly they were not intended as such by the State, in view of 

various other statements in the Plan. Nevertheless, 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 submit a demonstration to either 

support or reverse the presumption under the PM2.5 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 results 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 VOC supplement. Some of the reviewed documents 

are available on the “Central California Air Quality Studies” web site at www.arb.ca.gov/airways 

or are cited in the Plan, and are reports from contractors involved in CRPAQS. 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 modeling studies were found to be relevant to the 

VOC precursor issue and are discussed further 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 controls. Unlike the monitoring studies, most of 

the modeling studies explicitly assessed the relative effectiveness of precursor controls. They 

generally found that VOC controls could be effective at reducing ambient PM2.5 for some times 

and places, though there were also findings of little benefit or even a disbenefit in some cases. 

The monitoring studies examined time series of various pollutants annually and during 

severe winter PM2.5 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 NOx controls, rather than on VOC versus. NOx

controls. They nevertheless do contain some tentative conclusions about VOC. The monitored 

relative abundances of precursors and other intermediate chemical species can yield information 

on the chemical processes occurring and their relative importance. For example, nitrate 

concentrations far below those of ammonia are evidence that the formation of particulate 

ammonium nitrate is limited by NOx emissions rather than by ammonia emissions. (Lurmann et. 

al., 2006). The concentration of nitric acid (HNO3) relative to peroxides suggests the prevalence 

of VOC-limited OH and nitrate formation relative to VOC-abundant conditions (Pun, 1998). The 

correspondence of daytime ozone and nitrate PM2.5 peaks for rural sites is evidence that they are 

driven by a common process, daytime NOx oxidation via NOx and VOC-driven oxidant 

photochemistry (Pun, 2004). However, a later study concluded that this correspondence could 

also be explained by ozone transport or by daytime entrainment of nighttime nitrate formed aloft 
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(Lurmann et. al., 2006). The Plan quoted this study’s somewhat generic statement that “daytime 

photochemistry is VOC, sunlight, and background-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 Valley”. Lurmann, F. et. al., p.1688, cited at 2008 

PM2.5 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 PM2.5, a pathway that 

is not directly affected by VOC emissions reductions. The monitoring studies provide evidence 

that VOC-limited processes contribute to PM2.5 formation, but are not conclusive on the efficacy 

of VOC controls. 

By contrast, most of the six relevant modeling studies did explicitly assess the relative 

effectiveness of precursor controls, though again they tended to emphasize ammonia more than 

VOC. One study did not directly address the issue, but stated that background ozone was the 

most important oxidant, implying that VOC control would have little effect (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 share this view. See ftn 10. The other five studies explicitly 

evaluated precursor controls, simulating the PM2.5 effect of 50 percent reductions in emissions of 

NOx, ammonia, and VOC. The two earliest of these studies used photochemical box models; one 

found VOC control to be ineffective (Stockwell, 2000), while the 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 performance, so that it should 

not be weighted too heavily in making conclusions about the effectiveness of VOC reductions. 

The later three studies used more sophisticated photochemical grid models, and generally found 

VOC control to be effective, at least for some times and places, though generally less so than 

NOx control. 

One of the photochemical grid modeling studies predicted VOC control to be about 2/3 as 

effective as NOx control (17.5 percent benefit from VOC vs. 25 percent from NOx), though VOC 

disbenefits occurred at some smaller reductions (Kleeman, Ying, and Kaduwela, 2005). In 

addition, in its VOC supplement, CARB drew attention to various NOx vs. VOC isopleth 

diagrams in the study, which contain curves showing the PM2.5 effect of various combinations of 

NOx and VOC reductions. The flat or upward-tilting curves show that for the more realistic 

situation of NOx and VOC reductions occurring simultaneously, VOC reductions show very little 

PM2.5 benefit, and even a disbenefit at greater NOx 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 disbenefit may occur because in this case a VOC reduction reduces 

VOC-nitrate chemical reactions that form organic nitrates such as PAN; by lessening this nitrate 

“sink”, VOC reductions leave more nitrate available to form PM2.5. CARB VOC supplement, p.7 
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24-hour NOx/VOC particulate isopleths, μg/m3

 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 PM2.5

levels, which occur toward the end of the modeled episode, and that this is likely due to a 

different chemical regime during the high PM2.5 days. An alternative, that the sensitivity is 

somehow a result of cumulative carryover of pollutants 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 ozone 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 HO2

(hydroxyl and hydroperoxyl). CARB VOC supplement, 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 the 2000 episode, and the 12/28 – 12/31 period; 

there is significant sensitivity to VOC only toward the end of the episode, when total PM2.5 is 

about 80 μg/m3 for Angiola, and about 100 μg/m3 for Bakersfield. CARB VOC supplement, 

Fig.5, p.11, reproduced below. If the daytime VOC-driven OH route for NOx oxidation to nitrate 

were important, VOC sensitivity would be expected throughout the whole episode, not just the 

latter half with the highest PM2.5 concentrations. 
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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 PM2.5 concentrations for 

assessment of VOC as a plan precursor is the CARB point that “nitrate was only responsive to a 

50 percent reduction in VOCs at PM2.5 concentration levels that are no longer reached in the San 

Joaquin Valley... the Valley is now in a nitrate chemical formation regime that is less responsive 

to VOC controls.” CARB VOC supplement, p. 10. This implies that the study results are of 

limited relevance. According to monitoring data in EPA's AQS database, there were 172 PM2.5

daily maximum values over 80 μg/m3

 during 1999-2002; by contrast, there were only 24 maxima 

over 80 μg/m3 during 2007-2010.17 The decreased frequency of high values lends support to the 

CARB position, but does not imply the study results are irrelevant. It does appear, however, that 

there is complexity to PM2.5 formation in the SJV that is not fully understood, and this study did 

not consider the more realistic scenario of VOC and NOx reductions occurring together. 

The third grid modeling study predicted VOC control to give slightly more benefit than 

NOx control (23 percent for VOC vs. 21 percent for NOx) (Livingstone et. al., 2009). CARB 

pointed out that, of the various scenarios modeled in this study, the most realistic one showed a 

PM2.5 benefit of only 12 percent from a 50 percent VOC reduction, and a 38 percent benefit from 

a 50 percent NOx. CARB VOC supplement, p.9. 

While the models, assumptions, input data, and results differed between these studies, 

they provide evidence that control of VOC by itself can significantly reduce ambient PM2.5

 17 EPA's Air Quality System, Violation Day Count Report, May 13, 2011. 
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concentrations in the San Joaquin Valley, at least for some times and locations. However, some 

studies show little benefit, or even a disbenefit from VOC controls. The only study that 

thoroughly explored the effect of simultaneous VOC and NOx reductions, a more realistic 

scenario given the control measures that are in place, showed a VOC disbenefit, especially for 

larger NOx reductions. There is some indication that VOC sensitivity is less important for more 

recent episodes, with lower PM2.5. Finally, there also appears to be a partial consensus in the 

latest work, and in the most important monitoring study, that the nighttime ozone route for 

nitrate formation is more important than the VOC-sensitive daytime OH route. 

Altogether, the currently-available evidence does not amount to a technical 

demonstration that VOC should be considered a PM2.5 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 PM2.5 implementation rule 

presumption that VOC is not an PM2.5 attainment plan precursor should remain in place for the 

time being. 

It is unfortunate that the only study that explored the combined effect of NOx and VOC 

reductions predated CRPAQS, the most comprehensive PM2.5 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 appears to occur at higher PM2.5 concentrations, and the relative roles of 

the daytime and nighttime NOx oxidation routes. It would be highly desirable for future 

modeling efforts, such as for the attainment demonstration needed for the new PM2.5 standard, to 

explore precursor effectiveness more definitively. 

Table C-1 

San Joaquin Valley Modeling and Monitoring Study Findings 

on VOC as a Precursor for PM2.5

Study and Basis Quotes from Study 

Pun and Seigneur, 

1998 

monitored IMS95 data 

p. E-3 

Since only a small fraction of NOx is converted to HNO3... it was 

possible that the oxidation system was limited by the availability of 

oxidants. During wintertime, these oxidants may be sensitive to 

VOC rather than NOx. However, these inferences need to be 

confirmed. 

p. E-4 

However, further research is needed to understand the production of 

oxidants during the fall season and to assess the sensitivity of 

oxidants and HNO3 to VOC and NOx precursors. 

p. 3-14 

Typical concentrations of HNO3... and H2O2... suggest that the 

oxidant chemistry of the San Joaquin Valley may be in the VOCsensitive regime during the winter season. This result is 

preliminary... 
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Table C-1 

San Joaquin Valley Modeling and Monitoring Study Findings 

on VOC as a Precursor for PM2.5

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 matter (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 emissions reduces peak OH and O3

concentrations by as much as 20%. The resulting N2O5

concentrations are more than proportionately reduced, and 

consequently, the rate of HNO3 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 HNO3-sensitive, that HNO3 formation is 

oxidant-sensitive, and that oxidant formation is sensitive to 

reductions in VOC emissions. 
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Table C-1 

San Joaquin Valley Modeling and Monitoring Study Findings 

on VOC as a Precursor for PM2.5

Study and Basis Quotes from Study 

Pun, 2004 

monitored CRPAQS 

data 

p. 2 

During winter, high concentrations of PM2.5 and O3 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 O3 at the urban sites [Fresno 

and Bakersfield] show a phase difference between these two 

pollutants. 

In Angiola, nitrate is the dominant component of winter PM2.5 and 

the daytime peaks of PM2.5 are caused by daytime peaks in PM2.5

nitrate concentrations. Since daytime conditions are comparatively 

less favorable for nitrate to partition into the particulate phase, peak 

concentrations during the 1 to 4 p.m. period are strongly indicative 

of a daytime chemical process occurring at this site. 

The difference in the nitrate diurnal profiles in Angiola and at the 

urban sites indicates that the dominant processes contributing to the 

observed surface nitrate concentrations 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 chemical production of nitrate occurs at 

the surface during the day. It is postulated that the daytime chemical 

process for the production of nitrate involves OH radicals or nitrate 

radicals, if it persists due to slower photolysis during the wintertime. 

Reliable measurements of NO2 and HNO3 and additional 

measurements of nitrate radicals may be needed to evaluate the 

feasibility of the nitrate reaction. 
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Table C-1 

San Joaquin Valley Modeling and Monitoring Study Findings 

on VOC as a Precursor for PM2.5

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 NOx emissions applied to sources within the 

SJV reduced the predicted concentration of total nitrate by 

approximately 25% during the study episode.... A 50% reduction in 

VOC emissions lowered predicted concentrations of total nitrate by 

17.5%, while a 50% reduction in NH3 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 total concentration 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 Refuge leads to a predicted decrease 

in particulate nitrate concentrations of approximately 25–30% 

pp.5336-5338 

a 50% reduction in NOx emissions reduces maximum particulate 

nitrate concentrations by approximately 12 μg/m3 ...VOC and NH3

emissions controls are not as effective as NOx controls for 

particulate nitrate... a 50% reduction in VOC emissions reduces 

ground level particulate nitrate concentrations by only 7 μg/m3... a 

50% NH3 emissions reduction reduces ground level particulate 

nitrate concentrations by only 4 μg/m3

McCarthy, 2005 

monitored CRPAQS 

data 

p. 18 

Daytime HNO3 production rates are limited by sunlight, VOCs, and 

background ozone 

Nighttime HNO3 production is limited by background ozone which 

is abundant aloft but not at the surface 
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Table C-1 

San Joaquin Valley Modeling and Monitoring Study Findings 

on VOC as a Precursor for PM2.5

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 NOx and VOC emission rates and background O3 concentrations 

that control the rate of NOx oxidation. This analysis is not able to 

assess the relative benefits of controlling NOx 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 daytime 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 O3

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 aerosol concentrations are small 

compared with concentrations of likely VOC precursors; however, 

the estimated secondary portion of PM2.5 OC and PM2.5 mass is 

significant in several locations. 
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Table C-1 

San Joaquin Valley Modeling and Monitoring Study Findings 

on VOC as a Precursor for PM2.5

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 NOx and PM emissions would be 

effective on average, but reductions in VOC and NH3 emissions 

would also be beneficial for certain times and locations. 

p.405 

Reductions in anthropogenic VOC led to decreased O3

concentrations at both urban and rural sites. However, there was 

virtually no effect on OM 

p. 408 

The reduction in NOx emissions by 50% induced a strong response 

in nitrate concentrations. At the rural site, nitrate reductions 

approached 50% on average, and the 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 O3 concentrations in both urban and rural 

locations. However, nitrate concentrations were less sensitive to 

anthropogenic VOC emissions than to NOx 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 NOx emissions. Rural nitrate 

concentrations were quite insensitive to anthropogenic VOC 

emissions on some days. [Fig. 2 shows at most 10% reduction in 

PM2.5 peaks at Angiola and Bakersfield.] 

p. 408 

an effective control strategy for PM2.5 in the SJV that is 

comprehensive in time and location may require controls of multiple 

precursors rather than a single key precursor. 
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Table C-1 

San Joaquin Valley Modeling and Monitoring Study Findings 

on VOC as a Precursor for PM2.5

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 NOx is not immediately transformed into nitric acid/NH3 nitrate 

due to slow photochemical reactions in the winter. Background 

ozone is the most important oxidant for reactive nitrogen with 

gradual conversion of NOx 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 NOx and AVOC 

[anthropogenic VOC] showed similar effects on percentage basis in 

different areas, and both are more effective than reducing NH3 for 

abating elevated concentrations of accumulation mode PM in 

California Central Valley during the winter episode. 

p. 5971 

[excerpt from] Table 1. Model results for ammonium nitrate at a 

Bakersfield station. Sensitivity of two-week average (ammonium + 

nitrate) to precursor reductions 

 [precursor] [response] 

 -50% NOx -21% PM2.5

 -50% AVOC -23% PM2.5

 -50% NH3 -8.8% PM2.5

p. 5976 

The fine aerosol concentration was more sensitive to AVOC than 

NOx in small areas around a Bakersfield station with high 

concentrations of accumulation mode PM 

Notes: CRPAQS and IMS95 are described on the Central 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 early 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.2005.05.044 
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Livingstone, P.L., et. al., 2009, “Simulating PM Concentrations During a Winter Episode in a Subtropical 

Valley and Sensitivity Simulations and Evaluation methods”, Atmospheric Environment, 43: 5971-5977. 

doi:10.1016/j.atmosenv.2009.07.033 

Lurmann, F.W., Brown, S.G., McCarthy, M.C., and Roberts 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 Association for Aerosol Research (AAAR), Supersites Conference, 

February 2005, Atlanta, GA. Available on CRPAQS web page listed above; direct link: 

http://www.arb.ca.gov/airways/Documents/AAAR/2005/mccarthy_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 Environmental 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/Documents/reports/sjvpmc~1.pdf 

Pun, B.K. and Seigneur, C., 2001, “Sensitivity of Particulate 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 O3 Correspond to High PM2.5? How Much 

PM2.5 Corresponds to Photochemical End Products?”, prepared by Atmospheric and Environmental 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 NOx 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 PM10/PM2.5 Air 

Quality Study (CPRAQS) using the UCD/CIT source-oriented 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 PM2.5 Plan that, at this time, 

ammonia does not need to be considered an attainment plan precursor for purposes of attaining 

the 1997 PM2.5 NAAQS. 

The information submitted by CARB raises legitimate questions about the extent to 

which VOC emissions contribute to ambient PM2.5 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 PM10 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 PM10 levels which 

exceed the standards in the SJV. See 69 FR 30006, 30011 (May 26, 2004). In that determination, EPA relied on the 

criteria that VOC control was not shown to be absolutely necessary for PM10 attainment and that it had a lower 

effectiveness than NOx control in reduction PM10. In addition, EPA noted in its 2004 final rule the District’s 

intention to re-examine the VOC issue when CRPAQS results were available. 69 FR 30010. 

Since its 2004 finding, EPA promulgated the PM2.5 implementation rule, which has an explicit criterion for 

determining which PM2.5 precursors must be evaluated for controls, namely, that a significant change in emissions 
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because the SJV is designated as nonattainment for the 8-hour ozone standard, this area is 

already required to adopt VOC control measures for ozone purposes, which may provide a cobenefit for PM2.5 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 PM2.5 NAAQS. EPA revised the 24-hour 

PM2.5 standard in 2006 to lower it to 35 μg/m3 and is currently reviewing both the annual and 24-

hour standards to determine if they should be further lowered to protect public health. See EPA, 

Policy Assessment for the Review of the Particulate Matter NAAQS, Second External Review 

Draft, June 2010. Evaluation of ammonia and VOC controls for the attainment of the 2006 

standard and any future lower standards may show that such controls would significantly 

contribute to lower PM2.5 levels in the Valley. 

 of the precursor would be projected to provide a significant change in PM2.5 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. 
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D. Reasonably Available Control Measures/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 control measures as expeditiously as practicable 

(including such reductions in emissions from existing sources in the area as may be obtained 

through the adoption, at a minimum, of reasonably available control technology [RACT]), and 

shall provide for attainment of the national primary ambient air quality standards.” 

We interpret reasonably available control measures (RACM) in CAA section 172(c)(1) as 

referring to measures of any type that may be applicable 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 potential control measure for application to point, area, onroad and non-road emission source categories that meets the following criteria: the control 

measure is (1) technologically feasible, (2) economically feasible, (3) does not cause “substantial 

widespread and long-term adverse impacts,” (4) is not “absurd, unenforceable, or impracticable,” 

and (5) collectively can advance the attainment date by at least 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 pollution) that is reasonably available considering 

technological and economic feasibility. 72 FR 20586 at 20610. 

