2008 PM2.5 Plan 

## Appendix J

Comments and Responses2008 PM2.5 Plan This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-1 

## Appendix J: Comments and Responses

This Appendix contains comments receiv ed during the District’s public workshops and during the public comment periods following those workshops. This appendix also contains the District’s responses to those comments. In most cases, the responses include the verbal response given at the workshop; occasionally, supplemental information was added to clarify and enhance the initial verbal response.

The District’s first workshops on the Draft 2008 PM2.5 Plan were held on December 18 and 19, 2007, and the public comment period for this first draft closed on January 9,

2008. Verbal comments from the December 2007 workshops are reported in the order in which they were received in Section J.5, and written comment s are summarized and organized by topic in Section J.6.

The District held workshops on the 2 nd Draft 2008 PM2.5 Plan were held on February 25 and 26, 2008, and the public comment period fo r this second draft closed on March 5,

2008. Verbal comments from the February 2008 workshops are reported in the order in which they were received in Section J. 3, and written comments are summarized and organized by topic in Section J.4.

The California Cotton Ginners and Growers A ssociations requested that the District complete a more thorough analysis and re sponse to documentation submitted on January 7, 2008. This is presented in Section J.2.

The District held a 30-day public review period on the Proposed 2008 PM2.5 Plan from March 13, 2008 through April 14, 2008. T hese written comments are summarized and organized by topic in Section J.1.

J.1 WRITTEN COMMENTS ON TH E PROPOSED 2008 PM2.5 PLAN

Comment period held from Marc h 13, 2008 through April 14, 2008.

Comments were received from the following people and organizations:

Coalition for Clean Air (CCA) On behalf of the Central Valley Air Qua lity Coalition, Fresno Metro Ministry,

Fresno/Madera Medical Soci ety, Latino Environmental Advancement and Policy Institute, Madera Coalition for Community Justice, Medical Advocates for Healthy Air, Merced-Mariposa Asthma Coalition, the Merced Stop Wal-Mart Action Team, and the Center on Race, Poverty, and the Environment International Sustainable Syst ems Research Center (ISSRC) Evan Shipp (Shipp)San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-2 Health Impacts of PM2.5

1. Comment: PM2.5 is known to cause prem ature death, heart disease, heart attacks, cancer, asthma, and other respirat ory problems. These impacts cost the Valley over $3 billion each year. PM2.5 needs to be cleaned up without delay. (CCA, Shipp) Response: Comment noted. The District is committed to improving public

health.

State PM2.5 Standard and th e 2006 Federal PM2.5 Standard

2. Comment: Despite repeated requests, the pl an doesn’t include information about its progress towards the more health protective California PM2.5 standard

and the 2006 Federal PM2.5 St andard. The plan should include more specific information about how and by when this pl an makes progress towards the more health protective standards. (CCA) Response: Attaining the 1997 PM2.5 standard will help the Valley make significant progress towards the 2006 PM2.5 standard and t he state standard.

The levels of these standards are shown in Chapter 2, in Table 2-1. The 24-hour average levels that are expected to be achieved by this plan are shown in Appendix H in Table H-4. However, while the annual averages presented in the plan (in Table H-3, calculat ed for the federal standard) c an provide an estimate of progress towards the state standard, it should be not ed that the State standard

uses a different calculation for the form of the standard, and t hus the two are not directly comparable.

The District is prohibited by state law (C alifornia Health and Safety Code 39602) from including measures in the SIP that are not required by the Clean Air Act.

Control measures that are needed to attain the state PM2.5 standard and/or the 2006 PM2.5 standard, but not needed for the 1997 PM2.5 standar d are therefore not appropriate for this SIP submittal.

Attainment Year

3. Comment: According to EPA’s Guidance on the Use of Models and Other Analysis for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze (April 2007), attainment is based on three-year averages. EPA guidance says that if, at the attainment date, the three year average is

above the standard while the dat a for the single year i mmediately preceding the

attainment date is within the standard (and it planning requirements have been met), the area is eligible for a 1-year ex tension. This implies that the modeled year of 2014 is the single year of 2014 and not an average of 2012-2014,

otherwise the document would not mention o ne-year extensions. It follows that in basing attainment on a 2014 carrying capac ity, it seems that the District isSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-3 planning on seeking a one-year extension for attainment in 2015. However, the plan only ensures sufficient NOx reducti ons for 2014, when the design value will be 14.68 μg/m3 (according to the regional modeling). When averaged with higher annual averages in 2012 and 2013, the Valley will not actually be in attainment in 2014. Therefore, the Valley will be in violation of t he Federal Clean Air Act for failure to attain the standard by Ap ril 5, 2015. The modeling uses 2004-2006 averages for the baseline year of 2005. Therefore, it could conceivably be interpreted that the 2014 design value is based on 2013-2015 data. (ISSRC) Response: EPA established guidance for selecting both the base year for modeling and the future year for modeling for development of the PM2.5 SIP. It should be noted that guidance for developing the plan to accomplish attainment is separate from the guidance for the retr ospective review of air monitoring data to demonstrate compliance with the standard. Planning relies on design values that by EPA nomenclature are defined by the middle year of the period. Attainment is determined on three prior year s of observations. The selection of years to model for development of the plan and the procedure for modeling are in compliance with EPA guidance.

The same EPA guidance referenced in the comment directs the District to model the year before the pr ojected attainment year, as the year to model for the “final” year for planning purposes. In this gui dance, EPA reference to a baseline year is the middle year of a design value period of several years. EPA nomenclature for describing the design value period with a single year number does not imply that the design value represents only one year. “PM2.5 Design value” is defined in 40 CFR Part 51, Subpart Z, Section 51.1000 as “the highest of the three-year average concentrations calculated for t he monitors in the area.” For more information on design values, please refe r to Section 2a of Appendix H and Table A-12 and Section A-4 in Appendix A. The relative modeling response between a baseline emissions year and a future emi ssions projection year is multiplied by the design value to predict the future des ign value. This projected design value is used to determine the sufficiency of t he plan, from a planning perspective, and

must meet the standard or be close to the standard and be confirmed as an acceptable target through weig ht of evidence evaluation. Because the projection to 2014 was close to the standard, both t he District and ARB prepared weight of

evidence evaluations that conclude t hat the PM2.5 plan meets requirements established by EPA.

At some future date, EPA will determine whether attainment has been achieved using actual monitored data. While t he attainment deadline is in early 2015, monitoring data for 2014 may not be fully certified until quality assurance has been completed and is submitted to EPA as r equired by July 1, 2015. Only after

all data is certified and EPA conducts its evaluation of progress will it be possible

to determine if attainment has been achi eved. The District believes that the progress predicted by the modeling is c onservative and has also committed to a variety of additional reduc tion efforts to advance progre ss for attainment. Many

of the additional reductions are not quantified in the model due to EPASan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-4 constraints on accounting for reducti ons that are not fully funded or are conducted through voluntary pr ograms. The District belie ves that attainment will be achieved well before 2015 and does not plan to seek a one-year extension.

4. Comment: The District claims to have modeled each three-year design value period from 2009 through 2014 (Comment #36, March 13 draft). Where are the predicted future annual design values for 2009 through 2014? (ISSRC) Response: The Weight of Evidence approach requires that several different metrics be used to evaluate air quality progr ess. The District’s receptor modeling was conducted for each year between 2009 and 2014 to determine when each site in the Valley could be expected to comply with the annual PM2.5 standard.

Results of these evaluations are incl uded in Table 3-2 as the "Predicted Compliance Year" with discussion for eac h site included in Section 3.4.1 Discussion of Results. ARB’s regi onal photochemical modeling was conducted

for for 2007-2009 and 2012-2014. Table 9-1 s hows the attainment outlook for the years 2009-2014 based on an analysis of the projected controlled emissions inventories. Because ARB’s regional modeling was only able to demonstrate attainment by including new emission reductions in the 2008 PM2.5 Plan , it can be surmised that repeating the regional modeling for ea rlier years (with higher emissions than 2014) would not demonstrate attainment.

