2007 Ozone Plan 

Note to readers: The District has provided a detailed written 

evaluation of the Alt SIP to the authors (ISSRC). 

 A summary of the District’s evaluation is attached 

and the full detailed evaluation is available upon request. 

 

Appendix P is being submitted to the SIP as the District’s response to public comment. 

Please refer to Appendix N and Appendix O for the commenter’s complete submittals. 

Please also refer to Appendix L for additional comments from ISSRC. 

Appendix P 

 

District Evaluation of ISSRC 

“Clearing The Air” Documents 
2007 Ozone Plan 

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San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix P: District Evaluation of ISSRC “Clearing the Air” Documents 

2007 Ozone Plan 

Appendix P-1

Appendix P: District Evaluation of ISSRC “Clearing 

The Air” Documents

International Sustainable Systems Research Center (ISSRC) is a Southern Californiabased non-profit organization that has worked with developing countries in Central and 

East Asia, Africa, and North and South America to meet “sustainability goals”. 

According to the organization’s website, www.issrc.org, ISSRC has conducted studies 

in 10 cities in developing countries aimed at better quantification of vehicular activities 

and enhancement of basic air quality management programs. 

ISSRC was retained by the Hewlett Foundation, on behalf of environmental 

organizations, to prepare an alternative State Implementation Plan (Alt SIP) for the San 

Joaquin Valley. ISSRC was tasked with developing an “alternative SIP” that could show 

attainment with the 8-hour ozone standard prior to 2013. ISSRC took on this enormous 

task without participating in the District’s public plan-development process and without 

communication with the District staff. Nonetheless, the District fully appreciates 

ISSRC’s hard work with limited resources. After careful consideration, we believe that 

their effort enhanced the quality and effectiveness of the Proposed 2007 Ozone Plan. 

Furthermore, the Alt SIP provided for a meaningful discussion of the enormous difficulty 

that the Valley faces in reaching attainment by 2013. 

On February 6, 2007, ISSRC released their first version of the Alt SIP claiming 

attainment by 2013. This document relied on outdated inventories, contained numerous 

double-counting of emission reductions, several basic mathematical and technical 

errors, and grossly underestimated the magnitude of reductions needed to reach 

attainment. After the above deficiencies were communicated, ISSRC published a 

Revised Alt SIP on February 19, 2007. 

The Revised Alt SIP no longer claimed that attainment by 2013 is possible. In fact, the 

Revised Alt SIP conceded to only achieving 95% of their own estimate of NOx 

reductions necessary for attainment. Although certain deficiencies were corrected, the 

Revised Alt SIP still relied on outdated information, underestimated attainment goals, 

double-counted reductions, and contained basic mathematical and technical errors. 

Despite the above shortcomings, the District carefully considered and evaluated all 

control measures proposed by ISSRC for inclusion in the 2007 Ozone plan. The District 

concludes that neither version of the Alt SIP is able to achieve attainment. In fact, 

neither version of the Alt SIP can bring the Valley into attainment under any timeline 

before 2024. Nevertheless, there are five concepts which have been deemed as viable, 

and these will be added to the 2007 Ozone Plan. 

Following discussions with ISSRC regarding the District’s concerns, a detailed analysis 

of the Alt SIP proposals is being made available to the public upon request. A summary 

of the detailed evaluation is shown below. Evaluation criteria consisted of state and 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix P: District Evaluation of ISSRC “Clearing the Air” Documents 

2007 Ozone Plan 

Appendix P-2

federal Clean Air Act planning requirements. State requirements cover economic, legal, 

social, and technological issues; federal requirements ensure that emission reductions 

are quantifiable, surplus, permanent, and enforceable. 

SUMMARY 

There are four main elements in the Alternative SIP: 

• Operational restrictions: The Alt SIP proposes 100 days each year of no driving, 

no farm operations, and no construction activities. (These restrictions are 

unenforceable, are beyond District authority, and could cripple the Valley’s 

economy. The reductions would not achieve the level needed for attainment.)

• $450 million per year in incentive funding: The Alt SIP proposes increasing 

incentive funding starting in 2007 and continuing through 2013. (The District 

cannot take federal credit for unsecured funding. The Alt SIP’s expenditure plan 

is impractical and would not achieve the proposed reductions. The Revised Alt 

SIP claimed significantly more emission reductions from incentives than the first 

Alt SIP, while maintaining the first version’s funding level.)

• Additional stationary and area source control measures: (Most Alt SIP reductions 

from stationary sources reflect double-counting. Existing and proposed District 

measures are more stringent.)

• Assumes attainment can be achieved in 2013 by reaching a “carrying capacity” 

of 195 tons per day (tons per day) of NOx and 230 tons per day of VOC. (The Alt 

SIP used outdated emission inventories and misapplied emission inventory 

numbers to ozone carrying capacity isopleths.) 

