Report No. SR2007-09-03

Assessment of the Need for 

Long-Term Reduction in 

Consumer Product Emissions 

in the South Coast Air Basin 

prepared for:

Consumer Specialty Products Association

September 12, 2007

prepared by: 

Sierra Research, Inc. 

1801 J Street 

Sacramento, California 95811 

(916) 444-6666

Attachment C - CSPA Comments on ARB Agenda Item # 13-2-2
Report No. SR2007-09-03 

Assessment of the Need for Long-Term Reductions in Consumer 

Product Emissions in the South Coast Air Basin

 prepared for: 

Consumer Specialty Products Association 

 September 12, 2007 

 Principal author: 

 James M. Lyons 

Sierra Research, Inc. 

1801 J Street 

Sacramento, CA 95811 

(916) 444-6666 

Attachment C - CSPA Comments on ARB Agenda Item # 13-2-2
-iAssessment of the Need for Long-Term Reductions in Consumer 

Product Emissions in the South Coast Air Basin 

Table of Contents

Page

1. Executive Summary.......................................................................................................1 

2. Introduction....................................................................................................................3 

3. Consumer Products Overview .......................................................................................5 

4. The 2007 AQMP............................................................................................................7 

4.1 General AQMP Requirements ............................................................................. 7 

4.2 Emission Reduction Targets of the 2007 AQMP ................................................ 8 

4.3 2007 AQMP Control Measures ......................................................................... 10 

5. Assessment of the Need for Long-Term Reductions in Consumer Product 

Emissions .....................................................................................................................13 

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 List of Tables

Table Page

Table 4-1 2007 AQMP PM2.5 Control Strategy.................................................................9 

Table 4-2 2007 AQMP Ozone Control Strategy..............................................................10 

Table 4-3 2023 SCAB Emission Reductions From 2007 AQMP Ozone Control 

Measures ..........................................................................................................11 

Table 5-1 Environ Ozone Air Quality Modeling Results Without Measure SCLTMO3.....................................................................................................................14 

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1. EXECUTIVE SUMMARY 

The long-standing efforts to eliminate the air quality problems related to photochemical 

“smog” in Southern California’s South Coast Air Basin (SCAB) are well known. These 

efforts have been primarily aimed at bringing the SCAB into compliance with the federal 

National Ambient Air Quality Standard (NAAQS) for ozone. As with all other NAAQS, 

the ozone standard has been set at a level designed to protect public health. 

More recently, public exposure to high ambient concentrations of fine particulate matter 

(PM2.5)

*

 has also become a major concern, leading to the establishment of a NAAQS for 

that pollutant. As is the case with respect to ozone, considerable efforts have been made 

to reduce emissions of both PM2.5 as well as its precursors. 

The latest step in the efforts to bring the SCAB into compliance with both the ozone and 

PM2.5 NAAQS has been the development of the 2007 Air Quality Management Plan 

(AQMP) by the South Coast Air Quality Management District (SCAQMD). Compliance 

with the PM2.5 NAAQS in the SCAB is required by 2015, while compliance with the 

ozone NAAQS is required by 2024. The 2007 AQMP includes an air quality modeling 

assessment intended to establish the emissions levels of pollutants that can be tolerated in 

the SCAB while assuring that levels of ozone and PM2.5 do not violate the respective 

NAAQS, and a suite of control measures designed to bring emissions down to those 

levels. This suite of control measures, which will be implemented by both the SCAQMD 

and the California Air Resources Board (CARB), targets virtually every source of 

pollutants related to ozone and PM2.5, but focuses primarily on reductions in oxides of 

nitrogen (NOx) emissions as the strategy for attainment of both the ozone and PM2.5

NAAQS. 

One of the emissions sources targeted by the 2007 AQMP is consumer products, the use 

of which results in emissions of VOC but not NOx. Although consumer products have 

been subject for almost 20 years to increasingly stringent emissions regulations imposed 

by CARB, additional reductions in VOC emissions from this source are sought in the 

2007 AQMP. The AQMP proposes additional consumer product regulations—including 

additional near-term CARB regulations and a long-term measure that would take effect 

beyond 2020.† The near-term consumer product regulations are expected to aid in 

achieving both the PM2.5 and the ozone NAAQS. In contrast, the long-term consumer 

 

*

 Fine particulate matter is defined as particles with a diameter of less than 2.5 microns. 

†

 The near-term CARB control measure is referred to as CARB’s Consumer Products Program, and the 

long-term measure is designated as SCLTM-03 in the 2007 AQMP. As discussed in Section 4, there are 

three SCAQMD near- and mid-term consumer product control measures discussed in the AQMP. 

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product regulation is intended to achieve the very last increment of VOC emission 

reductions that the air quality analysis performed for the 2007 AQMP indicates may be 

required for attainment of the ozone NAAQS. However, the 2007 AQMP has not 

examined the need for this second round of regulation in detail, and it is not clear it will 

actually be required to achieve compliance with the ozone NAAQS. 