For PM2.5 attainment plans, EPA is requiring a combined approach to RACM and RACT 

under subpart 1 of Part D of the CAA. Under this approach, RACM/RACT are measures that a 

state finds are both reasonably available and contribute to attainment as expeditiously as 

practicable in its nonattainment area. Thus, what constitutes RACM/RACT in a PM2.5 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 area attain the NAAQS as expeditiously as practicable are not 

required RACM/RACT. A state’s attainment plan must include a list of measures considered and 

information sufficient to show that a state has met all requirements for determination of 

RACM/RACT. 72 FR 20586 at 20612. A state must evaluate RACM/RACT for each identified 

PM2.5 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 issue 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 20610. Because of the variable nature of the PM2.5 

problem between nonattainment areas, which may require states to develop attainment plans that 

address widely disparate circumstances, 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. 
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The determination of RACM/RACT is a three-step process: (1) identifying 

technologically and economically feasible measures 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 necessary to meet these requirements which are 

not already either federally promulgated, 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 measures, should be based on an inventory of 

emissions of direct PM2.5 and PM2.5 attainment plan precursors from the range of relevant 

sources and source categories. 72 FR 20586 at 20613. A state is required to evaluate 

RACM/RACT for direct PM2.5 and SO2. A state is also required to evaluate RACM/RACT for 

NOx sources unless it finds that such sources do not significantly contribute to the PM2.5 levels in 

its area. 72 FR 20586 at 20613. Significantly contribute in this context means that a significant 

change in emissions of the precursor from sources in the area would be projected to provide a 

significant change in PM2.5 concentrations in the area. 72 FR 20586 at 20590. 

In the preamble to the PM2.5 implementation rule, EPA provided a recommended list of 

the types of source categories and control measures that may be appropriate for evaluation given 

the local source mix and attainment needs of a specific area. 72 FR 20586 at 20621. 

Technological feasibility refers to whether there are available measures capable of 

reducing emissions of PM2.5 or PM2.5 precursors or both. A number of factors are considered in 

this analysis, such as process and operating conditions, raw materials, physical plant layout, nonair quality and energy impacts, and the time needed 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 factors are considered in this analysis, 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 PM2.5 SIP

The 2008 PM2.5 Plan and the 2007 State Strategy are the 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 resulted 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 among the most stringent in the nation. 

For the 2008 PM2.5 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 reasonably available control measures that could 

contribute to expeditious attainment of the PM2.5 standards in the SJV. We describe each 

agency’s efforts below. 

 19 These plans include the 2003 PM10 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). 
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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 PM2.5 Plan. The analysis focused on controls for the categories of 

stationary and area sources under the District’s direct jurisdiction. 

To identify potential RACM/RACT, the District reviewed potential measures from a 

number of sources including but not limited to: 

• EPA’s list of potential PM2.5 control measures (in the PM2.5 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 report, “Accelerating Attainment in the San 

Joaquin Valley” November 6, 2007. 

2008 PM2.5 Plan, pp. 6-6 to 6-8. 

The identified potential measures, as well as existing District measures, are described by 

emissions inventory category in Appendix I. These measures address emissions of direct PM2.5, 

NOx and SOx. See 2008 PM2.5 Plan, p. 6-8 and Appendix I. Potential RACM/RACT controls for 

VOC or ammonia were not specifically identified or evaluated. From this set of potential 

controls, the District developed a Stationary Source Regulatory Implementation Schedule (2008 

PM2.5 Plan, Table 6-2) which gives the schedule for regulatory adoption and implementation of 

the selected RACM/RACT measures. See also Table F-1 of this TSD. The schedule was 

developed based on a variety of factors, including: 

• technological feasibility and practicality of emission controls; 

• magnitude of emissions from the source category and likely emissions reductions (where 

possible to determine); 

• cost, financial impacts, and potential for socioeconomic impacts (e.g., employment, 

profitability); 

• District authority and enforceability of emissions reductions; 

• rate and timing of emissions reductions; 

• public acceptability, including interests and concerns of community members; 

• pollutants reduced – NOx, PM2.5, VOC, SOx, or multiple pollutants; 

• any potential adverse environmental impacts; and. 

• potential for disparate environmental impacts (environmental justice). 

2008 PM2.5 Plan, p. 6-7. 

The District also identified a number of source categories for which feasibility studies to 

refine the inventory and evaluate potential controls would be done. These categories and the 
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schedule for studying them are given in Table 6-4 of the 2008 PM2.5 Plan and Table F-6 of this 

TSD. 

The Plan also includes descriptions of the District’s incentive programs (which target onand off-road engine replacement with an emphasis on diesel engines), its innovative strategies 

program including its Fast Track emissions reductions measures, and public education efforts. 

See 2008 PM2.5 Plan, pp. 6-13 to 6-23. See also, SJV PM2.5 Progress Report, sections 2.3 and 

2.4. 

Since submittal of the 2008 PM2.5 plan, the District has adopted a number of measures 

intended to meet its commitments and provide for the implementation of RACM/RACT. 

b. Local Jurisdictions’ RACM Analysis 

The local jurisdictions’ RACM/RACT analysis was conducted by the SJV’s eight 

MPOs.20 This analysis, which focused on potential NOx emissions reductions from transportation 

control measures (TCM) and builds on the work done for the SJV 2007 Ozone Plan. TCMs are 

generally measures designed to reduce emissions from on-road motor vehicles through 

reductions in vehicle miles traveled or traffic congestion. The results of the MPOs’ analysis are 

described in Chapter 7 of the 2008 PM2.5 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 adoption of a Congestion Mitigation and Air Quality 

(CMAQ) policy to fund cost-effective emissions reductions projects. 

For the 2008 PM2.5 Plan, the MPOs reviewed and updated the evaluation of potential 

RACM from the 2007 Ozone Plan following EPA’s guidance in the PM2.5 implementation rule 

preamble. The evaluation is documented in the 2008 PM2.5 Plan on pp. 7-8 to 7-11 and included 

the following steps: 

Step 1: Identification of potential new measures: The MPOs reviewed the measures in the 

2007 Ozone Plan, EPA’s draft list of PM2.5 measures (see 72 FR 20586 at 20621), and other SIPs 

including the South Coast 2007 AQMP and the New 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 PM2.5 problem in the SJV, the analysis focused on NOx to assess whether the 

reductions from these TCM could advance attainment. It did not look at potential emissions 

reductions of direct PM2.5, SOx, VOC, or ammonia. 

In the 2007 Ozone Plan, emissions reductions estimates were calculated for the list of 

possible local TCM. The maximum feasible emissions reductions for NOx estimated from 

implementing all of these TCMs are approximately 7 tons per day (tpd) in 2020 and 5 tpd in 

2023. 2008 PM2.5 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 Governments, the Merced County Association 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. 
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could be expected from the applicable measures and the average gram/mile emission rate of 

light-duty vehicles (i.e., passenger cars and light-duty trucks) operated during the summer. 

These summer time estimates for NOx 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 those in 2013/2014. This means the NOx reductions estimated in 2020 

and 2023 underestimate the reductions that could be produced in earlier years. Using a ratio of 

fleet average NOx emission rates for light-duty vehicles in 2013 to 2020 (2.07), maximum 

reductions are estimated to produce a reduction 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, PM2.5 levels in the SJV are higher in the winter time. Because 

mobile source NOx emissions are higher in the summer than winter, NOx 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 implementation of TCM would advance attainment in the 

SJV is conservative (i.e., over estimate the potential emissions reductions). 2008 PM2.5 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 PM2.5 plan, it was estimated that an additional 93.122 tons per average annual 

day of NOx emissions reductions would be necessary in 2013 to advance attainment of the PM2.5

standard by one year which is considerable more than the estimated 14 tpd of potential NOx

reductions from TCM. 2008 PM2.5 Plan, p. 7-11. 

Based on the above analysis, the MPOs determined that there were no additional local 

RACM, beyond those measures already adopted, that would advance attainment of the PM2.5

NAAQS in the SJV and thus no additional adoption of measures was necessary. 2008 PM2.5

Plan, p. 7-11. 

The eight MPOs did adopt a CMAQ policy that includes developing a standardized 

process across the Valley for distributing, beginning in FY2011, 20 percent of the CMAQ funds 

to projects that meet a minimum cost-effectiveness. This policy focuses on achieving the most 

cost-effective emissions reductions, while maintaining flexibility to meet local needs. 2008 PM2.5

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 assumption used is that the effectiveness 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 PM2.5 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 recession and updated estimates of reductions from District’s adopted controls. 

See Table E-2 of this TSD. 
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c. State’s RACM Analysis 

CARB describes its proposed strategy to reduce emissions from sources within its 

jurisdiction – on- and off-road engines and vehicles, fuels, and consumer products –- in 

Chapter 3 of the 2007 State Strategy. California has unique authority under the CAA to adopt 

standards for most categories of on- and off-road engines and vehicles, subject in most instances 

only to a waiver by EPA under CAA section 209. 

CARB developed its proposed statewide strategy after an extensive public consultation 

process to identify potential SIP measures. This process is described in the 2008 PM2.5 Plan, p. 7-

11. It included a SIP Symposium in October 2006 and a workshop in November 2006 to discuss 

development of potential control concepts for meeting the federal 8-hour ozone and PM2.5

standards.23 CARB made available a draft of the 2007 State Strategy for public review in 

April 2007 and then conducted a series of public 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 public 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 PM2.5 nonattainment problem. 2007 State Strategy, p. 65 and 

CARB Resolution 7-28, Attachment B, p. 8. These measures focused on cleaning up the in-use 

(“legacy”) fleet as well as increasing the stringency 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 proposed and adopted for the first time anywhere in 

the nation. They built on CARB’s already comprehensive program to address emissions of direct 

PM2.5, NOx, VOC, and SOx from all types of mobile sources, through both regulations and 

incentive programs, as well as from fuels and 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. 
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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 Introduction of Cleaner LineHaul Locomotives (enforceable agreement) 2007-2008 Starting in 2012 

Clean Up Existing Harbor Crafts 2007 2009-2018 

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

Cleaner In-Use Agricultural Equipment 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. 

 
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Table D-2 

Updated 2007 State Strategy: PM2.5 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 1 
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3. November 2010 Proposed Action on the RACM/RACT Demonstration

In November 2010, EPA proposed to disapprove the RACM/RACT demonstration in the 

SJV 2008 PM2.5 SIP based on our proposed disapproval of the attainment demonstration and 

proposed denial of California’s attainment date extension request. We also proposed to 

disapprove the RACM/RACT demonstration because it did not evaluate potential controls on 

VOC. See 2010 Draft TSD, section II.D. and 75 FR 74518 at 74528. 

We noted in our proposed disapproval that is appeared that the State, District, and local 

jurisdictions have identified and otherwise provided for the implementation 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 demonstration and appropriately address VOC as an 

attainment plan precursor in its RACM/RACT demonstration in the PM2.5 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 PM2.5 implementation rule, RACM/RACT are the set of measures necessary 

for expeditious attainment. The measures must address emissions of direct PM2.5

24and all PM2.5

attainment plan precursors that are necessary for expeditious attainment. Thus, in order for a 

PM2.5 plan to demonstrate that it provides for RACM/RACT, it must also demonstrate that it 

provides for expeditious attainment. 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 for the SJV until April 5, 2014 and to approve the 

attainment demonstration in the 2008 PM2.5 plan as providing for expeditious attainment of the 

1997 PM2.5 standards in the San Joaquin Valley by that date. 

As discussed in Section II.C. of this TSD, EPA proposes to concur with the evaluations in 

the 2008 PM2.5 Plan and supplemental information provided by CARB, at this time, ammonia 

and VOC do not need to be considered attainment plan precursors for purposes of attaining the 

1997 PM2.5 NAAQS in the SJV. 

Therefore, EPA is proposing to find that the 2008 PM2.5 Plan, together with the 2007 

State Strategy, provides for the implementation of all RACM/RACT necessary for expeditious 

attainment of the 1997 PM2.5 standards in the San Joaquin Valley as required by CAA section 

172(c)(1) and 40 CFR § 51.1010 and to approve the SJV PM2.5 SIP’s RACM/RACT 

demonstration pursuant to these sections. 

Petitions for consideration on provisions of the PM2.5 Implementation Rule related to RACT: 

As discussed in section I.A.2.b., EPA received a petition for reconsideration of several 

provisions in the PM2.5 implementation rule including three 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 PM2.5 SIP: 

 24 Condensable PM2.5, which is considered direct PM2.5, did not need to be addressed in rules prior to 

January 1, 2011. 40 CFR § 51.1002(c). 
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1. The presumption that compliance with the Clean Air Interstate Rule (CAIR) satisfies the 

NOx and SO2 RACT requirements for electric generating units. 72 FR 20586 at 20623-

28. 

The SJV nonattainment area was not subject to the CAIR which was intended to 

control the interstate transport of pollutants in the eastern United States. See 

70 FR 25162 (May 12, 2005). 

2. The allowance for states to defer establishing 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 revised after January 1, 2011 to assure that it 

appropriately addresses CPM. 

3. The revisions to the criteria for analyzing 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 regulated entity to 

bear, in light of benefits. 72 FR 20586 at 20619-20620. 

While the 2008 PM2.5 Plan includes some discussion of criteria for economic 

feasibility that seem to reflect the revised criteria in the PM2.5 implementation rule (see 

pp. 6-2 and 6-7), we can find no example of where those criteria actually resulted in 

the rejection of a potential RACT measure. 
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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 Administrator 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 PM2.5 designations, including that for the SJV nonattainment area, have an effective date 

of April 5, 2005, the initial attainment date for PM2.5 areas is no later than April 5, 2010. For any 

areas that EPA grants the full 5-year attainment date extension under section 172(a), the 

attainment date is no later than April 5, 2015. 

Section 51.1004 of the PM2.5 implementation rule addresses the attainment date 

requirement. Section 51.1004(b) requires a state to submit an attainment demonstration justifying 

its proposed attainment date and indicates that EPA 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 showing expeditious attainment. 

A state that requests an extension 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 nonattainment 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 technologically feasible for the area are being implemented to bring 

about expeditious attainment of the standard by the alternative attainment date for the area. The 

state’s plan will need to project the emissions reductions expected due to federal and state 

regulations and local measures such as RACT and RACM, and then 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 initial 5 years allowed by 

section 172(a)(2)(A) if the state has not considered 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 PM2.5 Plan

The expeditious attainment demonstration that supports the District’s proposed 

attainment date is found in Chapter 9 of the Plan 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 standard, the District and CARB requested an 

attainment date extension to April 5, 2015 for both the annual and 24-hour PM2.5 standards. See 

SJVUAPCD Governing Board Resolution, p. 4 and CARB Resolution 08-28, p. 4. In its 2011 

Progress Report, CARB continues to project April 5, 2015 as the most expeditious attainment 

date in the SJV. See 2011 Progress Report, p. 1. 
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Table E-1 

Expeditious Attainment Demonstration for the Annual PM2.5 Standard 

in the San Joaquin Valley 

(tons per annual average day) 

Year 2009 2010 2011 2012 2013 2014 

Baseline NOx 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 

NOx emissions level needed for 

PM2.5 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 PM2.5

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 PM2.5 emissions level needed 

for PM2.5 attainment 63.3 63.3 63.3 63.3 63.3 63.3 

At attainment level? no no no no no yes 

Baseline SO2 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 

SO2 emissions level needed for 

PM2.5 attainment 24.6 24.6 24.6 24.6 24.6 24.6 

At attainment level? no yes yes yes yes yes 

Overall annual PM2.5 standard 

attainment? no no no no no yes 

 Projected attainment year/ 

attainment date 2014/April 5, 2015

Source: 2008 PM2.5 Plan, Table 9-1. 

N/A: not applicable. CARB provided commitments to NOx and PM2.5 reductions in 2014 only . 
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Table E-2 

Revised Expeditious Attainment Demonstration 

for the Annual PM2.5 Standard 

in the San Joaquin Valley 

(tons per annual average day) 

Year 2009 2012 2013 2014 

Baseline NOx inventory 500.9 424.4 393.1 376.2 

District commitments/actual 

achieved1 2.4 11.8 12.4 9.0 

Adjustments to baseline2 117.5 84.6 73.95

76 

CARB commitment3 N/A N/A N/A 

Controlled inventory4 381 328 306.8 291 

NOx emissions level needed for 

PM2.5 attainment 291.2 291.2 291.2 291.2 

At attainment level? no no no yes 

Baseline direct PM2.5 inventory 79.8 77.0 75.9 75.0 

District commitments1 1.6 6.7 6.7 6.7 

Adjustments to baseline2 5.2 1.3 2.0 

5.0 

CARB commitment3 N/A N/A N/A 

Controlled inventory4 73 69 67.2 63.3 

Direct PM2.5 emissions level needed 

for PM2.5 attainment 63.3 63.3 63.3 63.3 

At attainment level? no no no yes 

Baseline SO2 inventory 26.4 23.6 23.8 25.5 

District commitments/actual 

reductions1 0.1 3.5 3.6 3.6 

Adjustments to baseline2 3.3 0.1 0.3 0.5 

CARB commitment3 N/A N/A N/A N/A 

Controlled inventory4 23.0 20 19.9 21.4 

At attainment level? no yes yes yes 

Overall annual PM2.5 standard 

attainment? no no no yes 

 Projected attainment 

year/attainment date 2014/April 5, 2015

Source: 2008 PM2.5 Plan, Table 9-1 and 2011 Progress Report, Appendix C, Table C-1. 