5. Comment: The District indicates that it conducted a thorough review of EPA Guidance. However, the District fails to mention that the EPA Guidance document (EPA 465/B-07-002) assumes that areas will model a future year based on attaining within the first 5-year period (by 2009, in this case): “The procedures for justifying an extension of the attainment date are contained in the PM implementation rule (40 CFR 50.1004) . In this guidance document, we will assume that areas will model a future y ear based on attaining within the first 5 year period.” The document goes on to i ndicate that “Area that request and are granted attainment date ex tensions should consult with their Regional Office regarding future year modelin g analyses and requirements.” (ISSRC) Response: The District has followed the procedures of the PM2.5 Implementation rule as well as EPA m odeling guidance. The District and ARB have worked very closely with EPA R egion IX on modeling for the PM2.5

Attainment demonstration. EPA staff has agreed with the approach presented by

the District and ARB. See also comment 4.

Reasonable Further Progress

6. Comment: Reasonable Further Progress (R FP) is important for ensuring

continuous health benefits as an area progresses towards attainment. (ISSRC) Response: Comment noted. Based on the analys is of Dr. Jane Hall, the District and ARB strategy will result in the elimin ation of an estima ted 460 prematureSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-5 deaths each year when the entire air basin r eaches attainment. Before that time it is estimated that 1500 premature deat hs will be avoided due to improving air quality.

7. Comment: Table 8-4 shows continuous and generally linear progress towards attainment by achieving between 2% and 5% per year of emission reductions of direct PM2.5 and NOx. However, EPA noted that “requiring a fixed annual emissions reduction percentage would impo st a ‘one-size-fits-all’ approach. ... The EPA believes that defining the RFP requ irement in terms of generally linear progress toward the emissions reductions needed for timely attainment assures that each area will achieve a steady rate of progress most appropriate for the area to achieve timely attainment.” (72 FR 20635) (ISSRC) Response: While EPA chose not to impose st rict percentage reductions to apply nationwide, the PM2.5 Im plementation Rule does not preclude regions from calculating their own perc entage reductions. Table 8-4 helps to demonstrate that the Valley’s progress towards a ttainment is generally linear.

8. Comment: The plan does not follow the proc edure for showing “generally linear progress as described by EPA’s example, wherein a region with a baseyear of 2005 and an attainment year of 2014 has to show 4/9 of the reductions needed by 2009 and 7/9 of the r eductions needed in 2012. (ISSRC) There is an RFP

shortfall for 2009 and 2012. (ISSRC, CCA) Response: The calculation noted by the commenter is outlined as 2009 and 2012 benchmarks in Table 8-2 in Chapter 8. The comparison of actual reductions to these benchmarks (the RFP shortfall noted by the commenter) is

shown in Table 8-3. Ho wever, EPA also notes (72 FR20635) that a one-sizefits-all approach is not appropriate for RFP. Generally linear progress is shown

for 2009 and 2012. Due to the innovative nature of ARB’s new measures and the technical complexities of implementat ion, the final increm ent of the emission

reductions needed for attainment will not occur until 2014.

9. Comment: 2012 reductions for ARB’s rules should be incorporated into the RFP

calculations. (ISSRC) The time of ARB’s truck Ru le implementation poses a significant challenge to the Valley’s abi lity to demonstrate RFP milestones in

2009 and 2012. (CCA) Response: At ARB’s direction, ARB contro l measure commitments do not show reductions prior to 2014, due to the complexi ties of implementat ion. Although the District agrees with the commenter that AR B emission reductions will likely occur prior to 2014, ARB has not committed to pre-2014 emission reductions. The District has called on ARB to expedite and commit to earlier reductions.

Contingency MeasuresSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-6 10. Comment: In Comment #22 in fo r the March 13 draft, the District said that ISSRC commented that $30 m illion in fees would bring 1/5 tpd of NOx reductions. In actuality, ISSRC wrote t hat $30 million would result in 1.5 tpd of

NOx. Please ack nowledge the error. (ISSRC) Response: This typographical error has been corrected.

11. Comment: The plan proposes three ways of meeting contingency measure requirements. Of the thr ee, only the current program using secured incentive funding clearly qualities as a contingency measure. Requesting ARB to accelerate implementation of state m easures (as South Coast proposes as contingency in their AQMP) could be costly, and it does not result in timely reductions. Using fees from failure to reach attainment of the 1-hour ozone

standard seems to indicate that the succe ss of bringing clean air to the Valley is contingent upon the failure to attain cl ean air (i.e., PM2.5 standards will be met, only if the 1-hour ozone standard is not met) . Furthermore, these fees will not be realized by the beginning of 2013, and they will result, at best, in 1.5 tpd of NOx

reductions. (ISSRC) Response: The plan implements all feasib le measures. No significant

additional emission reductions have been id entified that could be set aside and used only if needed for contingency. Bec ause real reductions from unsecured incentive funds cannot yet be counted as a federal commitment, the District believes these are appropriate contingency reductions. Prop 1B funding in the amount of $200 millio n would generate approximatel y 8 tpd of NOx, at $25 million/ton per day.

The District is not waiting to request ti mely adoption and impl ementation of state control measures. One of the primary components of the District’s Fast Track program is to compel the ARB to expedite its regulations and assure they are as effective as possible.

The commenter’s summary statement (“PM2 .5 standards will be met, only if the 1-hour ozone standard is not met”) unfai rly characterizes this contingency

measure. The District intends to attain both standards in a time ly manner. If, the unfortunate and unlikely event of nonattainment of the former 1-hr ozone standard in 2010 were to occur, additional fee revenue from any source would be put to use to expedite the attainment of all standards. Emission reductions from adopted Rule 3170 represent rule-based reductions not used in RFP or attainment demonstrations, and therefor e meet EPA’s criteria for contingency measures as given in 72 FR 20643.

12. Comment: Even with the District proposed c ontingency measures, the possible 3.5 tpd of NOx reducti ons feasible fall short of the required 31.5 tpd. The District

should consider the followi ng as contingency measures:San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-7 • Ban the use of pre-tier 3 off-r oad engines during high pollution days, as similarly proposed by the South Coast. In addition, the District should ban the use of pre-tier 3 agri cultural engines, such as tractors and harvesters during high pollution days.

• Require technologically feasible BACT-level technology on all existing stationary sources and allow alternativ e compliance, such as retrofitting mobile sources, which effects equivalent reductions.

• Furthermore, the District should accelerate the adoption and implementation of rules to the ext ent feasible, as proposed for state

mobile sources. (ISSRC)

• Operational controls, including limi ting the use of industrial equipment on high pollution days (CCA)

. Response: The 31.5 tpd cited by the commenter is an EPA recommendation, not a requirement embodi ed in regulatory language.

The contingency measures currently stated in the plan achieve more than 3.5 tpd

of NOx reductions. We will correct section 9.2.2.2.2 of the Plan to show that $90 million per year will cause a cumulative in crease in emission reductions. Adding $90 million each year would get an additional 3.6 tons per day each year. After 5 years, for example, the cumula tive reduction would be 18 tpd.

Requiring technologically-feasib le BACT on all existing stationary sources is the District’s primary strategy for reducing emissions under its jurisdiction.

Prohibiting the use of rela tively new Tier 1 and Tier 2 engines – which were purchased using public funds - on a s poradic, non-predictable basis could be disruptive and financially disastrous fo r smaller businesses. EPA notes that unreasonable measures, which are absurd, unenforceable, impractical, or that would cause severely disruptive socioecon omic impacts (e.g., gas rationing and mandatory source shutdowns), ar e not required by the Act (72 FR 20613). The District thus deems operational controls to be inappropriate as contingency

measures at this time.