This report presents the results of a detailed air quality modeling analysis performed 

using the same data, models, and methods used in preparation of the 2007 AQMP and 

specifically examines the need for the second round of long-term consumer product 

regulations incorporated into the 2007 AQMP. The results of this analysis show that the 

long-term regulations seeking additional reductions in consumer product VOC emissions 

are not necessary for the achievement of compliance with the ozone NAAQS in the 

SCAB. 

### 

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2. INTRODUCTION 

Air quality problems related to photochemical “smog” have been well documented in 

Southern California’s South Coast Air Basin (SCAB) since Professor A.J. Haagen-Smit 

first determined the chemical processes leading to its formation during the 1950s. The 

principal component of smog is ozone, which is formed in the atmosphere as the result of 

photochemical reactions involving oxides of nitrogen (NOx) and reactive volatile organic 

compounds (VOCs). Since that time, efforts to reduce ambient ozone concentrations to 

acceptable levels have been on-going. These efforts have been primarily aimed at 

bringing the SCAB into compliance with the federal National Ambient Air Quality 

Standard (NAAQS) for ozone. As with all other NAAQS, the ozone standard has been 

set at a level designed to protect public health. 

More recently, public exposure to high ambient concentrations of fine particulate matter 

(PM2.5)

*

 has also become a major concern, leading to the establishment of a NAAQS for 

that pollutant. Fine particulate matter may be directly emitted by sources such as Diesel 

vehicles or, like ozone, may be formed in the atmosphere from precursors such as NOx, 

oxides of sulfur (SOx), and VOC. As is the case with respect to ozone, considerable 

efforts have made to reduce emissions of both PM2.5 as well as its precursors. 

The latest step in the efforts to bring the SCAB into compliance with both the ozone and 

PM2.5 NAAQS has been the development of the 2007 Air Quality Management Plan 

(AQMP) by the South Coast Air Quality Management District (SCAQMD). Compliance 

with the PM2.5 NAAQS in the SCAB is required by 2015, while compliance with ozone 

NAAQS is required by 2024. The 2007 AQMP includes an air quality modeling 

assessment intended to establish the emissions levels of pollutants that can be tolerated in 

the SCAB while assuring that levels of ozone and PM2.5 do not violate the respective 

NAAQS, and a suite of control measures designed to bring emissions down to those 

levels. This suite of control measures, which will be implemented by both the SCAQMD 

and the California Air Resources Board (CARB), targets virtually every source of 

pollutants related to ozone and PM2.5, but focuses primarily on reductions in NOx 

emissions as the strategy for attainment of both the ozone and PM2.5 NAAQS. 

One of the emissions sources targeted by the 2007 AQMP is consumer products, the use 

of which results in emissions of VOC but not NOx. Although consumer products have 

been subject for almost 20 years to increasingly stringent emissions regulations imposed 

by CARB, additional reductions in VOC emissions from this source are sought in the 

 

*

 Fine particulate matter is defined as particles with a diameter of less than 2.5 microns. 

Attachment C - CSPA Comments on ARB Agenda Item # 13-2-2
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2007 AQMP. The AQMP proposes that CARB and perhaps the SCAQMD adopt 

additional consumer product regulations in the near-term and that an additional long-term 

regulatory effort targeting consumer products take effect beyond 2020. The near-term 

consumer product regulations will aid in achieving both the PM2.5 and the ozone 

NAAQS. The long-term consumer product regulations, however, are intended to achieve 

the very last increment of VOC emission reductions that the air quality analysis 

performed for the 2007 AQMP indicates may be required for attainment of the ozone 

NAAQS. The 2007 AQMP has not, however, examined the need for the long-term 

regulations in detail and it is not clear that it will actually be required to achieve 

compliance with ozone NAAQS. Given this, the purpose of this report is to investigate 

the need for additional long-term reductions in VOC emissions from consumer products 

in greater detail than was done during preparation of the 2007 AQMP. 

This introduction is followed by a brief overview of consumer products and their 

regulation; a summary of the 2007 AQMP; and, lastly, a summary of a detailed air 

quality modeling analysis performed using the same data, models, and methods used in 

preparation of the 2007 AQMP, and that specifically examines the need for the long-term 

consumer product regulations incorporated into the 2007 AQMP. 

### 

 

 

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3. CONSUMER PRODUCTS OVERVIEW 

The California Air Resources Board (CARB) has a well-established regulatory program 

for consumer products that is intended to reduce emissions of volatile organic compounds 

(VOC) from these products. From the perspective of air quality, a consumer product is 

defined by the Section 41712 of the California Health and Safety Code as: 

a chemically formulated product used by household and institutional 

consumers, including, but not limited to, detergents; cleaning compounds; 

polishes; floor finishes; cosmetics; personal care products; home, lawn, 

and garden products; disinfectants; sanitizers; aerosol paints; and 

automotive specialty products; but does not include other paint products, 

furniture coatings, or architectural coatings. 