DISTRICT AGREES WITH ALTERNATIVE SIP RECOMMENDATIONS 

Many of the Alt SIP suggestions have either been accomplished by existing District 

rules or are proposed as control measures in the 2007 Ozone Plan. However, the 

District is in agreement with the following five recommendations of the Alternate SIP: 

! The need for incentives. Regulations alone cannot achieve the emission 

reductions necessary for attainment. The District concurs that mobile source 

emission reductions are necessary to reach attainment, and incentivization of 

reductions from this category is of paramount importance. 

! Accelerating the Glass Melting Furnaces control measures for earlier reductions 

of 0.4 tons per day of NOx. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix P: District Evaluation of ISSRC “Clearing the Air” Documents 

2007 Ozone Plan 

Appendix P-3

! Encouraging model ordinances for cities and counties to require solar water 

heaters in new construction. 

! Replacing 30,000 light/medium-duty vehicles should additional funding become 

available, enhancing the District’s previous proposal. 

! Expanding the applicability of the Graphic Arts rule to very small shops. 

Incentive Funding 

Like the District’s 2007 Ozone Plan, the Alt SIP proposes using incentives to gain 

reductions from mobile sources, which are under state and federal jurisdictions. The 

2007 Ozone Plan laid out the case for needed incentive funding in order for the District 

to achieve attainment of the 8-hour ozone standard by 2015 in areas affecting 50% of 

its population and by 2020 in areas affecting 90% of Valley residents. Without incentive 

funding, this figures drop to 35% by 2015 and 65% by 2020, with about 1,000,000 

Valley residents experiencing unhealthy air after 2020. Furthermore, without the 

proposed incentives, the Valley may not reach attainment of the PM2.5 federal standard 

by 2015, as currently mandated by the federal Clean Air Act. 

Glass Melting Furnaces 

Glass melting furnaces were already included in the 2007 Ozone Plan as the subject of 

control measure S-COM-7, and upon further analysis, it was found that stricter limits for 

four furnaces could be accelerated, resulting in 0.4 tons per day of additional NOx 

reductions by 2012. 

Residential Solar Water Heaters 

The District concurs with the suggestion to promote the use of solar water heaters in 

new housing developments. A model ordinance will be written, and cities and counties 

will be encouraged to adopt it. This suggestion will reduce the NOx emissions from this 

source category by approximately 0.1 ton per day. 

Light/Medium Duty Vehicles 

The District concurs that the replacement of high-polluting, light and medium-duty 

vehicles is an effective strategy to reduce mobile source NOx emissions, and the 

District Board recently adopted an enhanced vehicle replacement program. As 

increased funding for this program becomes available, the Alt SIP goal of replacing 

30,000 vehicles can be realized. 

Graphic Arts 

The District concurs with the suggestion to expand the applicability of Rule 4607 to 

sources with emissions of 60 pounds per month. While this rule change would not 

provide enough reductions to accelerate attainment, it would allow the District to claim 

reductions from currently available low-VOC technologies. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix P: District Evaluation of ISSRC “Clearing the Air” Documents 

2007 Ozone Plan 

Appendix P-4

ALTERNATIVE SIP UNDERESTIMATES ATTAINMENT GOALS 

The Executive Summary of the Alternative SIP used a simplistic combined NOx/VOC 

approach and a carrying capacity of 300 tons per day of combined NOx and VOC, 

apparently assuming that VOC reductions are as effective as NOx reductions. Although 

an aggressive combined NOx/VOC strategy would provide for attainment, a combined 

strategy would need approximately the same amount of NOx reductions as a NOx-only 

strategy, and would therefore be a very inefficient and needlessly expensive way to 

attain the 8-hour ozone standard. The Alt SIP prescribes reducing the amount of NOx 

reductions by increasing the amount of VOC reductions. In reality, according to ARB 

photochemical modeling, NOx reductions could be reduced by a maximum of 20 tons 

per day, but only by increasing VOC reductions by 150 tons per day. Using a 

conservative cost of $25 million per ton of emission reduction per day, the extra VOC 

emission reductions could raise the cost of attainment by over $3 billion. This amount 

would be in excess of the base cost of achieving the NOx reductions needed for 

attainment. 

ALTERNATIVE SIP FALLS SHORT OF ATTAINMENT 

In both versions, the Alternative SIP fell short of their own goals. Furthermore, when 

double-counted reductions are removed and other errors are accounted for, the 

remaining reductions fall significantly short, and the Alternative SIP fails in its objective 

of showing how attainment of the 8-hour ozone standard can be accomplished by 2013. 

First Alt SIP NOx and VOC Reductions 

The first Alt SIP relied on an outdated emissions inventory (version 1.04). The updated 

inventory (version 1.06), has a combined year 2013 NOx+VOC total of 846 tons per day 

(482 tons per day of NOx, 364 tons per day of VOC). Even if it is assumed that the 

reductions in the Alt SIP could be achieved, this new inventory results in a shortfall of 

approximately 66 tons per day of combined NOx and VOC for the first Alt SIP. In the 

detailed evaluation, it is shown that several errors, especially in double counting 

emission reductions, make the first Alt SIP highly flawed, which is also the case with its 

revised version. 