N/A: not applicable. 
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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 reductions 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. According to the 2007 State Strategy, actual 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, Attachment B, p. 3); therefore, adjustments to the 

baseline are counted towards meeting 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 PM2.5 and NOx

numbers are estimated from information in the 2011 Progress Report and additional information provided 

by the District, see SJVUAPCD, Tables 3-1 “Adjusted PM2.5 Inventory” and Table 3-2 Adjusted NOx

Inventory,” no date. 

5. Calculated by averaging 2014 adjustments to baseline (63.1 tpd for NOx and 2.7 tpd for PM2.5, see Table 

F-7) and averaging this result with the adjustment to baseline for 2012. A similar calculation is done for 

PM2.5, and SOx. 

The 2008 PM2.5 Plan does not specifically address the most expeditious date for the 

attaining the 24-hour PM2.5 standard. In reference to attainment of the 24-hour standard, the Plan 

states: 

Attainment of the 24-hour 65 microgram standard 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 identifies 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 concerns that the last 

two years have experienced slightly higher 24-hour values, the District also performed a 

screening assessment with estimated design values for 2007 (based on incomplete and 

uncertified data). Evaluation by the District 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 PM2.5 Plan, p. 3-32. 

3. November 2010 Proposed Action on the Attainment Date Extension

In 2010, we proposed to not grant the State’s request to extent the attainment date for the 

1997 PM2.5 standards in the SJV to April 5, 2015. This proposal was based primarily on our 

proposed disapproval of the RACM/RACT demonstration. See 75 FR 74518, 74534. As stated in 

preamble to the PM2.5 implementation rule (72 FR 20586 at 20601), EPA cannot grant an 

extension of the attainment date beyond the initial five years provided by section 172(a)(2)(A) if 

the state has not adequately considered and evaluated the implementation of RACM and RACT 

in the area .We had proposed to disapprove the RACM/RACT demonstration because of the 

issues with the air quality modeling and absence of analysis of VOC controls. We noted, 

however, that given the severity of the PM2.5 nonattainment problem in the SJV, an extension of 

the attainment date would most likely be appropriate and approvable if it were supported by the 
TSD for the Revised Proposal 

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EPA- Region 9 Page 82

necessary analysis and part of an attainment plan that meets the applicable statutory and 

regulatory requirements. 

4. Evaluation and Conclusions

SJV’s degree of PM2.5 nonattainment can fairly be characterized as severe. The area 

typically records the highest ambient PM2.5 levels in the nation, with 2008-2010 design value for 

the annual PM2.5 levels in urban Bakersfield area of 21.2 μg/m3

. See EPA, Air Quality 

Subsystem, Design Value Report, June 1, 2011. The PM2.5 problem in the San Joaquin Valley is 

complex, caused by both direct and secondary PM2.5 and compounded by the area’s 

topographical and meteorological conditions that are particularly conducive to the formation and 

concentration of PM2.5. See 2008 PM2.5 Plan, Chapter 3. 

As discussed in section II.F. below, the District's and State’s strategy for attaining the 

PM2.5 standard in the SJV relies on significant reductions of direct PM2.5 as well as the PM2.5 

precursor pollutants NOx and to a lesser degree SOx. The State and District have already adopted 

and are currently implementing a comprehensive set of PM2.5, NOx, and SOx 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 PM2.5 emissions are achieved primarily from control measures on 

open burning, commercial charbroiling, residential wood combustion, and in-use trucks and 

buses. These types of control measures present special implementation challenges (e.g., the large 

number of individuals subject to regulation and the difficulty of applying conventional 

technological control solutions). Reductions in NOx emissions come largely from District rules 

for fuel combustion sources and from the State’s mobile source rules. Reductions in SOx

emissions come primarily from controls on combustion sources and glass melting furnaces. 

Because of the necessity of obtaining additional emissions reductions from the more 

challenging-to-control source categories and the need to conduct significant public outreach if 

applicable control approaches are to be effective, EPA agrees with the District and CARB that 

the 2008 PM2.5 Plan reflects expeditious implementation of these controls during the 2008-2014 

time frame. We also agree that the implementation schedule for the District’s enhanced 

stationary source controls is expeditious, taking into account the time necessary for purchase and 

installation of the required control technologies. Finally, we believe that it is not feasible at this 

time to accelerate the emissions reduction schedule for the State and Federal mobile source 

control program which must rely on fleet turnover over the years 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 PM2.5 air quality in the SJV and adoption and expeditious 

implementation of all reasonably available measures to reduce direct PM2.5 and PM2.5 precursors, 

we believe that the SJV PM2.5 SIP provides for attainment of the 1997 PM2.5 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 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page 83

F. Adopted Control Strategy and Enforceable Commitments

1. Requirements for Control Strategies and Enforceable Commitments

CAA section 172(c)(6) requires nonattainment plans to “include enforceable emission 

limitations, and such other control measures, means or techniques (including economic 

incentives such as fees, marketable permits, and auctions of emission rights), as well as 

schedules and timetables for compliance, as may be necessary or appropriate to provide for 

attainment of such [NAAQS] in such area by the applicable attainment date....” 

CAA section 110(a)(2)(A), which applies to all SIPs, contains virtual identical language. 

The PM2.5 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 should 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 already SIP approved, federally promulgated, or 

otherwise SIP creditable. EPA, however, recognizes that circumstances exist 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 that 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 all 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-implementation before mandatory sanctions are imposed. 

Once EPA determines that circumstances warrant use of an enforceable commitment, 

EPA considers three factors in determining whether to approve the enforceable commitment: 

(a) does the commitment address a limited portion of the statutorily-required 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 Appeals 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 approving 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page 84

2. Control Strategy in the SJV 2008 PM2.5 Plan and Revised 2007 State Strategy

For the purposes of evaluating the SJV 2008 PM2.5 Plan and 2007 State Strategy, we have 

divided the measures relied on in the attainment and RFP demonstrations and to meet the 

RACM/RACT and contingency measures requirements 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 PM2.5 Plan 

and 2007 State Strategy) that continue to generate emissions reductions through to the attainment 

year of 2014 and beyond.27 2007 State Strategy, Appendix A, p. 1 and 2008 PM2.5 Plan, 

Appendix B, p. B-1. Reductions from these measures are incorporated into the baseline inventory 

and, for the most part, not individually quantified. These measures provide the majority of 

emissions reductions needed to attain the PM2.5 standards in the SJV. See Table G-1 in this TSD. 

 Control strategy measures are the new rules, rule revisions, commitments, and other 

adjustments to the inventory that provide the additional increment of emissions reductions 

needed beyond the baseline measures to demonstrate 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 PM2.5 Plan, the District identified and committed to adopting and 

implementing 13 new control measures for direct PM2.5, NOx, and/or SOx. In Table F-1 below, 

we list these measures, which mostly involve strengthening existing District rules, along with 

their anticipated and actual adoption, final compliance, and initial implementation dates. As can 

be seen from Table F-1, the District has mostly 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 PM2.5 Plan; however, we note that the District’s commitment is only to the 

aggregate emissions reductions shown. See 2008 PM2.5 Plan, p. 6-9 and SJVUAPCD Governing 

Board Resolution, p. 5. The reductions listed in Table F-2 are those anticipated to be achievable 

from each rule at the time the 2008 PM2.5 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 PM2.5 Progress Report, for the measures that have 

been approved or proposed for approval by EPA. 

For a number of potential measures identified 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 District 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 compliance 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 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page 85

feasibility studies. See 2008 PM2.5 Plan, page 6-13 and Table 6-4. Measures that are identified as 

being feasible through these studies will be included in future plan updates with schedules and 

emissions reduction commitments. A list of these studies, their anticipated completion dates, and 

their current status is given in Table F-6. Additional information on these feasibility studies can 

be found in the SJV PM2.5 Progress Report, Appendix C. 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Table F-1 

San Joaquin Valley Air Pollution Control District 

2008 PM2.5 Plan Specific Rule Commitments

Measure Number & Description District Rule 

Number 

Rule Making 

Completion 

Date 

Actual 

Adoption 

Date 

Compliance 

Date 

Actual 

Compliance 

Date 

Y

Red

S-AGR-1 Open Burning (Phase IV) 4103 2nd Q – 2010 April 2010 2010 June 2010 2S-COM-1 Advanced Emissions Reductions for Boilers, Steam Generators and Process Heaters (> 5 MMBtu/hr) 

4320 3rd Q – 2008 October 2008 2012 July 2012 to January 2014 2

S-COM-2 Boilers, Steam Generators and Process Heaters (2 to 5 MMBtu/hr) 4307 3rd Q – 2008 October 2008 2012 July 2010 to January 2016 2S-COM-3 Boilers, Steam Generators and Process Heaters (0.075 to < 2 MM Btu/hr) 

4308 4th Q – 2009 December 2009 2011 January 2011 2

S-COM-5 Stationary Gas Turbines 4703 3rd Q – 2007 September 2007 2012 January 2012 2S-COM-6 Reciprocating Internal Combustion Engines 4702 4th Q – 2010 Anticipated: August 2011 2012 TBD 2S-COM-7 Glass Melting Furnaces 4354 3rd Q – 2008 

October 2008; 

Revised 

September 

2010 

2009 

PM10 & SOx – 

January 2011 

NOx limits – 

January 2014-

2018 

2

S-COM-9 Residential Water Heaters 4902 1st Q – 2009 March 2009 Attrition Attrition 2S-COM-10 Natural Gas-Fired, Fan Type Residential Central Furnaces 4905 4th Q – 2014 N/A Attrition TBD 2S-COM-141 Wood Burning Fireplaces 

and Wood Burning Heaters 4901 3rd Q – 2009 October 2008 2010 2010 2

S-IND-9 Commercial Charbroiling 4692 2nd Q - 2009 September 2009 2011 January 2011 2
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Table F-1 

San Joaquin Valley Air Pollution Control District 

2008 PM2.5 Plan Specific Rule Commitments

Measure Number & Description District Rule 

Number 

Rule Making 

Completion 

Date 

Actual 

Adoption 

Date 

Compliance 

Date 

Actual 

Compliance 

Date 

Y

Red

S-IND-21 Flares 4311 2nd Q – 2009 June 2009 2010 July 2011 2M-TRAN-1 Employer Based Trip Reduction Program 9410 4th Q – 2009 December 2009 2012 January 2012 2

Source: 2008 PM2.5 Plan, Table 6-2, revised June 17, 2010. Anticipated adoption date for Rule 4702, SJVAPCD, District Highlights, Ju

the District Governing Board. 

1 Listed as S-COM-11 in Table 6-2 but as S-COM-14 elsewhere in the Plan. 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Table F-2 

San Joaquin Valley Air Pollution Control District 

Estimated Emissions Reductions for 2008 PM2.5 Plan Specific Rule Commitments Plan A

(tons per average annual day) 

NOx Emissions Reductions 

 2009 2010 2011 2012 

S-AGR-1 4103 - Open Burning (Phase III & IV) 1.21 1.95 2.68 2.67 S-COM-1 

Rule 4320 - Advanced Emissions Reductions for Boilers, Steam Generators and Process Heaters (> 5 MMBtu/hr) 

0 0 0 1.49 

S-COM-3 4308 - Boilers, Steam Generators and Process Heaters (0.075 to < 2 MMBtu/hr) 0 0 0.12 0.27 S-COM-5 4703 - Stationary Gas Turbines 0 0 0 2.21 S-COM-7 4354 - Glass Melting Furnaces 1.22 1.25 1.18 1.60 S-COM-9 4902 - Residential Water Heaters 0 0 0.20 0.25 S-COM-14 4901 - Wood Burning Fireplaces and Wood Burning Heaters 0 0.04 0.08 0.07 

Commitment to Total NOx Reductions 2.43 3.24 4.26 8.56 

Direct PM2.5 Emissions Reductions 

 2009 2010 2011 2012 S-AGR-1 4103 - Open Burning (Phase III & IV) 1.60 2.57 3.53 3.52 S-COM-1 

Rule 4320 - Advanced Emissions Reductions for Boilers, Steam Generators and Process Heaters (> 5 MMBtu/hr) 

0 0 0 0.23 

S-COM-14 4901 - Wood Burning Fireplaces and Wood Burning Heaters 0 0.39 0.76 0.73 S-IND-9 4692 - Commercial Charbroiling 0 0 2.17 2.21 

Commitment to Total PM2.5 Reductions 1.60 2.96 4.461 6.69 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Table F-2 

San Joaquin Valley Air Pollution Control District 

Estimated Emissions Reductions for 2008 PM2.5 Plan Specific Rule Commitments Plan A

(tons per average annual day) 

SOx Emissions Reductions 

 2009 2010 2011 2012 S-AGR-1 4103 – Open Burning (Phase III & IV) 0.062 0.10 0.14 0.14 S-COM-1 

Rule 4320 - Advanced Emissions Reductions for Boilers, Steam Generators and Process Heaters (> 5 MMBtu/hr 

0 0 0 0.76 

S-COM-14 4901 - Wood Burning Fireplaces and Wood Burning Heaters 0 0.01 0.02 0.02 M-TRAN-1 9410 – Employer Based Trip Reduction Programs TBD TBD TBD TBD 

Commitment to Total SO2 Reductions 0.06 0.11 0.16 0.92 

Source: 2008 PM2.5 Plan, Table 6-3 1 The value 4.46 is given on Table 6-3b in the 2008 PM2.5 Plan. PM2.5 reductions expected in 2011, however, sum to 6.46 tpd. 2 Value given as 0.03 tpd in Appendix I, page I-4. 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page 90

Table F-3 

Approval and Submittal Status of SJVAPCD Rules in the 2008 PM2.5 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 Heaters (> 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 Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Table F-4 

San Joaquin Valley Air Pollution Control District 

Emissions Reductions for 2008 PM2.5 Plan From Approved or Proposed for Approval Measu

(tons per average annual day) 

NOx Emissions Reductions 

2009 2012 

S-AGR-1 4103 - Open Burning 1.21 1.87 S-COM-1 

4306 - Boilers - Phase 3 & 4320 - Advanced Emissions Reductions for Boilers, Steam Generators and Process Heaters (> 5 MMBtu/hr)1 

0 (1.58) 

S-COM-2 4307 - Boilers, 2 to 5 MMBtu/hr 0 1.25 S-COM-3 4308 - Boilers, 0.075 to 2 MMBtu/hr 0 0.69 S-COM-5 4703 - Stationary Gas Turbines 0 2.20 S-COM-7 4354 - Glass Melting Furnaces 1.22 3.50 S-COM-9 4902 - Residential Water Heaters 0 0.30 S-COM-14 4901 - Wood Burning Fireplaces and Wood Burning Heaters 0 0.12 M-TRAN-1 9410 - Employer-Based Trip Reduction2 0 (0.31) 

Total Creditable NOx Reductions from Approved/ 

 Proposed For Approval Measures 2.43 9.93 

Direct PM2.5 Emissions Reductions 

2009 2012 

S-AGR-1 4103 - Open Burning 1.60 2.91 S-COM-1 

4306 - Boilers - Phase 3 & 4320 - Advanced Emissions Reductions for Boilers, Steam Generators and Process Heaters (> 5 MMBtu/hr) 

0 0.24 

S-COM-14 4901 - Wood Burning Fireplaces and Wood Burning Heaters 0 1.15 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Table F-4 

San Joaquin Valley Air Pollution Control District 

Emissions Reductions for 2008 PM2.5 Plan From Approved or Proposed for Approval Measu

(tons per average annual day) 

S-IND-9 4692 - Commercial Charbroiling3 0 0.0 M-TRAN-1 9410 - Employer-Based Trip Reduction2 0 (0.03) 

Total PM2.5 Reductions from Approved/ 

Proposed for Approval Measures 1.6 4.30 

SOx Emissions Reductions 

2009 2012 

S-AGR-1 4103 - Open Burning 0.05 0.05 S-COM-1 

4306 - Boilers - Phase 3 & 4320 - Advanced Emissions Reductions for Boilers, Steam Generators and Process Heaters (> 5 MMBtu/hr) 

0 1.92 

S-COM-7 4354 - Glass Melting Furnaces 0 1.49 S-COM-14 4901 - Wood Burning Fireplaces and Wood Burning Heaters 0.01 0.02 

Total SO2 Reductions from Approved/ 

Proposed for Approval Measures 0.06 3.48 

Source: SJVUAPCD, “Table 3-1 Adjusted PM2.5 Emission Inventory; Table 3-2 Adjusted NOx Emission Inventory; and Table 3-3 Adju

Emission Inventory,” March 2011, available in the docket for this proposal. All reductions are based on the Plan’s emissions inventory

1 NOx reductions from Rule 4320 are not currently SIP creditable. See EPA’s approval of the rule at 76 FR 16696 (March 25, 2011) 2 Because Rule 9410 has not been proposed for approval, reductions from this rule are not included in the totals reductions listed. Shoul

rulemaking to approve this rule prior to final action on the SJV 2008 PM2.5 plan, we propose to grant the rule the listed credit. 

3 Erroneous value given in SJVUAPCD tables.
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Table F-5 

San Joaquin Valley Air Pollution Control District 

2008 PM2.5 Plan Feasibility Studies

Measure Number & Description District Rule Number Anticipated Study Completion Date Status 

S-AGR-2 Conservation Management Practices 4550 2010 On-going through 2011. Study currently focused 

direct PM2.5 from sources covered by this rule. 