 

The one common characteristic of consumer products is that their formulations contain 

VOCs that, to some degree, enter the atmosphere. VOC emissions from consumer 

products were first targeted for regulation by CARB during the late 1980s when the 

agency approved its first “Consumer Products Control Plan.”*

 Beginning with the 

adoption of the Phase I Consumer Products Regulations in 1990, to date there have been 

15 separate CARB rulemakings related to the regulation of VOC emissions from 

consumer products.† Control measures targeting VOC emissions from consumer 

products were incorporated into CARB’s statewide control strategies for both the 1994 

and 2003 ozone State Implementation Plans (SIPs).‡

 

As part of the most recent CARB rulemaking, the agency estimated that by 2010 its 

existing consumer product regulations would result in the elimination of approximately 

180 tons per day of VOC emissions statewide.§ This translates into about a 42% 

reduction in VOC emissions from the entire consumer products category relative to 

uncontrolled levels. The magnitude of this reduction is remarkable given that 

reformulation is the only means of reducing VOC emissions from consumer products and 

the presence of specific VOC compounds is, in many cases, essential to product efficacy 

and performance. 

 

*

 Consumer Products Control Plan, State of California Air Resources Board, June 16, 1989. 

†

 See http://www.arb.ca.gov/consprod/regact/passhearings.htm ‡

 See http://www.arb.ca.gov/planning/sip/sip.htm §

 Proposed Amendments to the California Consumer Products Regulation and the Aerosol Coatings 

Regulation, California Air Resources Board, September 29, 2006. 

Attachment C - CSPA Comments on ARB Agenda Item # 13-2-2
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Another important factor associated with VOC emissions from consumer products is that 

they tend to have lower photochemical reactivity or “ozone forming potential” than VOC 

emissions from other sources. A previous study* determined that consumer product VOC 

emissions are approximately 50% less photochemically reactive than the average VOC 

emissions from other sources. In addition, CARB staff has reported that motor vehicle 

exhaust VOC emissions are three times more reactive than VOC emissions from 

consumer products.† This means that eliminating VOC emissions from sources other 

than consumer products is likely to result in a considerably larger air quality benefit than 

would be achieved by reducing an equivalent mass of VOC emissions from consumer 

products. 

 

In summary, many consumer products, by their very nature, must include VOC 

compounds in their formulations to ensure efficacy and proper performance. Some of 

these VOC compounds enter the atmosphere where they can cause adverse impacts on air 

quality, with increased ambient ozone concentrations being the primary effect. This fact 

has long been recognized by CARB, which has been regulating VOC emissions from 

consumer products for almost 20 years, and there have been dramatic reductions in VOC 

emissions from consumer products as a result of regulations implemented during that 

time. Finally, on a per-unit basis, VOC emissions from sources other than consumer 

products lead to greater increases in ambient ozone levels. 

### 

 

*

 Impact of Consumer Products on California’s Air Quality, Sierra Research Report SR97-07-01, July 

1997. 

†

 See http://www.arb.ca.gov/planning/sip/2007sip/2007sip.htm

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4. THE 2007 AQMP 

The most recent South Coast Air Quality Management District Air Quality Management 

Plan has been designated as the 2007 AQMP.*

 The 2007 AQMP describes how 

compliance with federal NAAQS for ozone and PM2.5

†

 will be achieved in the South 

Coast Air Basin. As noted previously, the SCAB is currently classified as a 

nonattainment area with respect to the PM2.5 NAAQS and a “severe” nonattainment area 

with respect to the ozone NAAQS. As part of the 2007 AQMP, however, the SCAQMD 

is requesting redesignation of the SCAB to an “extreme” ozone nonattainment area. 

Under federal law, the SCAB is required to come into attainment with the PM2.5 NAAQS 

no later than 2015. Assuming that the SCAB is redesignated as an extreme ozone 

nonattainment area, compliance with the NAAQS is required by 2024. Attainment of the 

NAAQS requires that observed ambient levels of PM2.5 and ozone demonstrate that 

compliance with the NAAQS has been achieved. 

 

4.1 General AQMP Requirements 

The main purpose of the 2007 AQMP is to demonstrate and document how the SCAB 

will achieve compliance with the PM2.5 and ozone NAAQS by the applicable deadlines. 

In general terms, this required the following: 

1. Development of an inventory of current emissions from all sources; 

2. Development of an inventory of projected future-year emissions from all sources 

that accounts for all existing emission control measures; 

3. Performance of an air quality modeling analysis to determine which pollutants 

need to be controlled and to what degree emissions of those pollutants must be 

reduced to achieve compliance with the NAAQS; and 

4. Development of a suite of emission control measures that achieve the required 

emission reductions by the required compliance dates. 