Mid-course review

13. Comment: The PM2.5 Implementation Rule r equires areas that plan attainment beyond the first five-year period to conduct a mid-course review of the plan by April 2011. ISSRC recommends that a mid- course review be done right after the adoption of ARB’s proposed tr uck rule (the end of 2009). (ISSRC) Response: The District will be continuously eval uating the situation regarding PM2.5. Rather than committing to an ear ly and possibly premature mid-course review, the District will allow sufficient time for research and development to come to fruition, thereby providing important data for evaluating PM2.5.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-8 Control Measures

14. Comment: The Plan’s analysis of control m easures that could be deemed Reasonably Available Control Technolog y (RACT) for stationary sources and Reasonably Available Control Measures (RACM) for all sources, including area sources and stationary sources, is inadeq uate. Potential m easures that are reasonably available considering techni cal and economic feasibility must be adopted as RACM if, considered collectivel y, they would advance the attainment date by one year or more. For example, a modest 10% reduction of PM2.5 from agricultural sources by enhancing the Conservation Management Practices Requirement or by removing ex emptions for on-field agricu ltural operations in the Fugitive Dust Rules (Regulation VIII) would show that attainment could be advance by one year, without serious disrupt ions of agricultural activities. (ISSRC) Response: The discussion of RACM in Sect ion 6.2 of the Plan meets federal requirements. Appendix I of the Plan iden tifies in detail the measures considered by the District. The State has submitted a similar strategy for emissions sources under their jurisdiction.

With so many ARB reductions occurring in 2014, it would take a very large magnitude of reductions to advance attain ment by one year. Furthermore, the commenter is assuming that reducing agr icultural fugitive dust emissions will automatically and assuredly im prove PM2.5 air quality. The District, on the other hand, must assure that proposed control measures will actually benefit air quality, and not just reflect “paper reductions.” The Dis trict understands that the highest concentrations of PM2.5 occur during the wintertime in urban areas, when and where agricultural fugitive dust c oncentrations are relatively low. As shown in Chapter 6, both agricultural and non-agricultural fugitive dust emissions

are scheduled for review via feasibi lity studies to better determine their

contribution to the PM2.5 emission in ventory and the efficacy of potential

controls.

15. Comment: There should be more stringent NOx controls on the following sources: medium boilers, small boilers , glass melting furnaces, IC Engines, Dryers, and Solid-fuel Boilers. A 40% reduction of 2012 emi ssions from these categories would result in 17.13 tpd of NOx reductions. (ISSRC) Response: ARB has commended the District current rules as being some of the most stringent in the state, setting the benchmark for stationary source control (Air Resources Board Staff Report on Accelerating San Joaquin Valley Air Quality Progress (2007)). As stated frequently througho ut the development of the Plan, the District will be applying the most effective controls to all stationary sources according to the rulemaking schedu le in Chapter 6. We welcome the commenter’s input on technological feasib ility issues during the rulemaking projects.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-9 It is noted that some of the commenter ’s estimated reductions do not equate to

40% of the commenter’s stat ed baseline emissions. It is also unclear why the commenter chose a general 40% reduction for all categories.

16. Comment: There should be more stringent PM2.5 controls on the following sources: On-field Farming Operations; Co nstruction, Demolition, Excavation & Other Earthmoving Activities; Open Areas ; Paved & Unpaved Roads; Agricultural Sources; and Prescribed Burning & Haza rd Reduction Burning. A 10%

reduction of 2012 emissions from these ca tegories would result in 5.3 tpd of

PM2.5 reductions. (ISSRC) Response: Without supporting information, it is unclear why the commenter assigned 10% reductions to all categor ies without supporting discussion. As stated frequently throughout the developm ent of the Plan, the District will be applying the most effective controls to all stationary sources according to the rulemaking schedule in Chapter 6. We welcome the commenter’s input on technological feasibility issues during the rulemaking projects and feasibility

studies.

17. Comment: There should be more stringent VOC controls on the following sources: Confined Animal Facilities, Composting Biosolids, Composting Greenwaste, Wine Fermentation and Storage Tanks, and Brandy and Wine Aging. A 40% reduction of 2012 emissions from thes e categories would result in 32.14 tpd of VOC reductions. (ISSRC) Response: See response to comment 15 above. ARB modeling has shown that

VOC reductions are not as effective in reducing secondary PM 2.5 as NOx or SO 2 reductions.

18. Comment: When the more stringent NOx, PM2.5, and VOC reductions [Comments 18-20] are evaluated for NO x equivalency, attainment can be

reached in 2013. (ISSRC) Response: The commenter’s proposed reductions and equivalency factors are unsupported. Using this approach to claim earlier attainment would be questionable from a technical perspective . Also, the commenter’s controlled 2013 emissions inventory is still 93 tpd abov e the target NOx level presented in Chapter 9 of the Plan.

19. Comment: The commenter (ISSRC) resubmitted their draft control measures to

show where additional control me asure improvements are possible. Response: Please refer to responses previo usly provided by the District.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-10 20. Comment: The District should take a more vocal and public approach to urge ARB to follow through on its commitments. (CCA) Response: Comment noted. See response to comment 9.

21. Comment: Opportunities for additional direct PM emissions, such as limiting exemptions for open burning sh ould be further explored. (CCA) Response: Open burning exceptions are alr eady tightly controlled. Open burning is prohibited on days where it could lead to an exceedance of the federal

air standards.

22. Comment: Additional reductions should be obtained from secondary PM2.5

sources such as internal combustion engines, glass-melting furnaces, boilers, and dryers and the District should commit to those reductions in the plan. (CCA) Response: The Plan already contains the indicated control measures and the governing Board has also made a commi tment to these measures in the 2007
Ozone Plan . No additional reductions are expected over what is indicated in Chapter 6.

23. Comment: The Plan should include control meas ures for measures that reduce VOC emissions from coatings, solvent s, composting operations, sumps and refinery equipment. (CCA) Response: EPA guidance does not require such control measures in this plan unless they are required to demonstrate compliance with the PM2.5 standard. All of the categories mentioned, however, are commitments in the 2007 Ozone

Plan and will not result in additional control measure commitments.

24. Comment: The current proposed PM2.5 plan re lies almost exclusively on the upcoming, not-yet adopted Air Resources Board (ARB) Heavy Duty Diesel Truck Rule. While we acknowledge the signific ance of this rule to help reduce PM2.5 levels in the Valley, we are concerned t hat most of the emi ssion reductions from

this rule will not be actualized in t he Valley until 2014 at the earliest. (CCA) Response: Comment noted. With about 37% of the Valley’s NOx inventory coming from heavy heavy duty diesel trucks, ARB’s measure is indeed a crucial part of the plan’s strategy . It is also important to note that ARB’s emission reduction commitment is binding, and mu st be achieved once the statewide strategy is approved by EPA.

Modeling and Technical Issues

Summary of comments received from Evan ShippSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-11 Comments were provided on t he PM2.5 SIP regardi ng meteorological assessments, modeling and air quality data to be used for the PM2.5 SIP. In addition to general remarks, 27 page identifications were prov ided where the issues discussed in his general remarks were mentioned. Sevent een comments on District responses to his previous questions were submitted and attached all of his previous comments as

reference documentation.

Meteorology

25. Comment: The District needs to ensure that attainment will occur even under worst-case meteorology. Because the 2004-2006 period had better dispersive meteorology, these design values ar e non-representative. The 2005 design value may not be the best year to project into future years. (Shipp) Response: The premise of this comment is in conflict with the form of the air quality standard and the guidance from EPA on selection of the years to be

modeled. The standard is not based on wo rst case and the form of the standard is to minimize the influence of meteorologi cal variation on the design of the plan. That is why the design value is aver aged across three years, to minimize exaggeration of cont rol requirements that might be implied by a single year’s unusual meteorology or atypic al events. The basis of the plan, as recommended by EPA guidance, confirmed by c onsultation with EPA and using EPA terminology, is the 2005 design value, representing the aver ages of 2004 to 2006 data rather than a single year as suggested. The averaging of three years is

done to remove over and underestimation due to single year variations of meteorology. Mode ling is conducted for specific years s recommended by EPA but is only used in a relative fashion with the rate of change between the beginning and end year of the modeling projection (Relat ive Reduction Factor – RRF) being applied to the three year base des ign value. Note carefully that the

form of the health-based st andard is not based on the highest worst-case value,

but rather the 98 th percentile value averaged across th ree years. It is possible to be in full compliance with the air quality health standard and still have a few days with higher concentrations at each si te. Where data collection has missing samples, EPA has established the procedur es, which the District has followed, that are to be used to provide co rrection for missing data (see detailed explanation in Appendix A.3.2).