Revised Alt SIP NOx and VOC Reductions 

The Revised Alt SIP misapplied the 2012 isopleth from the October Draft of the 2007 

Ozone Plan to come up with an emission level of 195 tons per day of NOx and 230 tons 

per day of VOC, which the Alt SIP claims would be sufficient for attainment. The proper 

application – using the 2012 emission inventory from the October Drafts of the 2007 

Ozone Plan in conjunction with the 2012 isopleths - would actually result in a lower 

emission level of 164 tons per day of NOx and 195 tons per day of VOC, which requires 

more emission reductions than is contained in the Revised Alt SIP. The actual carrying 

capacity for NOx is approximately 160 tons per day. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix P: District Evaluation of ISSRC “Clearing the Air” Documents 

2007 Ozone Plan 

Appendix P-5

The Revised Alt SIP admits a 5% shortfall in NOx reductions. In reality, the Alt SIP falls 

even further short, since the carrying capacity from modeling results actually equate to 

164 tons per day of NOx and 195 tons per day of VOC. 

EVALUATION OF ALTERNATIVE SIP CONTROL MEASURES 

Control measures in state implementation plans must conform to requirements of the 

Federal Clean Air Act (FCAA) and California’s Health and Safety Code (CH&SC). To 

be deemed SIP-creditable, emission reductions must be surplus, quantifiable, 

enforceable, and permanent (FCAA, 42 U.S.C. Section 7410 (a)(2)(F)). Surplus 

reductions must come from measures beyond what existing rules and regulations 

require and must clearly be shown as not “double-counted.” 

Several California statutes cover the viability of control measures. CH&SC Section 

40406 states that, “ "best available retrofit control technology" means an emission 

limitation that is based on the maximum degree of reduction achievable, taking into 

account environmental, energy, and economic impacts by each class or category of 

source.” In addition, “all feasible measures” in state law and in CEQA guidelines mean: 

"capable of being accomplished in a successful manner within a reasonable period of 

time, taking into account economic, environmental, legal, social, and technological 

factors." These federal and state requirements were considered in the evaluation of 

proposed Alt SIP control measures. 

Double-Counting

The District found double counting errors, which are reductions that the Alt SIP claimed, 

even though these reductions already have occurred or will occur due to existing rules 

and proposed measures. 

Technological Feasibility

Several of the control measures suggested in the Alt SIP rely on untested technologies. 

For example, the effectiveness of controls for confined animal facilities and aftertreatment controls for diesel-powered equipment are unverified. The Alt SIP 

recommends these unverified technologies in their methodology to attain the 8-hour 

ozone standard by 2013. 

Legal and Practical Constraints

Several of the Alt SIP control measures present legal and practical obstacles for the 

District. For example, retrofitting on-road and off-road vehicles with selective catalytic 

reduction (SCR) technology is presented by the Alt SIP as a silver bullet-like solution, 

described as follows: “this single strategy is essential for achieving clean air in the 

valley,” (February 19 Alt SIP, page 57). In reality, the District does not have the 

authority to require retrofits. On a practical level, retrofitting on-road and off-road 

vehicles cannot effectively be done at the District level, since many of these vehicles 

are from out-of-state and from other districts. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Appendix P: District Evaluation of ISSRC “Clearing the Air” Documents 

2007 Ozone Plan 

Appendix P-6

Economic Impacts

Operational controls called for by the Alt SIP, such as shutdown of sources during 

episodes of high ozone, would cause serious economic harm to many industries, 

including agriculture, construction, and landscaping. Since there are no known 

technologies that would make it possible to achieve the reductions proposed by the Alt 

SIP, these reductions could only be accomplished by shutting down various activities 

which are critical to the Valley’s economy. The Alt SIP’s reduction projections are 

premised on the availability of BACT level technology, which will be installed by 

equipment users, in order to avoid non-operation during high ozone days, or as stated 

in the Alt SIP, “In this example, waiver of the operational restriction is the incentive for 

using clean technology” (Revised Alt SIP, page 54). 

The operational restrictions are also considered by the Alt SIP as enabling the District to 

lower the amount of incentive funding necessary, or as stated on pages 54-55 of the 

Revised Alt SIP, “These types of techniques allow the District to reduce emissions from 

these sources without many times raising incentive funding.” The District foresees legal 

obstacles in using operational restrictions as a “stick” in forcing the installation of clean 

technology. In combination with the absence of secured incentive funding sources, the 

federal approvability of the Alt SIP’s “Park it or Fix It” strategy is highly unlikely. 

A detailed evaluation of the Alt SIP has been submitted to ISSRC . The full 

detailed evaluation of the Alt SIP’s control measures is available upon request.