The results of the air quality modeling analysis are particularly important because they 

both demonstrate that the area can be brought into attainment with the NAAQS and 

establish limits on the amount of pollutants that can be emitted while maintaining 

 

*

 The draft final version of the SCAQMD 2007 AQMP is available at 

http://www.aqmd.gov/aqmp/07aqmp/07AQMP_draftfinal.html. †

 The fine particulate NAAQS applies to particles that are less than 2.5 microns in diameter. 

Attachment C - CSPA Comments on ARB Agenda Item # 13-2-2
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compliance with the NAAQS. This limit is frequently referred to as the emissions 

“carrying capacity” of the area. 

Subtracting the projected future-year emissions of a given pollutant at the compliance 

date from the carrying capacity for that pollutant yields the amount of emissions that 

must be eliminated by the new control measures incorporated into the AQMP by that 

compliance date. Federal law imposes requirements on the new control measures that 

include the following: 

1. The emission reductions that would result from the implementation of each 

measure must be quantifiable; 

2. The emission reductions due to each measure must be surplus (e.g., not already 

assumed to have occurred for purposes of attaining the NAAQs); 

3. The emission reductions due to each measure must be permanent; 

4. It must be demonstrated that each measure can be implemented; and 

5. Each measure must be federally enforceable. 

Another issue with respect to control measures is that federal and state laws have created 

distinct authorities with respect to the imposition of emission regulations on specific 

sources. For example, only the federal government has the authority to regulate certain 

sources, such as new locomotives and aircraft; the state has the authority to regulate 

ubiquitous sources such as on-road vehicles, pesticides, and consumer products; and the 

SCAQMD has the authority to regulate local stationary sources such as power plants and 

refineries, and most commercial facilities. The 2007 AQMP describes the emission 

control measures proposed for adoption by both the SCAMQD and the state, with the 

latter also being described in CARB’s Proposed State Strategy.*

 

Finally, an important aspect of the redesignation of the SCAB to an “extreme” ozone 

nonattainment area is that it provides (in addition to a later compliance deadline) a “black 

box” to which some of the emission reductions required for attainment can be allocated. 

Emission reductions allocated to the black box are not required to be associated with 

defined control measures, but rather are reductions that are anticipated to be achieved as 

the result of “advancements” in emission control technology. Despite the fact that the 

black box affords time for technological development prior to the specification of the 

control measures that will be implemented, the SCAQMD has already defined four longterm control measures in the 2007 AQMP. 

4.2 Emission Reduction Targets of the 2007 AQMP

As discussed previously, the relative importance of emissions of different pollutants 

differs with respect to compliance with the PM2.5 and ozone NAAQS and there are two 

distinct deadlines for compliance. As a result, the 2007 AQMP has two distinct emission 

 

*

 See http://www.arb.ca.gov/planning/sip/2007sip/2007sip.htm 

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reduction targets, which are discussed below. It is important to note, however, that, in 

general, there is little documentation provided in the 2007 AQMP regarding how these 

targets were selected, what alternatives were considered, and how sensitive the 

attainment demonstrations are to changes in the target emission levels. 

Beginning with the PM2.5 emission reduction targets, the pollutants of concern include 

direct PM2.5 emissions as well as emissions of SOx, NOx, and VOC, which are all 

precursors to the formation of secondary PM2.5. Based on the air quality modeling 

analysis for the 2007 AQMP, the relative reduction in ambient PM2.5 concentrations due 

to the reduction of a given mass of SOx emissions is 10 times greater than that of the 

same mass reduction in VOC emissions. In addition, the effects of reductions in a given 

mass of NOx and direct PM2.5 emissions are 5 and 3 times greater, respectively, than are 

reductions in VOC emissions. Using these and other data, the SCAQMD determined the 

carrying capacity (or the level of emissions of these pollutants that can be tolerated) for 

achieving the PM2.5 NAAQS by the 2014 deadline. These data are presented in 

Table 4-1, along with baseline emissions data for 2005 and 2014. As shown in the table, 

the focus of the SCAQMD strategy for achieving the PM2.5 NAAQS requires dramatic 

reductions in SOx and NOx emissions and smaller, but still substantial, reductions in 

emissions of direct PM2.5 and VOC. 

 

Turning to the carrying capacity for achievement of the ozone NAAQS, the 2007 AQMP 

air quality analysis indicates, as shown in Table 4-2, that dramatic reductions in NOx 

emissions will be required, along with significant but much more modest reductions in 

VOC emissions. Also, as noted above, the 2007 AQMP has allocated some of the 

emission reductions required for attainment to the black box; these allocations are also 

shown in Table 4-2. 