26. There should be more meteorol ogical evaluation. The District indicated that it reviewed 100 years of meteorologica l data, but it didn’t provide any documentation; this evaluation should be included in the plan. The District

dismisses the correlation of PM2.5 to the stability index as being poor, yet these indicators are used in CRPAQS analysis and in the District’s daily PM2.5 forecast. As stated in previous co mments, the trend charts need to reflect fluctuations in meteorology by us ing adjustment methods and/or analyzing meteorological parameters that correlate to PM2.5. Trends charts on pages A-14 though A-24 need to reflect fluctuations in meteorology. Again, as stated above,San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-12 these comparisons with 1999-2001 and 2004-2006 need a meteorological

evaluation. (Shipp) Response: The District selected those evalua tions that provided the most probative value as items to be included wi th the plan. The District has not received other requests for the 100-year me teorological analysis but will consider issuing the information as a separate docum ent in the near future to be available on public request. The District completed this analysis, speciation data analysis, persistence evaluation and a variety of te chnical assessments as a preparatory analyses for the PM2.5 SIP. The District has documented many of the results of technical evaluations in Appendix E. Additional analyses are documented by ARB in Appendix H. As the 100-year meteorological analysis provided a negative finding that recent years were not atypical and did not represent a special pattern, the publication of an extensive negative assessment does not

seem to be of reasonable value fo r inclusion within the Plan.

Note that stability is a factor used by the District and within CRPAQS to predict whether particulate levels can be expected to rise or fall but is not a strong predictor of absolute magnitude of particulate concentration.

The statistics reported on pages A-14 th rough A-24 follow standard methods. The suggestion for meteorological indexi ng of trend data is innovative and has been attempted in a few journal publications but generally require s a larger set of data for acceptable determination of unc ertainty. The District will stay with standard methods until a larger data set is available and alternative methodologies are developed and accepted by EPA.

27. Comment: Section 3.2.1 on Natural Conditions of the Valley should state that

PM2.5 emissions could be retained in t he air basin for up to one month (as seen
in the 2000-2001 CRPAQS episodes). Assessment of representative meteorology should include how long episodes last. The description of

subsidence does not account for the humid ity increase at the surface as water vapor is trapped by the dry warm air above it (a factor during major winter PM2.5 events). (Shipp) Response: The first part of this comment imp lies that the stagnation events are progressive and cumulative for the entire period. That is not confirmed when diurnal data or analysis of persistence and particulate peak concentration is considered. The variations in atmospheric chemistry and other effects, such as deposition that remove pollutants, cause t he concentrations to rise and fall during extended stagnation events. A statement that the particulate can be retained for a month would imply that concentrations continue to accumulate progressively. Analysis of persistence of events (dete rmined by the daily variation of the meteorology parameter of the difference betw een Oakland and Fresno 850 millibar temperature) has determined that this is not the case. In 1999, concentrations for three to six day persistence events were higher than for events lasting seven to nine days. In 2005, persistence events lasting two toSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-13 eleven days reached similar values (sli ghtly less than 60 micrograms per cubic meter) with one twelve-day event reac hing 71 micrograms per cubic meter.

The increase in humidity during a subsidenc e event is not a significant factor in the calculation of expected particulate concentrations. The range of humidity

where both sulfate and nitrate formation occur is quite broad and therefore in most regimes provides only a tertiary c hange to the particulate concentration, inhibiting nitrate formation only at levels so high as to cause deposition (see the fog discussion Appendix E section 2a to section 2a.4).

Air Quality Data for the PM2.5 SIP

28. Comment: 2007 PM2.5 ambient air quality shoul d be used to calculate design values in the plan. Real time data indicates numerous exceedances of the 24- hour PM2.5 standard in 2007, and real ti me data can be used in the absence of

filter data. This should be incorporated into the Weight of Evidence and page 3- 30 (Air Monitoring and Trends). (Shipp) Response: Uncertified 2007 data cannot be submitt ed as the basis for the plan. At this point it can only be used as a s ensitivity evaluation, which has been done and is discussed in the plan in Secti on 3.4.2 “Weight of Evidence” in the paragraph on Air Monitoring Data and Tr ends. The procedure recommended in

the comment is not in accordance with EPA Guidance. The use of uncertified data and commingling data sets from two di fferent types of monitors is not appropriate and does not comply with establ ished guidance for the processing of air monitoring data. Differences between re al time monitors used to advise daily forecasting and federal reference met hod samplers used to assess compliance with the health standard must be carefully c onsidered. Real time monitors have a higher capture rate for water, VOC arti fact that the FRM would consider as gaseous material, and collection of semivo latiles of nitrate, sulfate and organic

carbon that would not be retained to t he same degree in the FRM sampler that

has been used to establish the health standard limits.

29. Comment: Because the 2004-2006 period h ad missing data, these design values are non-representative. Quarte r completion problems on page A-2 should be investigated – is missing data due to aerosol loading during poor meteorological conditions? Tables A-3 and A-8 are affected by missing data. Weight of evidence (Appendix H) should address missing data during periods of weather stagnation that are conducive to hi gh PM2.5 levels. Failure to address this issue in the design values underestimates the reductions needed to achieve
the NAAQS. (Shipp) Response: All guidance for adjusting for missing data when determining design values have been met, see Appendix A. Even uncertified data has been considered by sensitivity evaluation, s ee Section 3.4.2 “Weight of Evidence” in the paragraph on Air Monitoring Data and Trends. The Design Values and theSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-14 calculation of reductions needed to ac hieve the PM2.5 annual standard follow EPA methodology.

30. Comment: The plan references PM10 atta inment (page 3-27 and 9-3). However, the PM10 Plans didn’t predict exceedances due to natural events (and covered by the Natural Events Action Plan). (Shipp) Response: The modeling is not supposed to pr edict natural events, which are by EPA definition excluded from consideration in determi ning attainment. Natural events are not an appropriate basis for determining the amount of anthropogenic controls that should be imposed. The r equirement for natural events is to establish and impose BACT for sources t hat are commonly affected by natural events. Imposing BACT is intended to mini mize the severity of event that would ensue from the natural event; however, this does not mean that the District is required to prevent a natural event fr om causing an exceedance of the 24-hour standard, only to have a reasonable leve l of control imposed on applicable sources. As established by EPA Guidance, as long as the applicable BACT is in place and enforced, natural events are to be excluded from the nonattainment data determinations. Certainly, under no circumstances are natural events to be used to determine anthropogenic reduction goals.

31. Comment: The species trends in Appendix H, Figure H-14 and H-18 look flat. This should be explained. Figure H-23 is useful for worst-case scenarios, but might not reflect the chemistry involv ed that produces high annual averages.

More documentation is needed on what driv es the annual average (highest days, moderate episodes, etc). (Shipp) Response: The figures referenced are not species trends. They are reaction rate evaluations examining the strengt h of correlation between observed NOx throughout the Valley and local PM2.5 nitrate concentrations. This provides an

evaluation of the formati on dynamics of ammonium ni trate and the influence of NOx concentrations throughout the region on the urban nitrate concentrations.

Since NOx has been determined to be the limiting precursor for urban PM2.5 nitrate, this evaluation is intended to probe for the strength of relationship

between NOx and formed nitrate to determine if the linkage is related to local or regional emissions. Similarly, figur e H-23 and H-24 examine the atmospheric presence of nitric acid and ammonia showin g that ammonia is ubiquitous in the Valley and nitric acid, formed from the r eaction of NOx with hydrocarbons, is the limiting reaction media.