S-COM- 4 Solid Fuel Boilers, Steam Generators and Process Heaters (> 5 MMBtu/hr) 

4352 2009 

Completed. Study found additional controls are tefurther reduce NOx. District will evaluate various 

rule revisions in 2011. 

S-COM-6A Small Spark-Ignited Engines and Agricultural Spark-Ignited Engines 4702 2008 Completed. Rule revisions are currently under dev

expected August 2011. 

S-COM-8 Lime Kilns 4313 2011 Completed. Study found that there are no lime kil

the SJV. 

S-COM-11 Dryers 4309 2011 Continuing through 2011. Several options for rule 

considered. 

S-GOV-6 Prescribed Burning 4106 2008 

Feasibility study completed. Based on results of tseeking legislative changes to raise priority of air concerns in decision making on prescribed burnindeveloped a comprehensive outreach program and coordination calls with agencies involved in presc

S-IND-8 Cotton Gins 4204 2009 On-going through 2012. Completion delayed pen

national cotton gin particulate matter emissions st

S-IND-4 Fugitive PM10 Prohibitions Reg. VIII 2009 On-going through 2011. Study currently focused 

direct PM2.5 from sources covered by this regulati

M-OTH-8 Indirect Source Review Enhancement 9510 2010 Completed. Study concluded that no rules revisioM-OTH-10 Fireworks – 2012 On-going through 2012. Study is looking at legal 

future control options. 

Source: 2008 PM2.5 Plan, Table 6-4 and SJV PM2.5 Progress Report, Appendix C. 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page 94

b. CARB Measures and Commitment 

The 2007 State Strategy includes a commitment 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 lists 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. These new measures build on the State’s already 

extensive list of adopted measure; a list of which 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 PM2.5 NAAQS in the San 

Joaquin Valley by the requested attainment date of April 5, 2015. For the SJV, the 2007 State 

Strategy includes a State commitment to achieve 5 tpd of direct PM2.5 and 76 tpd of NOx 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 described in the State Strategy as follows: 

The total emission reductions from the new measures necessary to attain the federal 

standards are an enforceable State commitment in the SIP. While the proposed State 

Strategy includes estimates of the emission reductions from each of the individual new 

measures, it is important to note that the commitment of the State Strategy is to achieve 

the total emission reductions necessary to attain the federal standards, which would be the 

aggregate of all existing and proposed new measures combined. Therefore, if a particular 

measure does not get its expected emission reductions, the State still commits to 

achieving the total aggregate emission reductions, whether this is realized through 

additional reductions from the new measures or from alternative control measures or 

incentive programs. If actual emission decreases occur in any air basin for which 

emission reduction commitments have been made that are greater than the projected 

emissions reductions from the adopted measures in the State Strategy, the actual emission 

decreases may be counted toward meeting ARB’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 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page 95

As described in section II.A.3. of this TSD, CARB has adjusted baseline emissions 

estimates for source categories subject to its recently-revised in-use rules. Table F-7 shows 

original and adjusted baseline emissions 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) that 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 Progress Report, Table 1. Additional information from 

www.ca.arb.gov. Only defined measures with PM2.5, or NOx reductions in the SJV are shown here. 

 28 California Assembly Bill 2289, passed in 2010, requires 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. 
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Table F-7 

Original and Adjusted Baseline Emissions Inventories 

By State Measure 

(tons per day, 2014)

State Measure 

Direct PM2.5 NOx 

Original Adjusted Change Original Adjusted Change Original A

Smog Check Improvements (BAR) 2.5 2.5 0.0 41 41.2 +0.2 – Cleaner In-Use Heavy-Duty Trucks & Buses 6.2 4.3 -1.9 156.9 111.3 -45.6 0.3 Accelerated Intro. Of Cleaner LineHaul Locomotives 0.5 0.5 0.0 19.9 19.9 0.0 – Cleaner In-Use Off-Road Equipment (>25hp) 1.4 0.6 -0.8 31.4 13.7 -17.7 0.0 New Emission Standards for Recreational Boats – – – 3.5 3.5 0.0 – All Other Measures 641 641 0.0 123.0 123.0 0.0 242 Totals: 74.6 71.9 -2.7 375.7 312.6 -63.1 24.3 

Source: 2011 Progress Report, Appendix E, p. 4. 1 Includes emissions from recreational boats. 2 Includes emissions from all sources categories except for those subject to the Truck & Bus and Off-Road Equipment Rules 
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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 PM2.5 NOx

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 Agricultural 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 PM2.5, or NOx reductions in 

the SJV are shown here. Note: The 2007 State Strategy did not include SOx reductions for the 

SJV. 

3. November 2010 Proposed Action on the Control Strategy and Enforceable 

Commitments

In our 2010 proposed action, we found that circumstances warranted the consideration of 

enforceable commitments as part of the SJV PM2.5 SIP’s attainment demonstration. We also 

found that both the State and the District had demonstrated the capability to meet their 

commitments. We did not find, however, that the commitments constituted a limited portion of 

the required emissions reductions needed for attainment. The State’s and District’s unfulfilled 

commitments at the time of our 2010 proposal represent 41 percent of the PM2.5 reductions, 28 

percent of the NOx reductions, and 44 percent of the SOx emissions reductions estimated to be 

needed for attainment. We also found that the commitments, 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 two of the necessary findings, we were 

unable to propose to approve the attainment demonstration that relied in part on these 

commitments. We did, however, propose to approve 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 identified in their plans because they would 

strengthen the California SIP. 
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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 reductions come from a combination of District 

and State measures as well as adjustments to the baseline that reflect revisions to the economic 

forecasts that underlie the Plan’s estimates of future emissions levels.29

In the past two decades, the District has adopted or revised almost 40 prohibitory rules 

that limit emissions of NOx, SOx and/or particulate matter including most of the rule 

adoptions/revisions it committed to as part of the 2008 PM2.5 Plan. See Appendix B and Table F3. These rules include controls for boilers, fugitive dust sources, engines, woodburning, and open 

burning. The great majority of these rules and rule revisions are currently SIP approved and as 

such their emissions reductions are fully creditable in attainment and RFP demonstrations and 

for other CAA requirements, such as contingency measures. 

The 2005 baseline inventory includes uncreditable reductions from the District’s 

Rule 9510-Indirect Source Review (4.2 tpd NOx). 2008 PM2.5 Plan, Appendix B, Table B-2. 

While EPA has approved the rule into 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 federal 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. 
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Table F-9 

Summary of Reductions Needed for SJV’s PM2.5 Attainment Demonstration 

(tons per average annual day in 2014)

 Direct 

PM2.5

NOx SO2

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 categories of on- and off-road vehicles and 

engines, gasoline and diesel fuels, and numerous categories of consumer products. The State’s 

measures fall within two categories: measures for 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 Environmental 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. 
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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 measures 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 Vehicle Air Pollution Control Act of 1965 (which 

amended the CAA of 1963). In further CAA amendments, referred to as the Air Quality Act of 

1967 (Pub. L. 90-148), Congress allowed the State of California, and only California, a waiver of 

the Air Quality Act’s pre-emption of state emissions standards for new motor vehicles or new 

motor vehicle engines because of California’s pioneering efforts and unique problems. This was 

not changed when the statute was amended 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 the best means to protect the health of its citizens and the 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 emissions 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 California, a waiver of pre-emption (with certain 

exceptions) under criteria that mirror 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 vehicle emissions standards that are subject to a 

section 209(b) waiver without requiring California 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 credit for standards subject to the waiver 

process without requiring submittal of the standards as part of the SIP. In so doing, EPA has 

treated the California non-road standards similarly to the Federal non-road standards, which are 

relied upon, but not included in, various SIPs. 

Credit for Federal measures, including those 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 content 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, independently enforceable (by EPA and citizens), and 

quantifiable without regard to whether they are approved into a SIP, and thus EPA has never 
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found such measures to be “necessary or appropriate” 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 substitute for Federal measures, and like the Federal 

measures for which they substitute, EPA has historically 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 level of aggregate equivalence to the Federal Motor 

Vehicle Control Program (FMVCP). See section 209(b)(1). In this respect, 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 non-road vehicle and engine standards act as a 

partial backstop for corresponding California non-road 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, and thereby serve an anti-backsliding function 

similar in substance to those established for SIP revisions in CAA sections 110(l) and 193. 

Meanwhile, the growing convergence between California and EPA mobile source standards 

diminishes the difference in the emissions reductions 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 harmonization of EPA mobile source standards with the 

corresponding State standards, the Federal program 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-road standards for which EPA has issued the 

waiver. CARB has as long a history of enforcement of vehicle/engine emissions standards as 

EPA, and CARB’s enforcement program is equally 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 reductions from CARB’s rules in the same manner as 

EPA’s mobile source enforcement program lends assurance to other state’s SIPs 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 practice has been to give SIP credit for motorvehicle-related waiver measures by allowing California to include motor vehicle emissions 

estimates made by using California’s EMFAC (and its predecessors) motor vehicle emissions 

factor model in SIP inventories. EPA verifies the emissions reductions from motor-vehiclerelated waiver measures through review and approval of EMFAC, which is updated from time to 

time by California to reflect updated methods and data, as well as newly-established emissions 

standards. (Emissions reductions from EPA’s motor 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 and many other factors. The motor vehicle emissions estimates themselves 

combine EMFAC results with vehicle activity estimates, among other considerations. See the 

1982 Bay Area Air Quality Plan, and the related EPA rulemakings approving the plan (see 
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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 measures” and that are estimated through use of 

EMFAC are as verifiable as are the emissions reductions relied upon by states other than 

California in developing their SIPs 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 standards 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 notice of opportunity for public 

hearing and comment and then publishes a decision in the Federal Register following the public 

comment period. Once again, in substance, the process is similar to that for SIP approval and 

supports the argument that one hurdle (the waiver process) is all Congress intended for 

California standards, not two (waiver process plus SIP approval process). 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 Amendments to the CAA, is a general savings 

clause that provides for, among other things, EPA statutory interpretations 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 statute rendering EPA’s consistent 

prior treatment of California’s motor vehicle standards inconsistent with the Act. Moreover, 

where Congress intends state control measures that are otherwise pre-empted under title II of the 

 31 EPA’s historical practice in allowing 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 submittal. With respect to the 

CAC, the 1979 SIP revision states: “The following appendices are portions of the California Administrative Code. 

Persons interested in these appendices should refer directly 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). 
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Clean Air Act to be incorporated into SIPs, it has required that explicitly. See, e.g., section 

211(c)(4)(C) (State fuels regulations), section 211(m) (oxygenated gasoline regulations), and 

section 246 (centrally fueled fleets). Thus, in section 193, Congress effectively ratified EPA’s 

longstanding pre-1990 practice of allowing emissions reduction credit for California standards 

subject to the waiver process notwithstanding the absence of the standards in the SIP itself. 

As noted above, under the CAA Amendments of 1990, 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 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 agency interpretations and its subsequent revision 

of the statute to add subsection (e) without overruling EPA’s interpretation with respect to motor 

vehicle standards is further compelling evidence that the Agency correctly interpreted 

congressional intent with respect to crediting California requirements subject to a section 209 

waiver without requiring California to submit the standards themselves to EPA for approval as 

part of the California SIP. 

We believe that section 193 of the CAA, the general savings clause added by Congress in 

1990, effectively ratified our long-standing practice of granting credit for the California waiver 

rules because Congress did not insert any language into the statute 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 California with the broadest possible discretion in 

selecting the best means to protect the health of its citizens and the public welfare. Requiring the 

waiver measures to undergo SIP review in addition to the statutory waiver process is not 

consistent with providing California with the broadest possible discretion as to on-road and nonroad vehicle and engine standards, but rather, would add to the regulatory burden California 

faces in establishing and modifying such standards, and thus would not be consistent with 

Congressional intent. In short, we believe that Congress intended 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 acquiescence as to EPA’s treatment of the standards, the Act’s 

structure, evolution, and provision for the waiver of Federal pre-emption for California mobile 

source emissions standards, as discussed above, support EPA’s long-standing interpretation of 

the CAA to allow California to rely on emissions reductions resulting from waiver measures in 

SIPs, notwithstanding the waiver measures’ absence from the SIP itself. 

ii. Non-waiver measures

These measures include improvements to California’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 been SIP approved, can be found Appendix A. 

b. Enforceable Commitments 

As stated and shown in Table F-10 below, reductions in the projected baseline inventory 

resulting from the economic recession, changes to activity estimates and emissions factors, and 

measures already adopted by the District and State (both prior to and pursuant to the 2008 PM2.5
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Plan) and approved or proposed for approval by EPA provide more than 90 percent of the 

emissions reductions needed to demonstrate attainment of the 1997 PM2.5 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 respect to the 2008 SJV PM2.5 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 were 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 Valley nonattainment area were already subject to stringent rules 

prior to State Strategy’s and the Plan’s development, leaving fewer and more technologically 

challenging opportunities to reduce emissions. In the 2008 PM2.5 Plan and the 2007 State 

Strategy, the District and CARB identified potential control measures that could achieve the 

additional emissions reductions needed for attainment. See 2008 PM2.5 Plan, Appendix I and 

2007 State Strategy, Chapter 5. However, the timeline needed to develop, adopt, and implement 

these measures went many years beyond the April 5, 200832 deadline to submit the PM2.5

attainment plan. As discussed above, the District and State have made progress meeting their 

commitments but have not completely fulfilled them. Given these circumstances, we consider the 

District’s and CARB’s reliance in the 2008 PM2.5 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 requirements is approvable: (a) does the commitment 

address a limited portion of the statutorily-required program; (b) is the state capable of fulfilling 

its commitment; and (c) is the commitment for a reasonable and appropriate period of time. 

 

 32 The 2007 State Strategy was developed to address both the 1997 PM2.5 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. 
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Table F-10 

Reductions Needed for Attainment Remaining as Commitments 

based on SIP-Creditable Measures 

(tons per average annual day in 2014)

 Direct 

PM2.5

NOx SOx

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 reductions 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% 

 
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Table F-10 

Reductions Needed for Attainment Remaining as Commitments 

based on SIP-Creditable Measures 

(tons per average annual day in 2014)

 Direct 

PM2.5

NOx SOx

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 emissions 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 recent economic recession, are 3.0 tpd direct PM2.5 and 12.9 tpd 

NOx. When compared to the total reductions needed by 2014 for PM2.5 attainment in the SJV on 

a per-pollutant basis, these commitments represents approximately 13 percent of the direct PM2.5

and 4.5 percent of the NOx needed to attain the 1997 PM2.5 standards in the SJV. 

We believe that the reductions remaining as enforceable commitments in the 2008 PM2.5

Plan and 2007 State Strategy represent a limited portion of the total emissions reductions needed 

to meet the statutory requirement for attainment in the SJV and therefore satisfy the first factor. 

The level of reductions remaining as commitments 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 PM10 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). 
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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 and 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 progress in meeting its enforceable commitments 

for the San Joaquin Valley and several other nonattainment areas in California. Additional ongoing program that address locomotives and in-use agricultural equipment have yet to be 

quantified but are expected to reduce NOx and direct PM2.5 emissions in the SJV by 2014.34

The District has already exceeded its commitments for reducing NOx and SOx emissions 

and has substantially met its commitment to reduce direct PM2.5 emissions. See Table F-10. It 

also has already adopted rules (Rules 9510 and 4320) that are projected to achieve NOx

reductions of 5.8 tpd in 2014. These reductions, however, are not currently creditable to the 

attainment and RFP demonstrations. See Tables F- 4 and F-9. In addition, it is expecting to adopt 

later this year revisions to District Rule 4702 (Reciprocating Internal Combustion Engines) that 

are likely to achieve substantial NOx reductions by 2014. See SJVAPCD, Draft Staff Report For 

Draft Amendments To Rule 4702 (Internal Combustion 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 the feasibility studies currently underway at the 

District. 