 

Table 4-1 

2007 AQMP PM2.5 Control Strategy 

Pollutant Emissions (tons per day) 

Direct PM2.5 Sox NOx VOC 

2005 Baseline 106 62 1029 720 

2014 Baseline 102 43 654 528 

2014 Carrying Capacity 87 19 454 469 

Required Reductions from 2014 

Baseline 15 24 200 59 

Reductions as % of 2014 

Baseline 15% 56% 31% 11% 

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Table 4-2 

2007 AQMP Ozone Control Strategy 

Pollutant Emissions (tons per day) 

NOx VOC 

2005 Baseline 1029 720 

2023 Baseline 506 536 

2023 Carrying Capacity 114 420 

Total Required Reductions from 2023 Baseline 392 (188)a 116 (28)a 

Total Reductions as % of 2023 Baseline 78% 22% 

Black Box Reductions as % of 2023 Baseline 37% 5% 

a Values in parenthesis are reductions attributed to the advanced technology control measures of the black 

box. 

Overall, as shown, the 2007 AQMP strategy for attainment of the ozone NAAQS relies 

heavily on NOx emission reductions and NOx reductions dominate the black box. The 

focus of the 2007 AQMP control strategy for both PM2.5 and ozone on NOx emission 

reductions is significant because the relationship between NOx and VOC emissions and 

ozone is complicated and non-linear. As a result, it is possible that at some points along 

the AQMP’s NOx reduction pathway, additional reductions in VOC emissions may yield 

little or no additional improvement in ambient ozone levels. 

4.3 2007 AQMP Control Measures

As noted above, given the differences in the legal authority of CARB and the SCAQMD 

to adopt control measures targeting different sources, the 2007 AQMP includes a suite of 

measures that each agency will implement. The SCAQMD measures generally target 

stationary and area sources and, to a limited degree, mobile sources. In contrast, the 

CARB measures, which are implemented on a statewide (rather than local) basis, 

primarily target mobile sources as well as consumer products. 

Table 4-3 summarizes the reductions in NOx and VOC emissions in the SCAB in 2023 

resulting from control measures to be implemented by the SCAQMD and other local 

agencies and those to be implemented by CARB and other state agencies that have been 

incorporated into the 2007 AQMP. As shown in the table, the 2007 AQMP will result in 

the implementation of new control measures targeting virtually all sources of emissions 

and will include additional CARB regulations for consumer products. These additional 

CARB regulations, which are to be adopted by 2012 and implemented by 2014, are 

expected to yield VOC reductions of 14 tons per day in the SCAB in 2023. The 

reductions in VOC emissions achieved due to these near-term CARB consumer product 

measures are quite significant as they amount to 16% of all identified VOC reductions 

and 12% of the total required VOC reductions, including those allocated to the black box. 

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Table 4-3 

2023 SCAB Emission Reductions From 2007 AQMP Ozone Control Measures 

Emission Reductions (tons per day) 

Agency/Source NOx VOC 

SCAQMD/All Short- and Mid-Term Measures 9 19 

CARB/Passenger Vehicles 7 10 

CARB/On-Road Trucks 18 2 

CARB/Goods Movement 100 3

CARB/Other Off-Road 16 26 

CARB/Consumer Products 0 14 

Additional CARB Measures Proposed by 

SCAQMD 34 14 

Local Goods Movement Measures 11 0 

Total Identified 195 88 

Black Box 188 28 

Total 383 116 

Although general authority to regulate consumer products in California rests with 

CARB,* the SCAQMD’s list of short- and mid-term control measures includes the 

following measures targeting consumer products: 

• CTS-01 – Emission Reductions from Lubricants; 

• CTS-03 – Consumer Product Certification and Emission Reductions from Use of 

Consumer Products at Institutional and Commercial Facilities; and 

• CTS-04 – Emission Reductions from the Reduction of VOC Content of Consumer 

Products Not Regulated by the State Board. 

However, despite the fact that the AQMP associates 2023 SCAB VOC emission 

reductions of 2.0, 2.2 and 6.0 tons per day with CTS-01, CTS-03, and CTS-04, 

respectively, it also notes that these reductions are not included in the reductions claimed 

for all of the SCAQMD’s short- and mid-term measures. The AQMP’s treatment of 

these measures is further confused by the fact that the SCAQMD’s air quality modeling 

analysis assumes that the consumer product emission reductions associated with CTS-03 

are realized but that those associated with CTS-04 are not. Also, the SCAQMD air 

quality modeling analysis includes the reductions associated with CTS-01, but those 

reductions are assumed to come from a source category other than consumer products. 

 

*

 See Section 41712, California Health and Safety Code. 

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In addition to identifying the control measures summarized above, the SCAQMD has 

included in the 2007 AQMP recommendations for four long-term control measures that 

could provide at least some of the emission reductions allocated to the black box. 

Despite being included in the 2007 AQMP by the SCAQMD, all four measures would 

target sources that only CARB has authority to regulate: mobile on- and off-road sources 

and consumer products. The SCAQMD’s recommended measures are described in the 

2007 AQMP as follows: 

• SCLTM-01A – Further Reductions from On-Road Mobile Sources; 

• SCLTM-01B – Further Emission Reductions from On-Road Heavy-Duty 

Vehicles; 

• SCLTM-02 – Further Reductions from Off-Road Mobile Sources; and 

• SCLTM-03 – Further Reductions from Consumer Products. 