32. Comment: The plan states that the Valley complies with the 24-hour NAAQS, although section 3.3.3 supports the idea that the Distr ict does not have enough data to determine compliance. On page H- 27, it states t hat the Valley has attained of the 24-hour standard [based on 2004-2006 data]. Attainment is not the correct term, as that is an EPA designa tion. Page 3-22, Section 3.4 says thatSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-15 some sites already comply with the NAAQ S, but this should not be stated without rigorous analysis and EPA approvals. (Shipp) Response: Section 3.3.3 identif ies that the fact t hat the FRM monitoring network has been in place for only a few y ears makes it improper to use certain

statistical methods as corroboration for a finding that attain ment will be achieved in the weight of evidenc e determination required for sites where the predicted future design value is close to the standard. It only requires th ree years or more of data to establish District compliance or exceedance of the standard. There is

sufficient data to establish that the Dis trict does not currently comply with the annual PM2.5 standard. Compliance with t he standard is the correct terminology when one or more sites is within specif ied standard limits and the use of this terminology does not require an EPA designati on. Attainment is the term used only when all sites meet both the annual and 24-hour standards and is a designation that must be reviewed and approved by EPA. Attainment is projected to occur by or before 2014 but the Distric t does not automatically receive an attainment designation from EPA when monitoring data shows compliance with the standards. An offici al request for redesignation must be submitted and must comply with a wide variety of require ments including the establishment of a maintenance plan to ensure the District does not go back out of compliance. Due to the revision of the 24-hour standard, the District would not be able to request redesignation until both the annual standard and the new 24-

hour standard have been met at all sites.

Modeling

33. Comment: The plan should show projected PM2.5 concentrations for the intermediate years, not just the attainm ent year, to show steady progress toward

attainment. (Shipp) Response: This task was completed by re ceptor modeling analysis after determining strong agreement between rec eptor and regional m odeling results,

see section 3.4 Table 3-2 where the interv ening year results are used to identify the projected year of compliance for each site (attainment is not the applicable term until all sites comply with bot h parts of the PM2.5 standard and EPA redesignation is granted)

34. Comment: The plan does not include a full phot ochemical model evaluation. Uncertainty assessment and discussion is an integral part of specifying the amount and chemical species to control. (Shipp) Response: ARB is preparing the photochemical model evaluation. The District will rely on ARB to complete this assessment and forward the results to EPA with

the PM2.5 SIP submittal. It s hould be noted that EPA modeling guidance (Section 18.5.3) also recognizes the me thod of using multi-variate source apportionment models (CMB and PMF) to evaluate the uncertainty of the regional model. This process was comple ted by the District and is included inSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-16 the Plan in section 3.4.2. The correlat ion of the modeling me thods is extremely good with results that ar e nearly identical as shown in Table 3-5.

35. Comment : The Plan provides poor document ation of the relative reduction factors, and lack of documentation on how the photochemical model was used to

derive these. The process used to calculate the Relative Reduction Factors (RRFs) and show attainment of the NAAQS is undocumented. According to ARB, RRFs were based on a future year and baseyear model runs. However, a majority of emissions reductions in the pl an occur at the attain ment year, so the modeling system using the bas e and end year inventories is not sufficient. If the documentation files are too big to dow nload and distribute, then the District

and/or ARB should condense this information. (Shipp) Response: The process for SMAT calculations is fully documented in Chapter 3, Appendix F and Appendix G. The procedur es follow EPA guidance with use of the base and end year required as the methodology for SMAT. However, additional modeling was conducted for inte rmediate years with receptor modeling to evaluate the year-by-year progress at each site (see Table 3-2). Note that only the Kern County site requires t he 2014 reductions to reach compliance;

therefore it is not appropriate to imply that the District Plan places too much

reliance on 2014 reductions. The District and ARB have condensed the results

of the detailed technical calculations into tables provided in Chapter 3 and Appendix G. Receptor m odeling files for the year 2014 are posted and the receptor files for other years are avai lable on request. ARB produced the SMAT calculation files for the regional model, but these files are too large to be provided

as a download link.

36. Comment: Section 3.3.3 should document t he conclusion that the annual standard is more stringent than the 24-hour NAAQS. (Shipp) Response: See section 3.4.2 Weight of Evidence Conclusion on page 3-31.

37. Comment: Page 3-20 says that t he District will perform t he SMAT analyses, but ARB performed these analyses. More doc umentation of SMAT calculations should be provided on page 3-23. (Shipp) Response: The District performed SMAT for the receptor models, ARB performed SMAT for the regional model. Additional documentat ion of the SMAT procedure is included in the Appendix F SJV PM2.5 Modelin g Protocol and Appendix G Regional Air Qua lity Modeling. Procedures used are in accordance

with EPA Guidance. The District does not agree that the massive calculation

files should be included within the text of the plan. The District and ARB have

condensed the results of the detailed techni cal calculations into tables provided in Chapter 3 and Appendix G.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-17 38. Comment: PMF and CMB are not independent checks because they still depend on design value calc ulations that are flawed. PMF and CMB corroborate, but more co rroboration is needed, per haps including other photochemical modeling, meteorological adjusted trends, and alternate design

value calculations. (Shipp) Response: The procedure used for design value calculations follows EPA guidance, see Appendix A, and the District does not concur with the assertion that the design value calc ulations are flawed.

EPA modeling guidance (Section 18.5.3) does not agree with the assertion that CMB and PMF do not provide independent corroboration of the regional model. Guidance recognizes the method of usi ng multi-variate source apportionment models (CMB and PMF) as an independent means to corroborate and evaluate the uncertainty of the regional model . Receptor modeling is diagnostic – evaluating what was identified as present in the air. Re gional modeling is prognostic – replicating the accumulation of particulate from emissions inventory inputs and photochemical, chemical and eq uilibrium equations. The observed data is an input for receptor techniques but is not an input for the regional approach where the observed PM2.5 c oncentration data is only used for performance evaluation. The two mode ling approaches do not rely on the same techniques or inputs and these differenc es make them i ndependent from each

other. Additional corroborati on by other techniques is provided to establish the weight of evidence determination that attainment will be achieved by 2014 (see

section 3.4.2 Weight of Evidence and Appendix H: Weight of Evidence ).

39. Comment: ·The District has failed to recognize alternative methods of analysis under the weight of evidence provisio ns of the EPA model ing guidelines. (Shipp) Response: A variety of analyses have been c onsidered by ARB and the District to establish the weight of evidence determi nation that attainment will be achieved by 2014 (see section 3.4.2 Weight of Evidence and Appendix H: Weight of

Evidence ). The weight of evidence guidance provided by EPA is not intended to require that every possible approach be us ed; it identifies acceptable available methods, which may be included in a weight of evidence evaluation. The weight

of evidence determination should be made using enough different approaches to ensure that the projection of attainment does not rely on a single model or approach. The District and ARB a nalyses meet this requirement.

40. Comment: Without a meteorological evaluati on, Figure H-4 is not definitive. The 2001 meteorology was much worst than it was in 2006. This may be the difference in the meteorological trend and not necessarily emissions. As stated in previous comments, the 2004-2006 period had missing data and better dispersive meteorology and therefore is non-repres entative. Method 2 projections may be misleading. (Shipp)San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-18 Response: A weight of evidence determination is conducted because the data

available is often limited and ev ery analysis and modeling approach has

uncertainties and limitations. Individual assessments within a we ight of evidence evaluation are not expected to separately provide definitive information. The point of a weight of evidence determination is to consider a variety of technical factors and evaluations to provide a ssurance that the ov erall findings are reasonable, despite the uncertainties and dat a limitations that affect individual

assessments.

41. Comment: Because photochemistry is non-linear, the RRF’s should be based on multiple cuts in the inventory. If multiple cuts are run, the District should include nitrate, sulfate, and VOC isopleths. An evaluation of the result of control of individual NOx, VOC, EC, and SO 2 needs to be performed. It is the District’s and/or ARB’s responsibility to condens e this information into an easily understandable format showing the output of the photochemical model before

and after control for each chemical s pecies and how that affects the design

value. It is unclear whether the RRFs were the result of numerous modeling runs at various percentage cuts in the invent ory or just the 50% cuts as has been used in the past. In addition, the Dis trict should show alternative species strategies and give more detail on the way the model was used to show that a NOx only strategy is viable. As in the comment above on analyzing intermediate years, the plan needs to provide documentation on speciated RRF’s and predicted species concentrations for inte rmediate years. In addition, a run containing the attainment inv entory should be documented. (Shipp) Response: This comment is based on the approach used for ozone modeling. The procedure for particulate modeling is much different and is described in EPA SMAT methodology (see 3.3. 4, Appendix F and Appendix G). Rather than modeling a few days and doing percent cuts or isopleths as has been done in the past for ozone, the SMAT methodology fo r PM2.5 requires modeling more days and determining relative response from a base modeling year to the projected attainment year for each specified com ponent of the particulate concentration. The results of the regional modeling provide results for each day of the fourteenmonth period with each day having a specif ic meteorological and emissions input file and generating a daily output file. The amount of information developed is extensive and far exceeds the output from previous ozone modeling methods. The SMAT methodology does not follow the old ozone mode ling process of revising emissions until a specific attainm ent run is generated, rather the relative response of the model is used to dete rmine the amount of reductions needed to

achieve attainment.