Beyond the rules discussed above, both CARB 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 PM2.5 Progress Report, section 2.3 

Finally, the SJV is designated nonattainment for the 2006 24-hour PM2.5 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 State and District are capable of meeting their 

enforceable commitments to reduce emissions of direct PM2.5 and NOx by 2014 to the levels 

needed to attain the 1997 PM2.5 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 emissions to the levels needed to attain the 

1997 PM2.5 standards in the San Joaquin Valley, the 2008 PM2.5 Plan and 2007 State Strategy 

included an ambitious rule development, adoption, and implementation schedules, which both 

 34 See, for example, SJVAPCD; U.S. EPA; USDA, NRCS; and CARB; Statement 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. 
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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 and F-6 above. We, therefore, conclude that the 

third factor is satisfied. 

iv. Summary of Proposed Finding on Enforceable Commitments in the SJV 2008 PM2.5

SIP

EPA believes circumstances warrant the consideration of enforceable commitments as 

part of the attainment demonstration in the 2008 SJV PM2.5 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 PM2.5 standards in the SJV 

by 2015. We have found that the reductions that remain as enforceable commitments represent a 

limited portion of the overall reductions needed for attainment. We have also found that the State 

and District are capable of fulfilling their remaining commitments and that the commitments are 

for a time period that is both reasonable and appropriate to assure that the remaining reductions 

are in place prior to the attainment date of April 5, 2015. As a result of our findings here, EPA is 

proposing to accept enforceable commitments as part California’s strategy to attain the 1997 

PM2.5 NAAQS in the SJV. 

v. Proposed Action on Enforceable Commitments 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 PM2.5 Plan, to the extent that these commitments have not yet been 

fulfilled and to achieve specific aggregate emissions reductions of direct PM2.5, NOx and SOx by 

specific years as given in Table 6-3 of the 2008 PM2.5 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 revisions to the rule. Should the District adopt revision to the rule by the 

time of EPA’s final action on the Plan, EPA proposes 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 Progress Report, Appendix B and to achieve the total 

aggregate emissions reductions necessary to attain the 1997 PM2.5 standards in the SJV, whether 

these reductions are realized from the new measures, alternative control measures, incentive 

programs, or other actual emissions decreases 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 PM2.5 and 76 tpd NOx in the San Joaquin Valley by 2014 as 

given on page 21 of the 2009 State Strategy Status Report. 
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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 practicable but no later than the applicable attainment 

date. Under the PM2.5 implementation rule, this demonstration should consists of four parts: 

(1) technical analyses that locate, identify, and quantify sources of emissions that are 

contributing to violations of the PM2.5 NAAQS; 

(2) analyses of future year emissions reductions and air quality improvement resulting 

from already-adopted national and local programs, and from potential new local measures 

to meet the RACT, RACM, and RFP requirements in the area; 

(3) adopted emissions reduction measure with schedules for implementation; and 

(4) contingency measures required under 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) sections of this TSD. Requirements for parts 3 

and 4 are described in the control strategy (II.F.) and contingency measures (II.I.) sections of this 

TSD, respectively. In this section, we evaluate how these parts taken together provide for 

attainment of the 1997 PM2.5 NAAQS in the San Joaquin Valley as expeditiously as practicable 

but no later than the attainment date required by the CAA. 

2. Attainment Demonstration in the SJV 2008 PM2.5 Plan

The attainment demonstration in the 2008 PM2.5 Plan is in Section 9.1 “Attainment 

Outlook.” It is summarized in Table G-1 below. Table G-2 shows the contributions by the 

District and CARB to the control strategy in the 2008 PM2.5 Plan. 

Since adoption and submittal of the 2007 State Strategy and the 2008 PM2.5 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, proposed for approval, or granted a CAA section 209 

waiver by EPA. See Tables F-3 and F-6. In the 2011 Progress Report, CARB and the District 

have updated the emissions reductions expected from their adopted measures and resulting from 

changes to inventory and the economic recession. Tables G-3 shows 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. 

 
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Table G-1 

Summary of the SJV’s PM2.5 the Attainment Demonstration 

as Submitted June 2008 

(tons per average annual day in 2014)

Direct PM2.5 NOx SO2

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.

 
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Table G-2 

Summary of Control Strategy Reductions by Agency 

in the SJV 2008 PM2.5 Plan 

(tons per average annual day in 2014)

 Direct 

PM2.5

NOx SO2

Total reductions needed from baseline and 

control strategy measures to attain 22.7 284.2 1.8 

 Total reductions from control 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 PM2.5 Plan, Table 8-1. 

 
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Table G-3 

Summary of the SJV PM2.5 Attainment Demonstration Updated April 2011 

with Additional Adjustments 

 (tons per average annual day in 2014)

PM2.5 NOx SO2

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% 

 
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Table G-4 

Reductions Needed for Attainment Remaining as Commitments 

based on SIP-Creditable Measures

(tons per average annual day in 2014)

 Direct 

PM2.5

NOx SOx

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 reductions 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% 

 
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Table G-4 

Reductions Needed for Attainment Remaining as Commitments 

based on SIP-Creditable Measures 

(tons per average annual day in 2014)

 Direct 

PM2.5

NOx SOx

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 Attainment Demonstration in the SJV 2008 

PM2.5 Plan

EPA proposed to disapprove the attainment demonstration in the SJV 2008 PM2.5 Plan 

based on its proposed disapproval of the air quality 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 District’s unfulfilled commitments represented 

41 percent of the direct PM2.5 reductions, 28 percent of the NOx reductions, and 44 percent of the 

SO2 emissions reductions required for attainment. 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 demonstration, EPA must make several findings 

and approve the State’s requested attainment date. 

First, we must find that the demonstration’s technical bases—emissions inventories and 

air quality modeling—are adequate. As discussed above in sections II.A. and II.B., we are 

proposing to find that the emissions inventories and the air quality modeling on which the SJV 

2008 PM2.5 SIP’s attainment demonstration is based meet applicable EPA regulations and 

guidance and are an acceptable basis for the demonstration. 
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Second, we must find that the SIP provides for expeditious attainment through the 

implementation of all RACM and RACT on sources of direct PM2.5 and each PM2.5 attainment 

plan precursor. As discussed above in section II.D., we are proposing to approve the 

RACM/RACT demonstration in the SJV PM2.5 SIP. 

Third, EPA must find that the emissions reductions that are relied on for attainment are 

creditable. As discussed in section II.F., the 2008 PM2.5 SIP relies principally on adopted and 

approved/waived rules to achieve the emissions reductions needed to attain the 1997 PM2.5

standards in the SJV by April 5, 2015. The balance of the reductions is currently in the form of 

enforceable commitments that account for 13.2 percent of the direct PM2.5 and 4.5 percent of the 

NOx emissions reductions needed from 2005 levels 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 section II.F.4., we believe that circumstances here 

warrant the consideration of enforceable commitments and that the three criteria are met: 1) the 

commitments constitute a limited portion of the required emissions reductions, 2) both the State 

and the District have demonstrated their capability to meet their commitments, and 3) the 

commitment are for an appropriate timeframe. Based on these conclusions, we are proposing to 

allow the State to rely on these limited enforceable commitments in its attainment demonstration. 

Finally, for a PM2.5 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 demonstration for the area. As discussed above in section II.E., we 

believe that a five-year extension of the attainment date is appropriate given the severity of the 

nonattainment problem in the SJV and availability 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 attainment demonstration in 

the SJV 2008 PM2.5 SIP. 
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H. Reasonable Further Progress Demonstrations

1. Requirements for Reasonable Further 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 required 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 PM2.5 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 generally linear progress from the baseline year to the attainment 

year. Where a state requests an extension of the attainment deadline to 2014 or 2015, the state 

must additionally provide emissions 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 measures that provide for meeting the reasonable 

further progress milestones for the area, the timing of implementation of those measures, and the 

expected reductions in emissions of direct PM2.5 and all PM2.5 attainment plan precursors. See 

40 CFR § 51.1009(c). 

A state is also required to demonstrate in its 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 PM2.5 emission and each PM2.5 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 improvement in air quality by the milestone year as 

would be achieved under the 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 PM2.5

implementation rule in 40 CFR § 51.1009(f): 

(1) For direct PM2.5 emissions and each PM2.5 attainment plan precursor addressed in the 

attainment strategy, the full implementation reduction is calculated by subtracting the full 

implementation inventory from the baseline year inventory. The full implementation 

inventory is the projected RFP emissions inventory for the year preceding the attainment 

date, representing a level of emissions that demonstrates attainment. The baseline year 

inventory is the emissions inventory for the year used as the base year for the attainment 

demonstration (see 40 CFR § 51.1000). 

(2) For direct PM2.5 emissions and each PM2.5 attainment plan precursor addressed in the 

attainment strategy, a benchmark emissions reduction 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 baseline year to the milestone inventory year 

divided by the number of years from the baseline year to the full implementation year. 
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(3) The benchmark emissions level in the milestone year is calculated for direct PM2.5

emissions and each PM2.5 attainment plan precursor by subtracting the benchmark 

emissions reduction from the baseline year emission level. The benchmark RFP plan is 

defined as a plan that achieves benchmark emission levels for direct PM2.5 emissions and 

each PM2.5 attainment plan precursor addressed in the attainment strategy for the area. 

In comparing inventories between baseline and future years for direct PM2.5 emissions 

and each PM2.5 attainment plan precursor, the inventories 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 which the emissions inventories for direct PM2.5 emissions 

and each PM2.5 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 between emissions reductions of the direct PM2.5 emissions and 

each PM2.5 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 PM2.5 Plan

The RFP demonstration is in Chapter 8 of the 2008 PM2.5 Plan and is updated and revised 

in Appendix C of 2011 Progress Report. The demonstration addresses direct PM2.5, NOx, and 

SO2 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 implementation reductions, the first step in 

determining the RFP benchmarks under the PM2.5 implementation rule. 

Table H-2 provides the benchmark 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. The 2014 attainment year is 9 years from the 

2005 base year making the 2009 milestone date fraction 4/9 and the 2012 milestone date fraction 

7/9.

 
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Table H-1 

Full Implementation Reductions 

(tons per average annual day) 

 Direct PM2.5 NOx SO2

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 PM2.5 Plan, Table 8-1 

Table H-2 

Benchmark Calculations 

(tons per average annual day) 

 Direct PM2.5 NOx SO2

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 PM2.5 Plan, Table 8-2 
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3. November 2010 Proposed Action on the RFP Demonstration in the SJV 2008 PM2.5

Plan

Based on its proposed disapproval of the air quality modeling analysis and attainment 

demonstration, EPA proposed to disapprove the RFP demonstration in the SJV PM2.5 Plan. Air 

quality modeling establishes the emissions levels needed for attainment. These levels are also 

needed to determine what constitutes generally linear progress towards attainment 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 NOx emissions reductions, especially 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 District and State should address both these issues 

in any revisions to the SJV 2008 PM2.5 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 attainment 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 PM2.5 Plan describes in Chapter 6 (tables 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 measures, and the expected reductions in emissions 

of direct PM2.5 and the PM2.5 attainment plan precursors, NOx and SOx, 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 PM2.5 Inventory,” Table 3-

21 “Adjusted NOx Inventory,” and Table 3-3 “Adjusted SOx 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 find that neither VOC nor ammonia is a PM2.5

attainment plan precursor for attainment of the 1997 PM2.5 standards in the SJV (see section II.C 

of this TSD), the Plan does not need to provide an RFP demonstration for either precursor. 

40 CFR § 51.1009(f). 

In comparing inventories between baseline and future years for direct PM2.5 emissions 

and each PM2.5 attainment plan precursor, the inventories 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 PM2.5 emissions and each PM2.5 attainment plan precursor 

addressed in the Plan are derived as required by 40 CFR § 51.1009(f). 

In preparing its RFP demonstration, the State followed the procedures in by 

40 CFR § 51.1009(f) and correctly calculated the benchmark emissions levels. 

Using data from the 2011 Progress Report, we have evaluated the Plan’s past and 

projected controlled emissions levels against the 2009 and 2012 benchmark emissions levels 

adjusted to remove currently uncreditable reductions. See Table H-3. As can be seen from this 

table, controlled emissions levels for direct PM2.5, NOx, and SOx were below the benchmarks for 

2009, demonstrating that the SJV met its RFP targets in that year. For 2012, the projected 
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controlled emissions level for direct PM2.5 is only slightly above (by less than 5 percent) the 

benchmark and the projected controlled levels for NOx and SOx are substantially below the 

benchmarks. We believe that, overall, 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 PM2.5

SIP provides for reasonable further progress 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 Measures and Baseline Data 

(tons per annual average day) 

 Direct 

PM2.5

NOx SO2

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 estimated 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 estimated 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% 
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Table H-4 

Adjustments to Control Measures Reductions for the RFP Demonstration

(tons per annual average day) 

 2009 2012 

NOx

Direct 

PM2.5

NOx

Direct 

PM2.5

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 PM2.5 SIP’s RFP 

Demonstrations 

As discussed in section II.A. of this TSD, CARB has updated the inventories for several 

mobile source categories including off-road equipment and heavy duty diesel trucks and 

estimates that these updates reduce the 2005 base year inventory by approximately 6 percent for 

NOx and 5 percent for PM2.5. CARB Progress Report supplement, Attachment 1. The State, 

however, did not revise the RFP demonstration in the SJV 2008 PM2.5 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. 

 
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Table H-5 

Estimated Effect of Changes to the 2005 Base Year 

Inventory on the RFP Demonstration – Milestone Calculation 

(tons per average annual day)

 Direct 

PM2.5

NOx SO2

A. Base year inventory 86.0 575.4 26.4 

B. 

Adjusted base year inventory assuming 4.7% 

reduction in PM2.5 and 6.1% reduction in NOx 

(no change to SO2) 

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 needed 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% 

 
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Table H-6 

Estimated Effect of Changes to the 2005 Base Year 

Inventory on RFP Demonstration 

 (tons per annual average day)

 Direct 

PM2.5

NOx SO2

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 PM2.5 Implementation Rule 

In June 2007, a petition to the EPA Administrator was filed on behalf of several public 

health and environmental groups requesting reconsideration of several provisions in the PM2.5

implementation rule. See Earthjustice, “Petition for 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 discussed 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 PM2.5 plan does not rely on out-of-area emissions 

reductions to demonstrate RFP. 
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I. Contingency Measures

1. Requirements for Contingency Measures

Under CAA section 172(c)(9), all PM2.5 attainment plans must include contingency 

measures to be implemented if an area fails to meet RFP (RFP contingency measures) and 

contingency measures to be implemented if an area fails to attain the PM2.5 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 milestone or correct continuing nonattainment. 

The principle requirements for contingency measures are: 

• Contingency measures must be fully adopted rules or control measures that are 

ready to be implemented quickly upon failure to meet RFP or failure of the area to 

meet the standard by its attainment date. 

• 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 emissions reductions equivalent to 

approximately one year of reductions needed for RFP calculated as the overall 

level of reductions needed to demonstrate 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 continues to be applicable: 

States must show that their contingency measures can be implemented without further 

action on their part and with no additional rulemaking actions such 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 notifies the State of its 

failure. 

Contingency measures can include both Federal, state and local measures already 

scheduled for implementation or already implemented. The CAA requires contingency measures 

that provide for additional emissions reductions that are not relied on for RFP or attainment and 

are not included in these demonstrations. In other words, contingency measures are intended to 

achieve reductions over and beyond 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 under this interpretation. See, for example, 

62 FR 15844 (April 3, 1997) (direct final rule approving Indiana ozone SIP revision); 

62 FR 66279 (December 18, 1997) (final rule approving Illinois ozone SIP revision); 
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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 PM2.5 Plan and 2011 Progress Report

Contingency measures in the 2008 PM2.5 SIP are composed of several types: a new 

commitment 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 specifically-identified implemented rules that are not otherwise relied 

on in the attainment and RFP demonstrations. 

Contingency measures are discussed in Section 9.2.2. of the Plan, on page 29 of the 

CARB Staff Report, and Appendix A of the CARB Resolution 08-28 adopting the Plan. Updated 

information on both the RFP and attainment contingency measures for the SJV 2008 PM2.5 Plan 

is provided in the 2011 Progress Report and Supplement. This information includes revisions to 

the RFP demonstration that shows excess reductions and updated estimates of the reductions in 

2015 from the State’s mobile source control program. See 2011 Progress Report, Appendix A, 

p. 2, Appendix C, Table C-1, and CARB Progress Report supplement, Attachment 2. 

CARB also discusses the contingency measure provision in Appendix D of the 2007 

State Strategy; however, this discussion addresses the contingency measure provisions for 

California’s 8-hour ozone plans and not the PM2.5 plans. 

a. New Commitment 

As a contingency measure, the District proposes to request that CARB accelerate the 

adoption and/or implementation of any remaining CARB control measures that have not yet been 

adopted or fully implemented, to the extent feasible. This request would be made through a 

formal District Governing Board resolution adopted at a regularly-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 PM2.5 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 version of the Plan, the method 

used to calculate emissions reductions needed to meet RFP benchmarks withheld a certain 

percentage of those reductions for contingency purposes: 1 percent of the baseline PM2.5

inventory and 3 percent of the baseline NOx inventory. These percentages equated to roughly 1 

tpd direct PM2.5 and 17 tpd NOx being reserved for contingency. No reserve was included for 

SOx because SOx emissions levels were projected to be below the applicable benchmarks. See 

2008 PM2.5 Plan, p. 8-4. 

The 2011 Progress Report updates the RFP demonstrations in the 2008 PM2.5 Plan. See 

2011 Progress Report, Table C-1. The updated demonstration does not include a contingency 

measure reserve but rather shows that controlled emissions levels of NOx and SOx are or will be 

below the required RFP benchmarks. SOx reductions that are in excess of those needed to meet 
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RFP and contingency are reserved for PM2.5 contingency measures at an interpollutant trading 

ratio of 1 tpd SOx to 1 tpd direct PM2.5. See 2011 Progress Report, Appendix A, p. 2 and (for the 

trading ratio), SJV PM2.5 Progress Report, Table 2-2. 

Post-2014 Emissions Reductions – The 2008 PM2.5 Plan relies on the incremental emissions 

reductions that will occur in 2015 from CARB’s mobile source program to provide for 

contingency measures for failure to attain. See p. 9-9. The Plan does not provide an estimate of 

that these reductions. CARB initially estimated the NOx reductions at 21 tpd in 2015. See CARB 

Staff Report, p. 29. 

CARB updated the estimated incremental emissions reductions that will occur in 2015 

from its mobile source program including the reductions 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 SO2 and 21 tpd NOx. 

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 NOx located in the a severe or extreme ozone nonattainment 

that fails to attain the ozone standard by the area’s applicable attainment date to pay a fee to the 

state in each calendar year following the attainment year for all emissions above a baseline 

amount until the area attains the ozone standard. 