The 2023 emission reductions in the SCAB attributed to these control measures by the 

SCAQMD are 62 tons per day of NOx for the combination of SCLTM-01A and -01B, 

116 tons per day of NOx for SCLTM-02, and 20 tons per day of VOC for SCLTM-03. 

The long-term consumer product control measure, SCLTM-03, would account for twothirds of the VOC reductions allocated to the black box. Based on the discussion of this 

measure in the 2007 AQMP, it appears that it was selected simply because, by 2023, 

consumer product emissions will be the single largest remaining source of VOC 

emissions. The 20 ton per day reduction assigned to SCLTM-03 is relative to an 88 ton 

per day total consumer product emission inventory. It is not clear that it will be 

technically or commercially feasible*

 to achieve the additional 23% reduction in 

consumer product emissions ascribed to SCLTM-03 from what will be an already highly 

controlled source. Further, given the lack of documentation in the 2007 AQMP regarding 

how the VOC carrying capacity was determined, it is not clear that the VOC emission 

reductions from SCLTM-03 are even necessary to demonstrate or achieve attainment 

with the ozone NAAQS. 

### 

 

*

 Nor is it clear that the other requirements of Health and Safety Code Section 41712 can be satisfied. 

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5. ASSESSMENT OF THE NEED FOR LONG-TERM REDUCTIONS 

IN CONSUMER PRODUCT EMISSIONS 

As discussed above, there are a number of factors that call into question the need for the 

inclusion of SCLTM-03 in the AQMP. These factors include the following: 

• The methodology used to determine the required VOC reductions attributed to the 

black box; 

• The magnitude of the required NOx reductions attributed to the black box; 

• The projected margin of compliance with the eight-hour ozone NAAQS; and 

• The fact that the long-term consumer products measure will result in only limited 

reductions in emissions of low reactivity VOCs. 

Given the above factors, an assessment of the need for the inclusion of SCLTM-03 was 

undertaken. This assessment involved the replication of the SCAQMD ozone air quality 

modeling analysis that forms the basis for the AQMP attainment demonstration with and 

without the inclusion of SCLTM-03. This assessment, performed by ENVIRON,*

 is 

documented in Appendix A. 

 

These results are summarized in Table 5-1, which shows the eight-hour ozone design 

values calculated by ENVIRON without SCLTM-03 in place and the increase in design 

value if the measure is eliminated from the AQMP. As shown, the peak eight-hour ozone 

value of 84 ppb at Crestline is unchanged by the elimination of SCLTM-03 and the 

maximum increase in eight-hour ozone levels at any site is 1 ppb. 

The results of the ENVIRON assessment indicate that if the SCLTM-03 control measure 

were not implemented, the eight-hour average ozone levels at all monitoring sites would 

remain below the NAAQS attainment level of 85 ppb. More simply stated, even if the 

SCLTM-03 measure were eliminated from the 2007 AQMP, the SCAB would be 

expected to attain the ozone NAAQS based on the air quality analysis that forms the basis 

for the 2007 AQMP. Therefore, measure SCLTM-03 can be eliminated from the 2007 

AQMP even before an assessment is made as to whether it would conform to Health and 

Safety Code Section 41712. 

 

*

 ENVIRON developed the CAMx model used by the SCAQMD; all of the models, inputs, and other data 

required for the assessment were provided to ENVIRON by SCAQMD staff. 

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Table 5-1 

Environ Ozone Air Quality Modeling Results Without Measure SCLTM-O3 

Site 

Design Value without 

SCLTM-03 

(ppb) 

Increase in Design Value Due to 

Elimination of SCLTM-03 

(ppb) 

Azusa 62 1 

Banning Airport 68 1 

Burbank 68 0 

Crestline 84 0 

Lake Elsinore 61 0 

Fontana 81 1 

Glendora 80 1 

Indio 55 0 

Pasadena 73 1 

Perris 80 1 

Palm Springs 58 0 

Pomona 76 1 

Redlands 81 0 

Reseda 66 0 

Rubidoux 77 1 

Santa Clarita 75 1 

### 

Attachment C - CSPA Comments on ARB Agenda Item # 13-2-2
APPENDIX A 

ENVIRON Report on 

“Need for Additional Consumer Product VOC Controls Beyond the ARB’s Control 

Measure to Achieve Attainment of the 8-Hour Ozone Standard in Southern 

California”

Attachment C - CSPA Comments on ARB Agenda Item # 13-2-2
A-1

Need for Additional Consumer Product VOC Controls Beyond the 

ARB’s Control Measure to Achieve Attainment of the 

8-Hour Ozone Standard in Southern California 

Ralph Morris and Bonyoung Koo 

ENVIRON International Corporation 

101 Rowland Way 

Novato, California 94945 

September 6, 2007 

BACKGROUND 

The South Coast Air Quality Management District (SCAQMD) has released a 2007 Air 

Quality Management Plan (AQMP) that proposes control measures to achieve the 8-hour 

ozone NAAQS by 2024. The 8-hour ozone attainment demonstration was based on 

photochemical modeling using the Comprehensive Air Quality Model with extensions 

(CAMx). CAMx was run for a 2002 base case emissions scenario and a 2023 base case 

and 2023 AQMP control case and the results used to project 8-hour ozone Design Values 

to 2023 for comparison with the NAAQS. The projected 2023 8-hour ozone Design 

Values under the 2007 AQMP control plan were all below the 85 ppb NAAQS, thereby 

demonstrating attainment of the 8-hour ozone standard. 