EPA recommends modeling a full year for the PM2.5 SIP evaluated on at least a quarterly basis. Rather than relying on a few days and performing sensitivity evaluations, the particulate modeling in corporates at least an entire year and establishes variation in response by co mponent on a quarterly or monthly basis.

ARB modeled fourteen months for the regional model evaluated on a quarterlySan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-19 basis for each required component. Region al modeling allows use of equilibrium equations to reflect aerosol chemistry in a more dynamic manner. The CMB receptor modeling incorporated twelve mont hly evaluations for two different sets of years with a component breakdown that is more extensive than required by guidance. Receptor methods allow anal ysis of smaller division of the components, such as dividing the carbon into mobile, vegetative burning and industrial and secondary organic carbon.

42. Comment: Neither the 24-hour nor the annual NAAQS address the issue of the month long episodes the SJV experiences. (Shipp) Response: This comment should be directed to EPA, which is the agency responsible to identify the form of the standards related to health impacts. The

current standards address short-term one-day exposure and chronic annual exposure. The District is not authoriz ed or commissioned to establish additional

health based standards. The most that the Dis trict is able to do is support health studies in our area that might identify addi tional health concerns. The District is proactive in this regard by supporting and fa cilitating health based research in the SJV. Furthermore, although the SJV ex periences protracted stagnation events that last from a few days to two weeks, the particulate levels are not extreme for

the entire duration of these ev ents. Any implication that the particulate levels are above the applicable daily standard for a month at a time would be an exaggeration.

43. Comment: · The District does not address what types of days drive the annual standard and whether those were analyzed fo r NOx limitation. There is still a question as to whether moderate days t hat affect the annual average are NOx

limited. Document whether the NOx limitation on PM 2.5 is verified by the photochemical model for all days. (Shipp) Response: This comment is based on an inco rrect premise that all days must have similar NOx response and that the stra tegy must have the same effect each and every day. This is not a requirem ent or a reasonable expectation. The District has included reduction programs for days dominated by other source contributions including ca rbon, geologic material and sulfate particulate. The

detailed comment for this point also requested detail ed evaluation of VOC and

ammonia. These issues have been t horoughly investigated and discussed in both the Modeling Protocol and Chapter 3 Section 3. 2.6 of the Plan. The assertion that each day must be invest igated by the regional model, even days that meet the standard, is not a correct premise. EPA has outlined guidance that

indicates that VOC and ammonia s hould be presumed as not dominant and should not be the focus of the plan unle ss technical evaluation shows domination by these processes. All of the te chnical evaluations for CRPAQS and prior assessments of regional particulate m odels have indicated that NOx is the

dominant factor and VOC and ammonia are not.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-20 J.2 RE-EVALUATION OF COMMENT S AND RESEARCH SUBMITTED BY THE

CALIFORNIA COTTON GINNERS AND GROW ERS ASSOCIATIONS, JANUARY 7,

2008

The California Cotton Ginners and Growers Association (CCGGA) letter dated January 8, 2007, and technical documents accompanyi ng the letter, have been reviewed by

District staff.

1. Comment: CCGGA requests removal of all fugitive dust candidate control measure proposals and feasib ility studies from the PM2.5 Plan. This request

is based on various recent studies t hat show fugitive dust is a major component of PM10 annually and in aut umn, but PM2.5 is only a small fraction of that PM10 (five to ten percent). This is s upported by a recent study on the fig and almond PM10/PM 2.5 harvest emissions t hat shows a ratio of approximately ten percent PM2.5 contained within the PM10. Recent studies also show that the highest PM2.5 concentrations occur in the winter with ammonium nitrate (amm onium + NOx) as the dominant component and not fugitive dust. In addition, a winter PM2.5 study shows that ammonium nitrate, and to a lesser extent organic carbon, is transported from urban to rural areas. Reference was made to a present ation from the AR B project manager for CRPAQS, Karen Magliano, that i dentified geologic emissions from the

combination of urban and rural sources as a contribution of approximately one microgram to the PM2.5 annual av erage. Furthermore, the FRM (Federal Reference Method) PM2.5 sampler was designed for accuracy of particles generally found in urban env ironments, which generally have two to

four times smaller mass median di ameters (MMD) than do agricultural processing emissions. This sampler design adversely affects the FRM sampling which then produces a higher t han actual PM2.5 for agricultural processing facilities. This is further s upported by source test studies for cotton gin emissions which determined that current EPA-approved source sampling methods may be accurate for PM10, but are reportedly ov erestimating PM2.5 emission levels by as much as 1.5 to 13 times. Response: While agreeing that winter nitrate particulates are a dominant source for annual PM2.5 in the SJV, the District does not concur with the conclusion that geologic sources ma y be dismissed from consideration without further study. The impact on a ttainment must be assessed for all contributing sources. The PM- 10 annual standard of 50 micrograms per cubic meter was given a de minimus lim it of one microgram as a guiding standard for sources large enough to requi re control evaluation. The PM2.5 annual standard of 15 micrograms per cubic meter has no de minimus threshold. Therefore, the geologic contribution to the PM2.5 annual average of one microgram per cubic meter mu st be assessed for its contributing sources and potential for identifiable reduc tions. Feasibility studies will assist the District in determining the actual contribution of PM2.5 from urban and rural sources, identify if rural contribut ions contribute measurably to the peakSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-21 levels, improve the accuracy of emissi on factors for PM2.5 emissions from agricultural activities, determine which PM10 control measures provide PM2.5

emission reductions and est ablish whether PM2.5 redu ctions are achievable from sources emitting geologic material.

The range of values for PM2.5 fraction of PM10 cited in the CCGGA letter for the few activity types for which data is available provides justification for feasibility evaluation to establish PM2.5 actual em issions for a variety of agricultural practices. Improvement of the emissions in ventory requires feasibility studies to determine the ac tual magnitude of PM2.5 contributions from agricultural activities and to det ermine whether existing PM10 measures

have a measurable benefit for PM2.5 or could be refined to enhance their

PM2.5 benefit. Due to the wide variati on in reported results for different activities, PM2.5 emission factors applicable to agricul tural activities require an analysis to improve the emissions estimates. Refining these emissions estimates will require thorough review of technical literature and consultation with agricultural technical representatives and federal and state agencies. In consultation with stakeholders, exper ts and approving agencies, the District will employ a scientific quality assurance program for data collected as part of the feasibility studies, including as sessment and documentation of sampler

bias.

J.3 VERBAL COMMENTS, FEBRUARY 25-2 6, 2008 PUBLIC WORKSHOPS ON THE

2 ND DRAFT 2008 PM2.5 PLAN

J.3.1 February 25, 2:00pm Workshop

Approximately 34 people in attendance (18 Fr esno, 10 Bakersfield, and 6 Modesto)

1. Comment: Will CEQA thresholds be changing? Will the District compute PM2.5 reductions for ISR, and will District have PM2.5 fees for ISR? Response: The District’s CEQA department wil l respond to the commenter.

2. Comment: Will ISR (Indirect Source Review) reductions be incorporated into the

Plan? Response: Reductions from ISR will be incorporated into the next version of the plan. The reductions will be simi lar to those reported in the 2007 Ozone Plan

.

3. Comment: How will population growth affect the District’s 2014 attainment projections?San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-22 Response: Population growth estimates (a s developed by the California Department of Finance) are built into the emissions inventory and attainment

demonstration.

4. Comment: How do drive-through windows impact air quality? Response: Generally, if they have very short wait times, drive-through windows can reduce emissions (as compared to co ld start emissions resulting from shutting off a car and starting it again a few minutes later).