The CAA does not specify how states may spend or allocate the fees 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 for additional ozone precursor emissions reductions 

from stationary and/or mobile sources or for other purposes aimed at reducing ambient ozone 

concentrations in the affected area.36 In the 2008 PM2.5 Plan, the District indicated that it would 

use any funds collected under Rule 3170 (should the area fail to timely attain the 1-hour ozone 

standard and the rule be triggered) to implement other pollution control programs. See 2008 

PM2.5 Plan, p. 9-8. 

The District has recently revised its CAA section 185 program to create an equivalent fee 

program as allowed under EPA’s policy. See ftn. 36. The District’s section 185 equivalency 

program includes not only revisions to Rule 3170 but also a vehicle registration surcharge of 

$12. The District expects to begin collecting vehicle registration fees in late 2011 and Rule 3170 

fees in 2012. See SJVAPCD, Final Draft Staff Report Draft Amendments to Rule 3170 

(Federally Mandated Ozone Nonattainment Fee), April 21, 2011. No estimate of emissions 

reductions expected from the section 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. 
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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 NOx limits, added 

SO2 and PM10 limits, and removed certain exemptions. While the District committed to adopt 

revisions to Rule 4307 as part of the control strategy in the 2008 PM2.5 Plan’s control strategy, it 

had not included emissions reductions from these 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 Burning Heaters, to incorporate a contingency 

provision in section 5.6.5. This provision states that: 

On or after sixty days following the effective date of EPA final rulemaking that the San 

Joaquin Valley Air Basin has failed to attain the 1997 PM2.5 National Ambient Air 

Quality Standards by the applicable deadline, the [air pollution control officer] shall 

notify the public of an Episodic Curtailment for a geographic region whenever a PM2.5

concentration of 20 μg/m3

 or greater or a PM10 concentration of 135 μg/m3 is predicted 

for the geographic region. 

This provision lowers the trigger for calling an episodic curtailment from the existing 

30 μg/m3

. During an episodic curtailment, the operation of wood burning fireplaces, wood 

burning heater, or outdoor wood burning device (except when it is the sole source of heat) is 

prohibited. See Rule 4901, section 5.6.1. In its supporting documentations for this rule, the 

District did not quantify the emissions reductions expected should 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, 2011. Proposed revisions to this rule include 

lowering the applicability threshold of the rule to engines 25 hp and greater (from 50 hp) and 

lowering NOx, VOC, and carbon monoxide limits for all spark-ignition I/C engines that are used 

in non-agricultural operations and making these revisions effective January 1, 2014. See 

SJVAPCD, Draft Staff Report For Draft Amendments To Rule 4702 (Internal Combustion 

Engines–Phase 2), September 9, 2010. While the District committed to adopt revisions to Rule 

4702 as part of the control strategy in the 2008 PM2.5 Plan’s control strategy, it did not included 

emissions reductions from these revisions in either the original RFP or attainment demonstration. 

Because of this, the reductions could be considered excess to these demonstrations. 

Incentive Funds – The District has received and expects to continue to receive significant 

funding for its incentive grant programs from sources that include the State’s Carl Moyer 

Program, Proposition IB Goods Movement Emission Reduction Program, vehicle registration 

surcharges, its Indirect Source Review Rule (Rule 9510), and the federal Diesel Emissions 

Reduction Act. Through its incentive programs, the District has funded and continues to fund 

numerous projects that reduce emissions in the Valley. See 2008 PM2.5 Plan, Section 6.5 and SJV 

PM2.5 Progress Report, section 2-3. For various reasons, mainly related to their SIP creditability, 

the emissions reductions generated from these incentive-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, and reporting requirements to ensure that the all 

incentive-based reductions achieved by the District meet EPA requirements and guidance for SIP 
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creditability.37 At the time the Plan was submitted in 2008, the District expected these 

requirements would be in place in time for the 2009 and 2012 RFP milestone years so that the 

emissions reductions from its various incentive programs could be used to meet the contingency 

measure requirement and for other SIP-related purposes. 

The District currently estimates that there are $112 million of incentive funds available to 

invest in the SJV for the 2010-2011 fiscal year. See SJV PM2.5 Progress Report, p. 2-4. This is in 

addition to over $301 million received from 1998 until 2010. See SJV PM2.5 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 Contingency Measures in the SJV 008 PM2.5

SIP

In 2010, we proposed to disapprove the RFP and attainment contingency measures in the 

2008 PM2.5 Plan. We found that, although the Plan included suggestions for several potentially 

approvable contingency measures as well as several 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 determine if the Plan’s 

contingency measure provisions provided reductions roughly equivalent to one year’s worth of 

RFP. See 75 FR 74518, 74539 and Section II.J of the 2010 Draft TSD. 

4. Evaluation and Conclusions

Under the PM2.5 implementation rule, a state must submit contingency measures that 

meet the requirements of CAA section 172(c)(9) and provide for the equivalent 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 year (2014). 72 FR 20586 at 20643. We show this 

calculation for SJV 2008 PM2.5 Plan in Table I-1 below. 

We are not evaluating the provisions in the 2008 PM2.5 SIP that address contingency 

measures for failure to meet the 2009 RFP benchmarks. Information available to EPA and the 

public shows that SJV met its 2009 benchmarks for direct PM2.5, NOx, and SOx. 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 benchmark no longer have any meaning or effect 

under the CAA and therefore do not require any review 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 milestone. Failure to meet the 2009 benchmark would 

have required California to revise the SJV PM2.5 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 PM2.5 Plan, the District estimated that the $90 million per year of incentive funds then 

available to the SJV could provide 3.6 tpd of NOx emissions each year, accumulating year to year (that is, after five 

years, for example, the cumulative reduction would be 18 tpd). See 2008 PM2.5 Plan, p. 9-9. 
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revision to the SJV PM2.5 SIP that shows that the SIP continues 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 PM2.5 NOx SOx

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 shortfalls in RFP and attainment would be 

appropriate given the contribution of mobile sources to PM2.5 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 PM2.5 Plan would require multiple steps to implement 

including the adopting of a resolution by the 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-standing policies interpreting this section, 

contingency measures must require minimal additional rulemaking by the state and take effect 

within a few months of a failure to meet an RFP target or to attain. The District’s proposed 

commitment to request accelerated implementation 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 NOx and SOx will be below the required RFP benchmarks in 2012. These surplus 

reductions are available use as NOx and SOx contingency measures for the 2012 RFP milestone. 

The 2011 Progress Report reserves the SOx reductions that are in excess of those needed to meet 

RFP and contingency as PM2.5 contingency measures, using an interpollutant trading ratio of 

1 tpd SOx to 1 tpd direct PM2.5 to show equivalency. See 2011 Progress Report, Appendix A, 

p. 2. We do not, however, agree at this time with the use of an interpollutant trading ratio of 1:1 
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SOx to direct PM2.5 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 emission 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 NOx, 

and 3 tpd SO2. See CARB Progress Report supplement, Attachment 2. 

Table I-2 

Excess Reduction in Updated 2012 RFP Demonstrations 

 Available for Use As Contingency Measures 

(tons per annual average day)

 Direct PM2.5 NOx SOx

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 SOx proposed to substitute for 

PM2.5

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 collect fees under its CAA section 185 program in 

late 2011. It is the District’s intent to use the collected fees in its incentives grant program. See 

SJVUAPCD Governing Board Resolution, No. 10-10-14, October 21, 2010, p. 5. We address the 

use of incentive funds as contingency measures below. 

Rule 4307 – Reductions from Rule 4307 are now included 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 revisions to Rule 4702. Because this rule is not 

currently adopted or approved by EPA, it cannot be used for contingency 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. 
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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 implemented within 60 days of an 

EPA finding that the area has failed to attain the PM2.5 standards. We approved the October 2008 

revision of Rule 4901, including the contingency provision, into the California SIP on 

November 10, 2009, 74 FR 57907. 

Incentive Funds - As noted previously, the District has several incentive grant programs which 

use funds collected from a number of sources (including the District’s CAA section 185 

program). These grant programs have the potential to generate considerable emissions 

reductions. While neither the CAA nor EPA policy bar the use of emissions reductions from 

incentive programs to meet all or part of an area’s contingency measure obligation, the incentive 

programs must assure that the reductions are surplus, quantifiable, enforceable, and permanent in 

accordance with EPA’s guidance. See “Improving Air Quality with Economic Incentive 

Programs,” EPA-452/R-01-001 (January 2001). 

The 2008 PM2.5 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 requirement. Therefore, we are unable to determine if 

they are SIP creditable or sufficient to provide in combination with other measures the roughly 

one-year’s worth of RFP needed. For these reasons, 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 PM2.5 Plan. 

The 2008 PM2.5 Plan includes suggestions for several potentially approvable contingency 

measures as well as several measures that do not meet the CAA’s minimum requirements (e.g., 

no additional rulemaking, quick implementation). For many of the potential approvable 

contingency measures, the Plan neither provides sufficient information for us to determine if the 

emissions reductions are SIP creditable (e.g., those from incentive grant programs) nor quantifies 

the expected emissions reductions from them. 

The 2011 Progress Report, however, does show that 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 equivalent 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 requirements for RFP contingency measures.40

As also shown on Tables I-3 and I-4, the continuing implementation of the State’s mobile 

source program in combination with the District’s contingency measure in Rule 4901, if 

triggered, will reduce emissions substantially in 2015 (the year after the attainment year of 

 40 In the 2011 Progress Report, the State asserts that these reductions are equal to at least one-year’s worth 

of RFP when considered on a PM2.5 equivalency basis; however, to make this showing, the State relies in part on an 

interpollutant trading ratio of 1 ton of SOx reductions to 1 ton of PM2.5 reductions. As discussed in section II.B.4. of 

this TSD, there is insufficient technical support for this ratio and EPA is proposing to not allow its use as part of the 

2008 PM2.5 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 meet a CAA requirement. 
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2014). However, these reductions do not provide emissions reductions equivalent to 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 requirements for attainment contingency measures. 

Based on the above evaluation, EPA proposes to disapprove the RFP and attainment 

contingency measures in the SJV 2008 PM2.5 SIP pursuant to CAA section 172(c)(9) and 

40 CFR § 51.1012. 

Because we are proposing to approve the RFP 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 disapproval would result in a conformity freeze, under which only 

projects in the first four years of the most recent conforming Regional Transportation Plan and 

Transportation Improvement Programs can proceed. 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 contingency measures would not result in a 

transportation conformity freeze in the San Joaquin PM2.5 nonattainment area. 
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Table I-3 

Summary of Approvability of Contingency Measures from the SJV 2008 PM2.5 P

Measure 

RFP or 

Attainment 

Contingency 

Measure? 

Approvable as a 

Contingency 

Measure? 

Comment 

Tons per Average 

Year Direct PM2.5 

Request CARB to expedite implementation of mobile source controls 

Both No Requires additional rulemaking, no short term reductions N/A 

Ozone Nonattainment Area Fee 

2012 RFP 

milestone/ 

Attainment 

No 

Reductions are not SIP creditable (see Incentive funds—currently not SIP creditable) 

No

Incentives Funds – currently SIP creditable Both Yes NoIncentive Funds – currently not SIP creditable Both No Reductions are not SIP creditable NoExcess Reductions in RFP Demonstration RFP Yes 2012 0 “New” Post Attainment Year Reductions Attainment Yes 2015 0.0 Revisions to Rule 4307 

2012 RFP 

milestone/ 

Attainment 

No Reductions assumed in RFP and attainment demonstrations 2012 N/A 

2015 N/A 

Revisions to Rule 4702 Attainment No Rule not adopted 2015 – Contingency provision in Rule 4901 Attainment Yes 2015 1.61 

1 Phone conversation, Jessi Fierro, SJVAPCD, and Frances Wicher, EPA, August 26, 2010, value is average annual day.
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Table I-4 

Summary of Reductions from Contingency Measures 

(tons per average annual day) 

 Direct PM2.5 NOx SOx

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 0.2 
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J. Adequacy of the Motor Vehicle Emissions Budgets in the SJV 2008 PM2.5

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 reducing 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 will 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 Administration (FHWA) or Federal Transit 

Administration (FTA) funding or approval are subject to the EPA’s transportation conformity 

rule, codified at 40 CFR part 93, subpart A. Under this rule, metropolitan planning organizations 

(MPOs) in nonattainment and maintenance 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 demonstration 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 control 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 established for specific years and 

specific pollutants or precursors. 

PM2.5 attainment and RFP plans should identify budgets for direct PM2.5 and PM2.5

attainment plan precursors. All direct PM2.5 SIP budgets should include direct PM2.5 motor 

vehicle emissions from tailpipe, brake wear, and tire 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 included in the direct PM2.5 budget. See 40 CFR § 93.102(b) and 

§ 93.122(f) and the conformity rule preamble at 69 FR 40004, 40031–40036 (July 1, 2004). 

MPO may use budgets in a submitted but not-yet 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 conformity adequacy requirements of 40 CFR § 93.118(e)(4) and be 

approvable under all pertinent SIP requirements. In addition, the budgets must reflect all of the 

motor vehicle control measures contained in the attainment and RFP demonstrations. See 

40 CFR § 93.118(e)(4)(v). 
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2. Motor Vehicle Emissions Budgets in the SJV 2008 PM2.5 SIP

a. MVEB Submitted in SJV 2008 PM2.5 Plan (submitted June 2008) 

The SJV 2008 PM2.5 Plan included budgets for direct PM2.5 and NOx for the attainment 

year of 2014 and the RFP years of 2009 and 2012. See 2008 PM2.5 Plan, Section 7.2.2 and 

Appendix C. The direct PM2.5 budgets included tailpipe, brake wear, 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 PM2.5 levels in the Valley. 2008 PM2.5 Plan, p. 7-5. 

No budgets for SOx were included because on-road emissions of SOx were also considered 

insignificant. Id. No budgets were included for either VOC or ammonia because neither was 

considered a PM2.5 attainment plan precursor in the 2008 PM2.5 Plan. See section II.C of this 

TSD. 

b. Updated MVEB Submitted in 2011 Progress Report 

CARB submitted updated MVEB for the San Joaquin Valley and their documentation in 

Appendices D and A, respectively, of the 2011 Progress Report. See Tables J-1 and J-2 below. 

The updated MVEB are for direct PM2.5 and NOx for the RFP year of 2012 and the attainment 

year of 2014. No budgets were included for the RFP year of 2009 because it is no longer 

applicable as a conformity analysis year. Additional information associated with the motor 

vehicle emission budget calculations were provided in Attachment 4 of CARB Progress Report 

supplement. 

This submittal also includes a proposed trading mechanism for transportation conformity 

analyses that would allow future decreases in NOx emissions from on-road mobile sources to 

offset any on-road increases in PM2.5, using a NOx:PM2.5 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 established the relative contribution of each PM2.5 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 ensure that the trading mechanism 

does not impact the ability of the SJV to meet the NOx budget, the NOx emissions reductions 

available to supplement the PM2.5 budget would only be those remaining after the 2014 NOx

budget has been met. Clear documentation of the calculations used in the trade would be 

included in the conformity analysis. See 2011 Progress Report, Appendix D, footnote to 

Table D-2. 

 
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Table J-1 

Updated PM2.5 MVEB for the San Joaquin Valley 

(tons per average annual day)1

County 

2012 2014 

PM2.5 NOx PM2.5 NOx

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 PM2.5 Plan. These baseline inventories continue to be based on the activity data 

(e.g. vehicle miles travelled) provided by the SJV 2008 PM2.5 Plan as submitted in June 2008. 

The first adjustment, “State Strategy Adjustment,” incorporates the impacts 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 heavy duty truck idling 

regulations, smog check improvements, reformulated gasoline and District Rule 9510 Indirect 

Source Rule (SJV ISR rule). The second adjustment, “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 Carl Moyer program and benefits from the 

SJV District’s Rule 9310 for School Buses. 

 
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Table J-2 

Calculation of the Updated PM2.5 MVEB 

for the San Joaquin Valley 

(tons per average annual day) 

County 

 2012 2014 

PM2.5 NOx PM2.5 NOx

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 21.5 
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Table J-2 

Calculation of the Updated PM2.5 MVEB 

for the San Joaquin Valley 

(tons per average annual day) 

County 

 2012 2014 

PM2.5 NOx PM2.5 NOx

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 CARB41 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 Federal 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 emissions reductions from the rule should not be 

credited in any attainment and rate of progress/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 reductions 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, “Proposed 8-Hour Ozone State Implementation Plan 

Revisions and Technical Revisions to the PM2.5 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/2007sip.htm. These revised updated MVEB are 

given in Table J-3 below. The technical revisions corrected data entry 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 calculated. Baseline and adjustments are the same 

as those for the updated MVEB in the 2011 progress 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. 
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reductions from the ISR rule. CARB expects to adopt these revised updated budgets at its July 

21, 2011 board meeting. See CARB, “Notice of Public Hearing to Consider the Approval of 

Proposed State Implementation Plan Revisions for the 8-Hour Ozone and Minor Technical 

Revisions to the PM2.5 SIP Transportation Conformity Budgets,” June 20, 2011. 

Table J-3 

Revised Updated PM2.5 MVEB for the San Joaquin Valley 

(tons per average annual day)1

County 

2012 2014 

PM2.5 NOx PM2.5 NOx

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). 