The 2007 AQMP attainment demonstration includes three control measures for 

controlling volatile organic compound (VOC) emissions from Consumer Product (CP) 

sources. The California Air Resources Board (ARB) has jurisdiction over Consumer 

Products and developed the near-term control measure ARB-CONS-01 to control VOC 

emissions from CP sources. On top of this, the SCAQMD developed an additional longterm CP control measure, SCLTM-03, that specifies additional VOC CP controls that go 

beyond the ARB CP control measure. Among the additional short-term control measures 

proposed by the district, only CTS-03 was applied to CP sources. CTS-01 measure was 

applied to non-CP district-controlled sources and CTS-04 was not used in the attainment 

demonstration. 

The Consumer Specialty Products Association, Inc. retained ENVIRON to determine the 

effects of removing the SCAQMD’s additional SCLTM-03 CP VOC control measure on 

the 2007 AQMP 8-hour ozone attainment demonstration. 

APPROACH 

ENVIRON acquired the CAMx modeling inputs and outputs from the SCAQMD used in 

the 2007 AQMP 8-hour ozone attainment demonstration modeling. The 2007 AQMP 

ozone modeling database was stored in an IDE hard disk and shipped to ENVIRON in 

Attachment C - CSPA Comments on ARB Agenda Item # 13-2-2
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mid April 2007 by Satoru Mitsutomi at SCAQMD. The disk contained CAMx v4.40beta 

source code and input database for the following modeling periods: 

3⁄4 August 4-7, 1997 

3⁄4 August 4-8, 2004 

3⁄4 May 17-24, 2005 

3⁄4 July 14-19, 2005 

3⁄4 August 2-9, 2005 

3⁄4 August 25-29, 2005 

The modeling input database includes: 

3⁄4 Initial and boundary conditions 

3⁄4 Photolysis rate inputs 

3⁄4 Albedo/haze/ozone inputs 

3⁄4 Landuse input 

3⁄4 Meteorological inputs (height/pressure/wind/temperature/water 

vapor/cloud/rain/vertical diffusivity) 

3⁄4 Merged/premerged area and point-source emissions for base (2002/2004/2005), 

future (2023), and intermediate (2009/2012/2014/2017/2020) years 

3⁄4 Emission control factor inputs 

The disk also contained GEM emission model code and scripts, various emission 

preprocessing tools, and postprocessing tools for CAMx model outputs. The CEPA 

program used to prepare the emission control factors was provided to ENVIRON in late 

May 2007 by Susan Yan at SCAQMD via FTP transfer. 

As noted earlier, three control measures were applied to VOC emissions from CP 

sources: ARB-CONS-01 developed by ARB, and further reductions applied by 

SCAQMD (SCLTM-03 and CTS-03). Emissions adjustment factors for these control 

measures were specified in a CEPA input file. The SCLTM-03 CP control measure was 

removed from the 2007 AQMP control plan by setting the adjustment factors for the 

SCLTM-03 in the CEPA input file to 1.0 and re-running the CEPA program. The 2023 

modeling was performed without the additional SCLTM-03 CP control measure to 

determine whether it is needed to attain the 8-hour ozone NAAQS in southern California. 

RESULTS 

ENVIRON first tried to reproduce the 2023 8-hour ozone attainment demonstration 

published in the 2007 AQMP using the 2002 base case and 2023 control case CAMx 

output files provided by the SCAQMD. The calculated 2023 8-hour ozone Design 

Values for the 2007 AQMP control plan were close, but did not exactly match the values 

published in the 2007 AQMP. The differences were traced to differences in the CAMx 

2002 base case ozone estimates. The SCAQMD was contacted and the district staff 

noted the CAMx 2002 base case emissions inputs used in generating the 2023 8-hour 

Attachment C - CSPA Comments on ARB Agenda Item # 13-2-2
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ozone Design Values published in the 2007 AQMP were different than what was 

supplied to ENVIRON and that the emission files had been accidentally overwritten so 

could not be provided at the moment. According to Satoru Mitsutomi, the SCAQMD is 

currently in the process of reproducing the lost emissions and they will be available soon. 