5. Comment: The Plan does not meet RFP requirements for 2009 and 2012. Pre2014 reductions from ARB’s truck regulatio n should be incorporated into the RFP

demonstration. Response: At ARB’s direction, the 2008 PM2.5 Plan does not show pre-2014

reductions for this measure. The EPA’s fi nal rule on RFP stipulates “generally linear progress.” The 2009 and 2012 projected emission s presented in Chapter 8 of the Proposed 2008 PM2.5 Plan meet RFP requirements.

6. Comment: The plan does not satisfy the c ontingency measures requirement. Response: The plan’s contingency measure discussion is in Chapter 9. EPA’s Final Rule for implementing the PM2.5 NAAQS (72 FR 20586) emphasizes that

states should make decisions on cont ingency measures in conjunction with determinations of RACM. EPA also emphas izes that all available measures

needed in order to demonstrate attainment of the standards must be considered first; all remaining measures should then be considered as candidates for contingency measures (74 FR 20643). The District and ARB have complied with this directive by aggressively identify ing control measures for PM2.5 and its precursors; as shown in Chapter 9, these measures are needed to demonstrate attainment in 2014. Remaining measur es (those with reductions not used in demonstrating RFP or attainment) were us ed for contingency, in accordance with EPA’s Final Rule implem enting the PM2.5 NAAQS.

7. Comment: Will District be applying for 1-year extension to show attainment? Meeting the standard based on 2014 data is not enough bec ause attainment is based on three-year averages. Response: The District expects that the Vall ey will attain by 2014, with no extension required. The modeling projects attainm ent based on design values, which are three-year averages, as s pecified in Federal modeling guidance.

8. Comment: The plan should include evaluation of 2007 data and real-time data. Also, the plan reports that District staf f evaluated 100 years of meteorological data; where is this documented?San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-23 Response: 2007 data is available in Appendix A. See also page 3-27. Realtime data is used primarily for air quality forecasting. The 100-year review of meteorological data is available upon request.

9. Comment: There have been studies yielding measured data for PM2.5 from cotton gins. Re-entrained PM 2.5 fugitive dus t is included in the Plan, but dust is not as great a contributor in the winter. Response: The District is continuing to look into these issues.

10. Comment: Would Prop 1B funding help the Valley reach attainment sooner? Response: Increased amounts of Prop 1B funding would assist earlier

attainment.

11. Comment: ARB staff should consider delayi ng implementation of the truck rule by one year, to 2010. ARB would get reductions sooner and only require the replacement of one truck rather than two. Response: This comment has been relayed to ARB staff

12. Comment: Control measures in PM2.5 Plan should be aligned with those in

2007 Ozone Plan and focus on NOx only. All c ontrol measures for directly

emitted PM2.5 and SO 2 should be feasibility studies. Control measures for directly emitted PM2. 5 are very costly. Response: In accordance with federal regula tions (40 CFR 51.1002), this 2008

PM2.5 Plan identifies and evaluates s ources of PM2.5 direct, SO 2 , and NOx for potential control measures. The modeling conducted for this plan shows that the District’s projected PM2.5 and SO 2 reductions are important contributors to 2014 attainment; without these reductions, many more NOx reductions would be needed. The rule development process will a llow for further evaluation of costeffectiveness of controls of direct PM2.5, SO 2 , and NOx.

13. Comment: When will the 2006 PM2.5 standar d be addressed in a plan? Response: This 2008 PM2.5 Plan addresses the 2006 PM2.5 daily NAAQS of 35 μg/m3 in at least two ways. First, the Plan contai ns a commitment to re-open

the residential wood combustion rule to c onsider a number of changes, including establishing the threshold for wood burni ng prohibitions for when the PM2.5 air quality is predicted to be at or above t he level of the 2006 standard (35 μg/m3). Secondly, modeling results presented in Appendix G illustrate progress toward the 35 μg/m3 standard. As dictated by the requirements of the federal Clean Air Act, preparation of a formal plan dedicat ed to the 2006 standard will be linked to the timing of EPA’s official designations under the 2006 standard. Plans will be due in either 2012 or 2013, and the final atta inment year for the 2006 standardSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-24 will be 2019 or 2020. The 2008 PM2.5 Plan will result in quantifiable progress towards the 2006 standard. By 2014, wors t PM2.5 levels are expected to be

more than 50% closer to the 2006 standar d (as compared to 2006 air quality).

14. Comment: It is very important to look at alternatives to open burning. Biomass facilities may not be able to take the cuttings by 2010, as required. Response: District continues to work with industr y to investigate alternatives to open burning.

15. Comment: Additional incentive money is needed. Response: District continues work to identify mo re sources of incentive funding. The District aggressively pursued allocati on of more Proposition 1B funds at ARB’s Board hearing on February 28, 2008. See comment number 10.

16. Comment: Annual analysis shows that PM2.5 formation is NOx limited. Was annualized episodic data used for that analysis? Some days may be NOx limited, and some may be ammonia dominated. Response: The NOx limitation is documented through evaluation of two prior seasonal modeling evaluations and resear ch findings from t he CRPAQS project.

Much of this has been documented in t he modeling protocol (Appendix F). Current regional modeling provides a modeling assessment of each day of a fourteen-month period and continues to establish an annual dominance of ammonium nitrate. Many days during the year have very low levels of ammonium nitrate and are dominated by directly emitted particulate and

ammonium sulfate. It w ould not matter on these days whether ammonium nitrate

is NOx or ammonia limited when it forms in very small amounts. For any

reduction of ammonium nitrate of c onsequence to the annua l PM2.5 standard, we must concentrate on the winter period of high concentrations of ammonium nitrate, which has already been well est ablished by research and modeling as

NOx limited.

The photochemical model output is analyz ed in accordance with EPA guidance for speciated modeled attainment test (S MAT). This is a complex process that involves separate analysis of the main c hemical groups processed by the model (ammonium sulfate, ammonium nitrate, carbon) and use of the model results for each of these separate contributions usi ng the relative response factors (RRF)

from 2005 to 2014. More detail of this process is included in the modeling protocol (Appendix F) and Appendix G.

The development of a SIP control strategy for ozone, PM10 or PM2.5 is based on conditions that cause higher levels of air pollutants. For both PM10 and PM2.5 the key period for analysis is winter, with high levels of ammonium nitrateSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-25 that have been scientifically analyzed by re search project evaluation and several modeling analyses as being NOx limited.

17. Comment: The plan uses straight relative re sponse factor (RRF) out of the photochemical model. Alternative approaches should also be used. Response: The photochemical model output is analyzed in accordance with EPA guidance for speciated modeled attainment test (SMAT). This is a complex process that involves separate analysis of the main chemical groups processed by the model (ammonium sulfate, ammoni um nitrate, carbon) and use of the model results for each of these separat e contributions using the relative response factors (RRF) from 2005 to 2014. More detail of this process is included in the modeling protocol (Appendix F), and A ppendix G that presents the regional model methodology and results. Any alternative model evaluation approach that does not follow EPA modeling guidance would have to be submitted to EPA as a proposed modificati on in the modeling protocol. The District has not identified any alter native calculation procedures for the

attainment demonstration that merit amendment of the pr otocol. The District did identify in the modeling protocol, in part from EPA sources, elements of the approved methodology that are not ideal fo r California or the San Joaquin Valley; however, that does not provide an alte rnative processing procedure for the photochemical model results. Instead of alternative processing of the photochemical model results, it is more useful to compare the results of other analytical approaches including the rec eptor modeling and we ight of evidence evaluation in Chapter 3 of the Plan and in Appendix H to the Plan. These comparisons confirm the findings of the regional modeling results and the receptor analyses are in close agreement and are supported by other weight of evidence analysis.

18. Comment: Control measures should address just one pollutant; SO 2 , PM2.5, and NOx should have separate rules. T he control measures should focus on NOx and designate SO 2 and PM2.5 measures as feasibility studies. Response: See response to comment number 12. The modeling conducted for this plan shows that the Distr ict’s projected PM2.5 and SO 2 reductions are important contributors to 2014 attainment; without thes e reductions, many more

NOx reductions would be needed. The Distr ict believes that multi-pollutant controls can be optimized when considered in a single rule.