 
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Table J-4 

Calculation of the Revised Updated PM2.5 MVEB 

for the San Joaquin Valley 

(tons per average annual day) 

County 

 2012 2014 

PM2.5 NOx PM2.5 NOx

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 21.6 
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Table J-4 

Calculation of the Revised Updated PM2.5 MVEB 

for the San Joaquin Valley 

(tons per average annual day) 

County 

 2012 2014 

PM2.5 NOx PM2.5 NOx

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 

PM2.5 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 because they lacked specificity or 

enforceability of the emissions reductions relied on to demonstration attainment and therefore 

did not meet the requirements of our adequacy criteria at 40 CFR § 93.118(e)(4)). See letter 

Deborah Jordan, EPA Region 9, to James Goldstene, CARB, “RE: Adequacy Status of San 

Joaquin Valley PM2.5 Reasonable Further Progress and Attainment Plan Motor Vehicle 

Emissions Budgets,” April 23, 2010. We published 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/stateresources/transconf/pastsips.htm.

b. 2010 Proposed Action on the MVEBs in the SJV 2008 PM2.5 SIP 

The April 2010 adequacy determination was based on our preliminary review of the plan. 

During our subsequent more in depth review of the Plan, we proposed to determined that the 

2008 PM2.5 Plan did not provide for reasonable further progress as required by 

CAA section 172(c)(2). 75 FR 74518, 74537. As a result of this determination, we proposed to 
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disapprove the budgets for the RFP years. Specifically, the budgets, when considered together 

with all other emission sources, are inconsistent with applicable requirements 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 PM2.5 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 budgets against our adequacy 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 prior 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 happen at an earlier date. We will 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 PM2.5 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 PM2.5 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 currently 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 for the ISR rule as well as to corrected data 

entry errors in the budget calculations. Once adopted and a complete submittal made, the revised 

updated MVEB should be consistent with the attainment and RFP demonstrations and meet all 

other applicable statutory and regulatory requirements including meeting the adequacy criteria in 

§93.118(e)(4). EPA proposes, therefore, to approve 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 find inadequate and disapprove the updated MVEB 

contained in the 2011 Progress Report. If we disapprove the updated MVEB, a conformity freeze 

would take effect upon the effective date of the 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 conforming 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 inadequate and disapproving them, a final action approving 

replacement budgets, or a final action disapproving replacement budgets becomes effective. 
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EPA- Region 9 

Table J-2 

Evaluation of the Proposed Revised Updated Motor Vehicle Emissions Budge

June 2011 

Adequacy Review Criteria 

(40 CFR part 93) 

Is Criterion 

Satisfied? Reference in SIP Document/Co

Sec. 93.118(e)(4)(i) 

The plan was endorsed by the Governor (or designee) and was subject to a public hearing. 

Y 

See section I.C. and I.D. of this TSD. Proposed revisbeen noticed for public hearing. See CARB, “Notice Consider the Approval of Proposed State Implementathe 8-Hour Ozone and Minor Technical Revisions to 

Transportation Conformity Budgets,” June 20, 2011. 

Sec. 93.118(e)(4)(ii) 

The plan was developed through consultation with federal, state and local agencies; full implementation plan documentation was provided and EPA’s stated concerns, if any, were addressed. 

Y 

The 2008 PM2.5 Plan was developed through consulta

and local agencies which place with the San Joaquin consultation working group (the Model Coordinating the consultation group include: EPA, FHWA, FTA, CJoaquin Valley Unified Air Pollution Control Districcounty’s Metropolitan Planning Organization (MPO)Report and its Appendices A and D which describe thmade available to the MPOs and other agencies for reduring the public comment period. EPA received a co

Progress Report, the SJV 2008 PM2.5 Plan and draft S

provided no written comments. However, in response additional information, CARB provided Attachment Report supplement. CARB has now posted additionabudgets for public comment. 

Sec. 93.118(e)(4)(iii) 

The motor vehicle emission budgets are clearly identified and precisely quantified. 

Y 

The updated MVEB for 2012 and 2014 are clearly idquantified in Appendix A (Table A-2) of the 2011 Prdescribed in Attachment A of the May 18, 2011 lettecontrol measures that were already adopted at the tim2011 Progress Report on April 28, 2011. 2011 Progrep. 3. CARB did not update the MVEB for 2009 becaulonger needed for any conformity determination in thReport, Appendix D. 
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Table J-2 

Evaluation of the Proposed Revised Updated Motor Vehicle Emissions Budge

June 2011 

Adequacy Review Criteria 

(40 CFR part 93) 

Is Criterion 

Satisfied? Reference in SIP Document/Co

Sec. 93.118(e)(4)(iv) 

The motor vehicle emissions budget(s), when considered together with all other emission sources, is consistent with applicable requirements for reasonable further 

progress and attainment. 

Y 

EPA has concluded that the updated budgets for the yconsidered together with all other emission sources arequirement to demonstrate reasonable further progreand 24-hour PM2.5 standards. This finding is based on 

RFP demonstrations in Appendix C (Table C-1) of thAs documented in Section II.H. of this TSD, EPA is revised RFP demonstration. EPA has concluded that the updated budgets for the yconsidered together with all other emission sources arequirement to demonstrate expeditious attainment ohour PM2.5 standards. This finding is based on review 

demonstrations in the 2011 Progress Report. As docuof this TSD, EPA is proposing to approve the revised demonstration. The updated MVEBs for direct PM2.5 do not include 

entrained road dust (paved and unpaved) or road/tranThe 2008 SJV PM2.5 plan, pp. 7-5 & 7-6, concluded t

contributors to PM2.5 emissions in the SJV. EPA agre

dust is not a significant contributor to PM2.5 emissioValley. The 2011 Progress Report does not include budgets f

SOx because on-road vehicles are projected to be an i

PM2.5 levels in the SJV in both 2012 and 2014. 2008 

The 2011 Progress Report also does not include budg

precursors VOC and ammonia because they are not cPM2.5 precursors in the SJV and thus are not required 

attainment. See SJV PM2.5 plan, pp. 7-4 & 7-5 and se

CARB will be submitting revisions to the updated Memissions reductions associated with the SJV ISR Ruentry errors. Once revised the updated MVEB’s will creditable RFP and attainment demonstrations. CARcomment the revised updated budgets. 
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Table J-2 

Evaluation of the Proposed Revised Updated Motor Vehicle Emissions Budge

June 2011 

Adequacy Review Criteria 

(40 CFR part 93) 

Is Criterion 

Satisfied? Reference in SIP Document/Co

Sec. 93.118(e)(4)(v) 

The plan shows a clear relationship among the emissions budget(s), control measures and the total emissions inventory. 

Y 

The emissions inventory for all stationary, area, on-romobile sources, and their relation to control measureexisting measures are described in Appendix A of 20Appendix B of the SJV 2008 PM2.5 Plan as updated b

The final inventories incorporating the reductions frogiven in Tables B-1 and B-2 in Appendix B to the SJ

Appendix A, D and E of the 2011 Progress Report anCARB Progress Report supplement. 

Sec. 93.118(e)(4)(vi) 

Revisions to previously submitted control strategy or maintenance plans explain and document any changes to any previous submitted budgets and control measures; impacts on point and area source emissions; any changes to established safety margins (see §93.101 for definition), and reasons for the changes (including the basis for any changes to emission factors or estimates of vehicle miles traveled). 

Y 

CARB submitted revisions to the attainment and RFP SJV 2008 PM2.5 Plan as part of the 2011 Progress Re

D and Attachment A in CARB Progress Report suppspecifically documents the changes in the planning fatruck inventory and the revisions to the control measuupdated budgets from the original budgets. EPA analincluded in these reports to confirm that the updated with previous MVEB and revised as documented Note that CARB did not update the MVEB for 2009 are longer needed for any conformity determination iReport, Appendix D. CARB will be submitting revisions to the updated Memissions reductions associated with the SJV ISR Ruentry errors. 
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Table J-2 

Evaluation of the Proposed Revised Updated Motor Vehicle Emissions Budge

June 2011 

Adequacy Review Criteria 

(40 CFR part 93) 

Is Criterion 

Satisfied? Reference in SIP Document/Co

Sec. 93.118(e)(5) 

EPA has reviewed the State’s compilation of public comments and response to comments that are required to be submitted with any implementation plan. 

Y 

The 2008 PM2.5 Plan contains public comments and S

appendix J to the Plan. Additional verbal comments wadoption public hearings held by the SJVUAPCD anincluded as attachments to the June 2008 SIP submittverbal comments were received during the public comhearing on the 2011 Progress Report. See CARB Reshave reviewed the compilation of comments and respresponses (where provided) to be acceptable. No issuaffected our adequacy finding remain unanswered. 
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4. Proposed Action on Trading Mechanism

As noted above, CARB included a trading mechanism 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 NOx emissions from on-road mobile sources 

to offset any on-road increases in PM2.5, using a NOx:PM2.5 ratio of 9:1. As proposed by CARB, 

the trading mechanism would only be used, if needed, for conformity analyses for years after 

2014. Also, to ensure that the trading mechanism does not impact the ability of the SJV to meet 

the NOx budget, the NOx emissions reductions available to supplement the PM2.5 budget would 

only be those remaining after the 2014 NOx budget has been met. The trading mechanism will be 

implemented with the following criteria. The trading applies only to: 

• Analysis years after the 2014 attainment year. 

• On-road mobile emission sources. 

• Trades using vehicle NOX emissions reductions in excess of those needed to meet 

the NOx budget. 

• Trades in one direction from NOX to direct PM2.5. 

• A trading ratio of 9 tpd NOX to 1 tpd PM2.5. 

Clear documentation of the calculations used in the trade would be included in the 

conformity analysis. See 2011 Progress Report, Appendix D, footnote to Table D-2. 

EPA has reviewed the 9:1 NOx:PM2.5 ratio as discussed in section II.D.4. of this TSD, 

and finds it appropriate ratio for trading between NOx and direct PM2.5 for transportation 

conformity purpose in the San Joaquin Valley for the 1997 PM2.5 NAAQS. The method 

discussed in the documentation appears to be adequate for purposes of assessing the effect of 

area-wide emissions changes, such as are used in conformity budgets. 

EPA believes that the 2008 PM2.5 Plan as revised by the 2011 Progress Report includes 

an approvable trading mechanism for determining transportation conformity after 2014. EPA is 

proposing to approve the trading mechanism and all of the criteria included in the footnote to 

Table D-2 as enforceable components of the transportation conformity program for the SJV for 

the 1997 PM2.5 NAAQS. EPA is also proposing to approve the use of this ratio in transportation 

conformity determinations for the 2006 24-hour PM2.5 NAAQS but only until such time EPA 

finds adequate or approves budgets developed specifically for the 2006 standard. 
Appendix A – CARB Rules and Measures
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A. Complete List of State Measures 

Appendix Table A-1 is a list of all measures 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 PM2.5 Plan. The table should include any substantive rules that would still be 

generating emissions reductions in the San Joaquin 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 pesticide emissions adopted by the California 

Department of Pesticide Regulation nor the State’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 quality standards), do not address particulate matter or a PM2.5

attainment plan precursor in the SJV (e.g., asbestos air toxic control measure), 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 applicable 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 Trichloroethylene 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 applicable 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 Contaminant. 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 SO2. 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-road 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 amendments 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, 2292.5, 

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-road 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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-road 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 Pollutants. 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 Standards 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-road 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 Alternative 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 Fuels 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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, 2262.5, 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 Deodorants, Consumer Products, 

Aerosol Coating Products (ARB Test Method 310). T 17, 

CCR, 94506(a), 94515(a), 94526 

11/21/96 Consumer products 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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-road 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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, 2262.5, 2262.6, 

2262.7 and 2265 

08/27/98 Fuels 

Gasoline Vapor Recovery Systems. T 17, CCR, 94010-

94015 and 94150, 94156, 94157, 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, 60206, 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 products 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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, 94501, 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 2262.5(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 Requirement for 

Wintertime In Lake Tahoe Area/Gas Pump Labeling for 

MTBE. T 13, CCR, 2262.5, 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, 2262.5, 2263, 2264, 2264.2, 2265, 2266 etc... 

12/09/99 Fuels 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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, 80250, 80260, 80270, 80280, 

80290, 80300, 80310, 80311, 80320, 80330 

03/23/00 Not applicable 

Enhanced Gasoline Vapor Recovery 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 Refueling 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 applicable 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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, 2262.5, 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-road 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 Service 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 Procedure, 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, 2262.5, 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, 2262.6, 2263, 2266.5, 2272, 

2273, 2260, 2273.5 

12/12/02 Fuels 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 (SORE). 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 Procedure, Warranty and InUse Compliance Requirements (Amendments). T 13, 

CCR, 2701-2707 & 2709 

12/11/03 On-road 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 

PM2.5 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 Statewide 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 Commercial 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-road 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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, 2262.5, 2262.6, 2262.9, 2263, 2265 

(and the incorporated “California Procedures”), and 

2266.5 

11/18/04 Fuels 

Diesel Fuel Standards for Harbor 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, 93102.5

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 Fuels 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 Vehicles 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-road 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 Service 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 Vehicles 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 Incineration (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 products 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 PM2.5 or PM2.5 Attainment Plan 

Precursors in the San Joaquin Valley 

A substantial number of the measures adopted by CARB since 1990 do not affect direct 

PM2.5 or a PM2.5 attainment plan precursor emissions in the San Joaquin Valley. These types of 

measures include fee rules, identification of toxic air contaminants, area boundary designations, 

and controls for pollutants other than direct PM2.5 (or PM), NOx, VOC, or SO2. 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 PM2.5 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 measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page A-21

 Appendix Table A-2 

Measures Adopted by the California Air Resources Board 

That Do Not Address PM2.5 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 Trichloroethylene 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 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page A-22

 Appendix Table A-2 

Measures Adopted by the California Air Resources Board 

That Do Not Address PM2.5 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 Contaminant. T 17, & 26, 93000 08/08/91 Not an emissions reduction measure 

State Ambient Air Quality Standard for SO2. 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 PM2.5 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 

measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page A-23

 Appendix Table A-2 

Measures Adopted by the California Air Resources Board 

That Do Not Address PM2.5 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 Pollutants. 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 PM2.5 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 

measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page A-24

 Appendix Table A-2 

Measures Adopted by the California Air Resources Board 

That Do Not Address PM2.5 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 

measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page A-25

 Appendix Table A-2 

Measures Adopted by the California Air Resources Board 

That Do Not Address PM2.5 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, 60206, 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, 80250, 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 PM2.5 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 

measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page A-26

 Appendix Table A-2 

Measures Adopted by the California Air Resources Board 

That Do Not Address PM2.5 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 

PM2.5 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 

measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 Table 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 Harbor Craft & Locomotives. T 

13, CCR, 2299, 2281, 2282, and 2284, and T 17, CCR, 

93117 

11/18/04 

NOx reductions estimated at 0.1 

tpd for SJV. See CARB 6/29/09 

Letter 

California Reformulated Gasoline (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, 

superseded 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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, 2262.5, 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, 2262.5, 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 2262.5(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 Requirement for 

Wintertime In Lake Tahoe Area/Gas Pump Labeling for 

MTBE. T 13, CCR, 2262.5, 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, 2262.5, 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, 2262.5, 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, 2262.5, 2262.6, 2262.9, 2266.5, 2269, 2271, 2272, 

2265, and 2296 

07/25/02 Superseded by 11/18/04 & 

6/14/07 rules 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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, 2262.6, 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, 2262.5, 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 measures 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 Aftermarket Parts. VC 27156 & 

38391 02/08/90 Compliance provisions 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 amendments 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 PM2.5 SIP June 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 Heavy 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 Recovery 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, 2001 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 achieve approximately 

2 tpd NOx 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 PM2.5 SIP June 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 Service 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 Procedure, 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 Particulate 

Matter 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 PM2.5 SIP June 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 Procedure, 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 Agencies. 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 PM2.5 SIP June 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 Vehicles 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 Particulate 

Matter 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 retrofit 

technology, 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 Service 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 PM2.5 SIP June 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 (SORE). 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 Vehicles 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 PM2.5 SIP June 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 Statewide 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 rule 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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, 2007 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 Incineration (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 content of consumer products for 20 years and 

continues to tighten standards and regulate more products. Appendix 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 PM2.5 SIP June 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, 94500-94506 11/09/89 Approved 8/21/95 (60 FR 43379) 

Consumer Products BAAQMD. T 17, CCR, 94520-94526 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 Deodorants, 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, 94501, 94508, 94521, 94522, 

and 94524 

11/19/98 Superseded by 11/17/06 rule 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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, which 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 Safety Code Sections 41954), CARB is required 

to adopt procedures and performance standards for controlling gasoline emissions from gasoline 

marketing operations, including transfer and storage operations. State law also authorizes CARB, 

in cooperation with the districts, to certify vapor recovery systems, identify defective equipment, 

and develop test methods. The installation and operation of CARB-certified vapor recovery 

equipment is required and enforced by SJVAPCD Rules 4621 and 4622. Appendix Table A-7 is 

a list of rulemaking actions taken by CARB since 1990 that address vapor recovery equipment 

certification, defects, and/or test methods. 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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, 94157, 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 Refueling Vapor Recovery). T 

17, CCR, 94011 

03/23/00 

Enhanced Gasoline Vapor Recovery 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 06/22/06 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 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 one 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 PM2.5 

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 PM2.5 SIP June 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. NOx

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. NOx 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. NOx

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 PM2.5 SIP June 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 NOx

and VOC standards 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 Rules 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

4101 Visible Emissions 2/17/2005 2/17/2005 2/17/2005 

70 FR 46770 

(8/11/05) 

Baseline measure 

4103 Open Burning 4/15/2010 4/15/2010 

4/15/2010 5/17/2007 

NPR: signed 

6/29/11 

74 FR 57907 

(11/10/09) 

Control strategy measu

4104 Reduction of Animal Matter 12/17/1992 12/17/1992 12/17/1992 75 FR 10691 (3/9/10) Baseline measure 4105 

Commercial Offsite Multi-User Hazardous and Non-Hazardous Waste Disposal Facilities 

12/17/1992 N/A N/A N/A Odor rule only 

4106 Prescribed Burning 6/21/2001 6/21/2001 6/21/2001 67 FR 8894 (2/27/02) Feasibility study compl

additional rulemaking. 