Instead, the SCAQMD provided the 2002 base case CAMx modeling outputs that it 

claims were used for the 2007 AQMP. Although using the output data made it possible 

to reproduce the ozone Design Values published in the 2007 AQMP within rounding 

error (it appears that the design values published in the 2007 AQMP were rounded; 

ENVIRON used truncation, which is conventional for design value calculation) for most 

of the monitoring sites, there still was a significant difference in the design value 

ENVIRON calculated and that published in the 2007 AQMP for two of the sites: Azusa 

and Burbank.†

 For this analysis, ENVIRON proceeded using the 2002 base case 

modeling results provided by the SCAQMD, whose use still demonstrated that 8-hour 

ozone attainment would be achieved in 2023 under the 2007 AQMP control plan. 

The SCLTM-03 CP control measure was then eliminated from the 2007 AQMP control 

plan and new 2023 modeling was performed that included all of the control measures in 

the 2007 AQMP with the exception of the SCLTM-03 CP control measures. In the 2023 

base case, there was a total of 496 tons per day (TPD) of anthropogenic VOC emissions, 

114 TPD associated with CP sources. The 114 TPD CP VOC emissions are adjusted 

downwind by 5 TPD for a baseline adjustment and reduced an additional 14 TPD, 2.5 

TPD and 21 TPD due to the ARB-CONS-01, CTS-03, and SCLTM-03 CP control 

measures, respectively. Based on the adjustment factors specified for each of the control 

measures, the CEPA program generates the control factor inputs, which are then used by 

GEM emission model to prepare future year emissions inputs for CAMx. 

Table 1 displays the projected 8-hour ozone Design Values in 2023 (1) as published in 

the 2007 AQMP; (2) as calculated by ENVIRON using the 2002 base case and 2023 

AQMP control case CAMx output files as provided by the SCAQMD; and (3) as 

calculated by ENVIRON using the 2002 base case CAMx outputs provided by the 

SCAQMD and the 2023 CAMx output generated by ENVIRON that represents 

implementation of all control measures in the 2007 AQMP except the SCLTM-03 CP 

control measure. The maximum projected 8-hour ozone Design Value anywhere in the 

basin in all three scenarios occurs at the Crestline monitor, where an 83 ppb value was 

published in the 2007 AQMP; as this is less than 85 ppb, it therefore demonstrates 

attainment. The Crestline Design Value calculated by ENVIRON using the 2007 AQMP 

data provided by the SCAQMD was 84 ppb, 1 ppb higher than was published in the 2007 

AQMP but still below 85 ppb, so still demonstrating attainment of the 8-hour ozone 

standard. The removal of the SCLTM-03 CP control measures has no effect on the 

 

†

 Seeing different Design Values than those published even using the SCAQMD modeling outputs, it 

appears that the district has used a different methodology for the two sites. It is not clear in the AQMP 

document, however, what the methodology is. It is also noted that there exist some inconsistencies in the 

document: for example, multiplying the 2002 Design Value by the published RRF does not produce the 

published 2023 Design Value for some sites, including Azusa and Burbank. Nevertheless, it is immaterial 

since both sites are in attainment in either case. 

Attachment C - CSPA Comments on ARB Agenda Item # 13-2-2
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projected Design Value at Crestline so attainment is still demonstrated even without the 

SCLTM-03 CP control measure. 

CONCLUSIONS 

Removal of the SCLTM-03 additional Consumer Product VOC control measure from the 

2007 AQMP control plan does not affect the 2023 8-hour ozone attainment 

demonstration. Thus, the 2007 AQMP control plan without the SCLTM-03 measure is a 

viable and more cost-effective 8-hour ozone attainment plan. This result is not surprising 

since the SCAQMD is pursuing a NOx-heavy emissions control strategy in the 2007 

AQMP; once ozone goes over the “ridge line” in the VOC/NOx isopleths, further NOx 

control very effectively reduces ozone concentrations. One reason for the pursuit of the 

NOx heavy control plan is the presence of large amounts of uncontrollable biogenic VOC 

emissions, which explains the little sensitivity of ozone to the CP SCLTM-03 VOC 

control measure. 

Table 1. Projected 2023 8-hour ozone Design Values (ppb) for the 2007 AQMP control 

plan (1) as published in the 2007 AQMP and (2) as calculated by ENVIRON using the 

CAMx output data as provided by the SCAQMD and (3) as calculated by ENVIRON 

removing just the SCLTM-03 CP control measures fro the 2007 AQMP control plan. 

Monitoring Published(1) Calculated(2) Calculated(3)

Site 2007 2007 without 

 AQMP AQMP SCLTM-03 

Azusa 69 61 62 

Banning Airport 68 67 68 

Burbank 63 68 68 

Crestline 83 84 84 

Elsinore 62 61 61 

Fontana 81 80 81 

Glendora 79 79 80 

Indio Jackson 56 55 55 

Pasadena 73 72 73 

Perris 79 79 80 

Palm Springs 59 58 58 

Pomona 75 75 76 

Redlands 81 81 81 

Reseda 66 66 66 

Rubidoux 76 76 77 

Santa Clarita 74 74 75 

Attachment C - CSPA Comments on ARB Agenda Item # 13-2-2