4201 Particulate matter concentrations 12/17/1992 12/17/1992 12/17/1992 67 FR 16026 (4/4/02) Baseline measure 4202 Particulate matter emission rates 12/17/1992 12/17/1992 12/17/1992 65 FR 21347 (4/21/00) Baseline measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

4203 

Particulate Matter Emissions from Incineration of Combustible Refuse 

12/17/1992 12/17/1992 N/A no action Baseline measure 

4204 Cotton Gin 2/17/2005 2/17/2005 2/17/2005 71 FR 65740 (11/08/06) Baseline measure Feasibility study measu4301 Fuel Burning Equipment 12/17/1992 12/17/1992 12/17/1992 64 FR 26876 (5/18/1999) Baseline measure 4302 Incinerator Burning 12/16/1993 12/16/1993 12/16/1993 64 FR 45170 (8/19/1999) Baseline measure 4303 Orchard Heaters 12/16/1993 12/16/1993 12/16/1993 64 FR 45170 (8/19/1999) Baseline measure 4304 

Equipment Turning Procedures for Boilers, Steam Generators, and Process Heaters 

10/19/1995 10/19/1995 10/19/1995 66 FR 5766 (11/16/01) Baseline measure 

4305 

Boilers, Steam Generators, and Process Heaters - Phase 2 

8/21/2003 8/21/2003 8/21/2003 69 FR 28061 (5/18/04) Baseline measure 

4306 

Boilers, Steam Generators, and Process Heaters - Phase 3 

10/16/2008 10/16/2008 10/16/2008 75 FR 1715 (1/13/10) Control strategy measu
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

4307 

Boilers, Steam Generators, and Process Heaters - 2.0 MM BTU/hr to 5.0 MMBTU/hr 

5/19/2011 10/16/2008 10/16/2008 75 FR 1715 (1/13/10) Control strategy measu

4308 

Boilers, Steam Generators, and Process Heaters - 0.75 MM BTU/hr to 2.0 MMBTU/hr 

12/17/2009 12/17/2009 12/17/2009 76 FR 5276 (1/31/11) Control strategy measu

4309 Dryers, Dehydrators and Ovens 12/15/2005 12/15/2005 12/15/2005 72 FR 29887 (5/30/07) 

Baseline measure Feasibility study measu

(2011) 

4311 Flares 6/18/2009 6/18/2009 

6/15/2006 6/20/2002 

NPR - 72 FR 

65283 (11/20/07) 

68 FR 8835 

(2/26/03) 

Control strategy measu2009 revisions submitte(complete February 4, 2

4313 Lime Kilns 3/27/2003 3/27/2003 3/27/2003 68 FR 52510 (9/4/2003) 

Baseline measure Feasibility study measu

(2011) 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

4320 

Advanced Emission Reduction Option for Boilers 

10/16/2008 10/16/2008 10/16/2008 76 FR 16696 (3/25/11) Control strategy measu

reductions credit allowe

4351 

Boilers, Steam Generators, and Process Heaters - RACT 

8/21/2003 8/21/2003 8/21/2003 69 FR 28061 (5/18/04) Baseline measure 

4352 

Solid Fuel Fired Boilers, Steam Generators, and Process Heaters 

5/18/2006 5/18/2006 5/18/2006 75 FR 60623 (10/1/10) Limited approval/disap

S-COM-4 - Feasibility & PM2.5 (2009) 

4354 Glass Melting Furnaces 4/19/2011 9/16/2010 

9/16/2010 8/17/2006 

76 FR 37044, 

(6/24/11) 

72 FR 41894 

(8/01/07) 

Control strategy measu

4401 Steam-Enhanced Crude Oil Production Wells 6/16/2011 12/14/2006 12/14/2006 75 FR 3996 (1/26/10) VOC measure Limited approval/disap4402 Crude Oil Production Sumps 12/17/1992 12/17/1992 N/A 76 FR 298 (1/04/11) VOC measure Limited approval/disap4403 

Components Serving Light Crude Oil or Gases at Light Crude Oil and Gas Production 

4/20/2005 4/20/2005 4/20/2005 71 FR 14652 (3/23/06) VOC measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

4404 Heavy Oil Test Station – Kern 12/17/1992 12/17/1992 12/17/1992 75 FR 10691 (3/9/10) VOC measure 4405 

Oxides of Nitrogen Emissions from Existing Steam Generators (Central and Western Kern County) 

12/17/1992 not submitted N/A N/A 

4406 

Sulfur Compounds from Oilfield Steam Generators - Kern 

12/17/1992 not submitted N/A N/A 

4407 In-situ Combustion Well Vents 5/19/1994 5/19/1994 5/19/1994 60 FR 12121 (3/6/95) VOC controls 4408 Glycol Dehydration Systems 12/19/2002 12/19/2002 12/19/2002 68 FR 51187 (8/26/03) 4409 

Components at Light Crude Oil or Gases at Light Crude Oil and Gas Production 

4/20/2005 4/20/2005 4/20/2005 71 FR 14653 (3/23/06) VOC measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

4451 

Valves, Pressure Relief Valves, Flanges, Threaded Connections and Process Drains at Petroleum Refineries and Chemical Plants 

4/20/2005 4/20/2005 4/20/2005 71 FR 14652 (3/23/06) VOC measure Rule incorporated into 

4452 

Pump and Compressor Seals at Petroleum Refiners 

4/20/2005 4/20/2005 4/20/2005 71 FR 14653 (3/23/06) VOC measure Rule incorporated into 

4453 

Refinery Vacuum Producing Devices or Systems 

12/19/1992 12/19/1992 N/A 

73 FR 48 (1/02/08) 

withdrawn 

VOC measure 

4454 Refinery Process Turnaround 12/19/1992 12/19/1992 N/A 

73 FR 48 (1/02/08) 

withdrawn 

VOC measure 

4455 Components at Refineries 4/20/2005 4/20/2005 4/20/2005 71 FR 14652 (3/23/06) VOC measure 4501 Alternate Compliance for BARCT 6/17/1999 6/17/1999 N/A no action 4550 Conservation Management Practices 8/19/2004 8/19/2004 8/19/2004 71 FR 7683 (2/14/06) Baseline measure Feasibility study measu
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

4565 

Biosolids, Animal Manure, and Poultry Litter Operations 

3/15/2007 3/15/2007 N/A no action VOC measure 

4566 Organic Waste N/A N/A N/A N/A New rule for green was4570 Confined Animal Facilities 10/21/2010 6/18/5/2009 6/18/2009 75 FR 2079 (1/14/10) VOC measure Limited approval/disap4601 Architectural Coatings 12/17/2009 12/17/2009 

12/17/2009 10/31/2001 

NPR 76 FR 35167 

(6/16/11) 69 FR 34 (1/02/04) 

VOC measure Limited approval/disapclock (disapproved elem

4602 

Motor Vehicle and Mobile Equipment Coating Operations 

9/17/2009 9/17/2009 

9/17/2009 

12/20/2001 

NPR: 76 FR 3214 

(6/3/11) 

67 FR 42999 

(6/26/02) 

VOC measure 

4603 

Surface Coating of Metal Parts and Products 

9/17/2010 9/17/2010 

9/17/2010 

10/16/2008 

NPR: 76 FR 3214 

(6/3/11) 

75 FR 4612 

(1/19/10) 

VOC measure 

4604 Can and Coil Coating Operations 9/20/2007 9/20/2007 9/20/2007 75 FR 4612 (1/19/10) VOC measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

4605 Aerospace Assembly and Component Coating 6/16/2011 9/20/2007 9/20/2007 75 FR 3996 (1/26/10) VOC measure Limited approval/disap4606 Wood Products Coating Operations 10/16/2008 10/16/2008 10/16/2008 74 FR 52849 (10/15/09) VOC measure 4607 Graphic Arts 12/18/2008 12/18/2008 12/18/2008 74 FR 52849 (10/15/09) VOC measure 4610 Glass Coating Operations 4/17/2003 4/17/2003 4/17/2003 69 FR 60962 (10/14/04) VOC measure 4612 

Motor Vehicle and Mobile Equipment Coating Operations – Phase 2 

10/21/2010 10/21/2010 9/20/2007 75 FR 4612 (1/19/10) VOC measure 

4621 

Gasoline Transfer into Stationary Storage Containers 

12/20/2007 12/20/2007 12/20/2007 74 FR 33397 (7/13/09) VOC measure 

4622 Gasoline Transfer into Motor Vehicles 12/20/2007 12/20/2007 12/20/2007 74 FR 33397 (7/13/09) VOC measure 4623 Storage of Organic Liquids 5/19/2005 5/19/2005 5/19/2005 70 FR 53937 (9/13/05) VOC measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

4624 Transfer of Organic Liquids 12/20/2007 12/20/2007 12/20/2007 74 FR 52894 (10/15/09) VOC measure4625 Wastewater Separators 12/17/1992 12/17/1992 N/A 

73 FR 48 (1/02/08) 

withdrawn 

VOC measure

4641 

Cutback, Slow Cure, and Emulsified Asphalt Paving and Maintenance Operations 

12/17/1992 12/17/1992 12/17/1992 75 FR 10691 (3/9/10) VOC measure 

4642 Solid Waste Disposal Site 4/16/1998 4/16/1998 4/16/1998 66 FR 38939 (7/26/01) VOC measure 4651 Soil Decontamination Operations 9/20/2007 9/20/2007 9/20/2007 74 FR 52894 (10/15/09) VOC measure 4652 Coatings and Ink Manufacturing 12/17/1992 not submitted N/A N/A No sources 4653 Adhesives 9/16/2010 9/16/2010 9/20/2007 74 FR 52894 (10/15/09) VOC measure 4661 Organic Solvents 9/20/2007 9/20/2007 9/20/2007 75 FR 24406 (5/5/2010) VOC measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

4662 Organic Solvent Degreasing Operations 9/20/2007 9/20/2007 9/20/2007 74 FR 37948 (7/30/09) VOC measure 4663 

Organic Solvent Cleaning, Storage, and Disposal 

9/20/2007 9/20/2007 9/20/2007 74 FR 37948 (7/30/09) VOC measure 

4672 Petroleum Solvent Dry Cleaning Operations 12/17/1992 12/17/1992 12/17/1992 75 FR 10691 (3/9/10) VOC measure 4681 Rubber Tire Manufacturing 12/16/1993 12/16/1993 12/16/1993 63 FR 43881 (8/17/98) VOC measure 4682 

Polystyrene, Polyethylene, and Polypropylene Products Manufacturing 

9/20/2007 9/20/2007 1994 

60 FR 31086 

(6/13/95) 

VOC measure 

4684 Polyester Resin Operations 6/16/2011 9/17/2009 9/20/2007 75 FR 3996 (1/26/10) VOC measure Limited approval/disap

4691 

(461.02) 

Vegetable Oil Processing Operations 12/17/1992 12/17/1992 12/17/1992 

59 FR 2535 

(1/18/94) 

 VOC measure 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

4692 Commercial Charbroiling 9/17/2009 9/17/2009 9/17/2009 3/21/2002 

NPR: signed 

6/9/11 

68 FR 33005 

(6/03/03) 

Control strategy measu

4693 Bakery Ovens 5/16/2002 5/16/2002 5/16/2002 

69 FR 22441 

(4/26/04) 

VOC measure 

4694 Wine Fermentation and Storage Tanks 12/15/2005 12/15/2005 N/A no action VOC measure 4695 Brandy and Wine Aging 9/17/2009 9/17/2009 9/17/2009 NPR: 76 FR 33181 (6/8/11) VOC measure 4701 I/C Engines - Phase 1 8/21/2003 8/21/2003 8/21/2003 69 FR 28061 (5/18/04) Baseline measure 4702 I/C Engines - Phase 2 1/18/2007 1/18/2007 1/18/2007 73 FR 1819 (1/10/08) Control strategy measu

Scheduled adoption Au

4703 Stationary Gas Turbines 9/20/2007 9/20/2007 9/20/2007 

74 FR 53888 

(10/21/09) Control strategy measu

4801 Sulfur Compounds 12/17/1992 12/17/1992 12/17/1992 no action 4802 Sulfuric Acid Mist 12/17/1992 12/17/1992 12/17/1992 64 FR 30396 (6/08/99) 

Baseline measure Limited approval/disapclock 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

4901 

Wood Burning Fireplaces and Wood Burning Heaters 

10/16/2008 10/16/2008 10/16/2008 74 FR 57907 (11/10/09) Control strategy measu

4902 Residential Water Heaters 3/19/2009 3/19/2009 3/19/2009 75 FR 24408 (5/5/10) Control strategy measu4905 

Natural Gas-fired, fantype, residential central furnaces 

10/20/2005 10/20/2005 10/20/2005 72 FR 29886 (5/30/07) Additional revisions sch

PM2.5 plan commitmen

8011 Fugitive Dust General Requirements 8/19/2004 8/19/2004 8/19/2004 71 FR 8461 (2/17/06) Baseline measures 8021 

Construction, Demolition, Excavation, Extraction, and other Earthmoving Activities 

8/19/2004 8/19/2004 8/19/2004 71 FR 8461 (2/17/06) Baseline measures 

8031 Bulk Materials 8/19/2004 8/19/2004 8/19/2004 71 FR 8461 (2/17/06) Baseline measures 8041 Carryout and Trackout 8/19/2004 8/19/2004 8/19/2004 71 FR 8461 (2/17/06) Baseline measures8051 Open Areas 8/19/2004 8/19/2004 8/19/2004 71 FR 8461 (2/17/06) Baseline measures8061 Paved and Unpaved Roads 8/19/2004 8/19/2004 8/19/2004 71 FR 8461 (2/17/06) Baseline measures
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP 

EPA- Region 9 

Appendix Table B -1 

Status of San Joaquin Valley Air Pollution Control District Rules 

June 16, 2011 

Rule No. Rule 

Date of Most 

Recent Rule 

Adopted/ 

Revised 

Date of 

Most Recent 

Rule 

Submitted 

Date of 

Most Recent 

Rule 

Approved 

Federal Register 

Cite Comm

8071 

Unpaved Vehicle/ Equipment Traffic Areas 

9/16/2004 9/16/2004 9/16/2004 71 FR 8461 (2/17/06) Baseline measures

8081 Agricultural Sources 9/16/2004 9/16/2004 9/16/2004 71 FR 8461 (2/17/06) Baseline measures9310 School Bus 9/21/2006 9/21/2006 9/21/2006 75 FR 10420 (3/8/10) Baseline measure 9410 Employer Based Trip Reduction 12/17/2009 12/17/2009 N/A no action Control strategy measu

2010 (complete June 8, 

9510 Indirect Source Review 12/15/2005 12/15/2005 12/15/2005 76 FR 26609 (5/9/11) No emissions reduction 
Appendix C -List of Document References 
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page C-1

72 FR 20586 Clean Air Fine Particle Implementation Rule; Final Rule (April 25, 

2007) 

75 FR 74518 2010 Proposal: Approval and Promulgation of Implementation Plans; 

State of California; 2008 San Joaquin Valley State Implementation Plan 

for Fine Particulate Matter; 2007 State Strategy; PM2.5; Proposed Rule 

(November 30, 2010) 

2007 State Strategy Proposed State Strategy for California’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) and 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 

PM2.5 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 

2008 PM2.5 Plan 2008 PM2.5 Plan, adopted on April 30, 2008 by the SJVAPCD as 

amended in 2008 PM2.5 Plan Amendment to Extend the Rule 4905 

Amendment Schedule and Progress Report on Implementation of PM2.5

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 Proposed 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, Region 9, “Draft Technical Support Document 

for the Revised Proposed Action on the San Joaquin Valley 2008 PM2.5

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

Strategy,” November 8, 2010 

2010 Proposal Approval and Promulgation of Implementation Plans; State of 

California; 2008 San Joaquin Valley State Implementation Plan for Fine 

Particulate Matter; 2007 State Strategy; PM2.5; Proposed Rule. 75 FR 

74518 (November 30, 2010)

2011 Progress 

Report 

Progress Report on Implementation of PM2.5 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
TSD for the Revised Proposal 

on the SJV 2008 PM2.5 SIP June 29, 2011 

EPA- Region 9 Page C-2

CARB modeling 

Supplement 

Letter, John DaMassa, Chief Modeling 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 Division, 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 

PM2.5 Precursor for the San Joaquin Valley 2008 PM2.5 State 

Implementation Plan (SIP).”

Plan Same as 2008 PM2.5 Plan 

PM2.5

Implementation 

Rule 

40 CFR part 51, subpart Z promulgated at 72 FR 20586 (April 25, 2007) 

Revised 2007 State 

Strategy Same as 2007 State Strategy 

SJV 2008 PM2.5

Plan 

Same as 2008 PM2.5 Plan 

SJV 2008 PM2.5 SIP 2008 PM2.5 Plan and 2007 State Strategy (as it applies to the SJV)