19. Comment: Biomass power plants are not the answer for replacing open burning. Other agencies are in rulemaki ng process for measures that will limit composting. Response: The District continues to work with industry on alternatives to open burning.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-26 20. Comment: Future presentations should include slides to show progress towards

the State standards for PM2.5. Response: There is no 24-hour State standard. The State’s annual standard is 12 μg/m3. While the annual averages presen ted in the plan (calculated for the federal standard) can provide an estima te of progress towards the state standard, it should be noted that the Stat e standard uses a different calculation

for the form of the standard.

21. Comment: What is the timing for submitting this plan to EPA? Response: The Plan is due to EPA 4/5/08. It is scheduled to go to the District Board in April 2008 for consideration for adoption. ARB is scheduled to consider the Plan for adoption in May 2008. The District and ARB have discussed this schedule with EPA Region 9 staff, who indi cated that the schedule as presented would not trigger EPA issuance of a finding of failure to submit.

22. Comment: The contingency measures section includes a curious element, saying that failure to attain the 1- hour ozone standard will trigger section 185

fees. These fees will not be available if the Valley attains the standard. Response: Emission reductions from Section 185 fees for failing to attain the
former 1-hour ozone NAAQS are rule- based reductions above and beyond those

used to demonstrate RFP and attainment in this 2008 PM2.5 Plan . As such, they meet EPA requirements for contin gency measures for PM2.5 (72 FR 20642- 20643) and were thus included in this plan.

J.3.2 February 26, 6:30pm Workshop

Approximately 8 people in attendance (5 Fr esno, 3 Bakersfield, and 0 Modesto)

23. Comment: By planning based on 2014 levels, the District seems to expect to need a 1-year attainment extension. Please review the April 2007 EPA Model Guidance, page 35, 2 nd paragraph. Response: The District has conducted a thorough review of said guidance. The District expects that the Va lley will attain by 2014, with no extension required. The modeling projects attainment based on design values, which are three-year

averages.

24. Comment: Are the Healthy Air Living program , incentives, and Fast Track all above and beyond SIP requirements? Response: Yes. Programs such as these l ead the District to expect that

attainment can be achieved before 2014.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-27 25. Comment: How will the current plan im pact the 2006 PM2.5 standard? Response: See the response to comment #13.

26. Comment: Will there be PM2.5 reductions from ISR? Response: Yes. PM2.5 reductions will come fr om reductions in NOx emissions. ISR is expected to achieve about 4. 2 tpd of NOx reduc tions in 2014.

27. Comment: The District should include developers on the list of groups for Healthy Air Living outreach. Response: The District will include developers in outreach.

28. Comment: How and when will the new wood burni ng fireplace regulation affect the number of no-burn nights? Response: There were approximately 13 no- burn nights during the 2007-2008 season Valley-wide (Kern County had the most no-burn nights with 12). Next year, the same regulation will be in place. In 2010, the new rule could result in more no-burn nights (possibly as many as 36 total no burn nights per year in Fresno and 32 in Bakersfield, bas ed on 2006 PM2.5 concentrations).

29. Comment: The District should do more to c oordinate air quality with general plans at the local level. Response: The District’s Air Quality Guidelines for General Plans includes suggested policies for cities and counties to include in their General Plans. The District reviews CEQA documents for general plans and general plan amendments. The District integrates air quality considerations into the General Plan process via its comments on those plans.

30. Comment: Into which emissions category does smoke from wood burning fireplaces fall? Response: It is categorized in the modeling as vegetative burning; chemically, wood smoke from fireplaces is nearly i dentical to smoke from other types of vegetative burning. In the emissions in ventory, fireplaces are part of the Residential Fuel Combustion category.

31. Comment: How does this plan address AB32? Response: The state Air Resources Board and other state agencies have the main workload for AB32. AB32 is incorpor ated into the District’s CEQA projects, and the District may help collect em issions inventory data for AB32.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-28 J.4 WRITTEN COMMENTS, DECEMBER 18 -19, 2007 PUBLIC WORKSHOP ON THE

DRAFT 2008 PM2.5 PLAN

Comment period held through March 5, 2008

Comments were received from the following people and organizations:

California Cotton Ginners and Gr owers Associations (CCGGA) California Grape and Tree Fruit League (CGTFL) California League of Food Processors (CLFP) Central Valley Air Quality Coalition (CVAQC) On behalf of Fresno Metro Ministry, Mader a Coalition for Community Justice, Merced-Mariposa Asthma Coalition, and t he Center on Race, Poverty, and the

Environment Chevron U.S.A. Inc. (CUSA) International Sustainable Syst ems Research Center (ISSRC) Nisei Farmers League (Nisei)

Western States Petroleu m Association (WSPA) Steve Gary (Gary) Sandi Murray (Murray) Evan Shipp (Shipp)

Public Process

1. Comment: Thank you for providing workshops in the evening to allow community residents the opport unity to participate. (CVAQC) Response: Comment noted.

2. Comment: The time period for review for the 2 nd Draft was too short (20 days). (CVAQC) Response: The comment period on the first draf t was 36 days, and there will be a 30-day public comment period on the Pr oposed Plan beginning on March 13,

2008.

Control Measures

3. Comment: The District’s proposal to incorporate PM10 and SO 2 control

measures contradicts the Dis trict’s NOx-based strategy, which previously stated

that PM10 and SO 2 reductions are not needed to attain the 1997 PM2.5 Ambient Air Quality Standard (AAQS) . The proposed PM10 & SO 2 control measures do not conform to federal gui delines which states that measures that are notSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-29 necessary to satisfy Reasonable Fu rther Progress (RFP) or expeditious

attainment are also not required RACT/RACM for t he area, and any measures that collectively, would not advance atta inment by at least one year are not required for PM2.5 RACT/RAC M. Therefore, PM10 and SO 2 control measures should be removed from the plan because the District projects to attain the 1997 PM2.5 AAQS in 2014 (one year prior to the 2015 statutory deadline). (CUSA, WSPA) Response: The Plan has been revised to more clearly explain that the

reductions from PM2.5 and SO 2 controls are required to attain federal AAQS by 2014. This finding was reflected in t he ARB modeling, which was recently received; federal regulations (40 CFR 51.10 02) require their inclusion in the Plan.

The discussion included in previous dra fts of the PM2.5 SIP was intended to

reflect that because the annual PM2.5 c oncentration is almost half ammonium nitrate, the primary focus of controls has to be the precursor to ammonium nitrate, emissions of nitrogen oxides (NOx ). However, the emissions reductions included in the plan and modeling have alwa ys included the reductions of directly emitted PM2.5 and other precursors incl uding SOx. The text of the plan has been improved to reflect this comprehens ive approach that includes reductions from all emissions and precursors. Additional evaluation has been conducted to

determine how much the other reductions assist towards attainment (see additional text added to Chapter 3 at the end of section 3.4.1). The total of other

reductions reduces the need for additio nal NOx reductions by 172 tons, advancing attainment by much more than a single year.

4. Comment: A control measure for IC Engines (mostly stationary diesel engines, some spark ignited engines; applicati on includes poweri ng irrigation pumps) could achieve an additional 11 tpd of NOx reductions. (CVAQC) Response: Electrification would appear to be the only control technology available to achieve the suggested reduc tions. Unlike the more urbanized Los Angeles area, the San Joaquin Valley does not have the electrical distribution infrastructure needed to support a rapid swit ch to electric mo tors. The current rule incorporates feasible controls fo r this category, based on technological and

economic considerations. The Plan does co mmit the District to revisit this rule and incorporate new technology that is av ailable or planned at that time. The commenter is encouraged to participat e in the rulemaking process.

5. Comment: The District can achieve an additiona l 2 tpd of NOx reductions from Glass Furnaces. The proposed rule for i ndustrial glass manufacturers should be adopted. (CVAQC) Response: District staff is currently devel oping a rule with potential reductions of 3.4 tons of NOx/day from glass-me lting furnaces. District staff would be

interested to learn what additional control technologies are available to obtain the suggested reductions. More information per taining to this comment is needed.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-30 The draft rule is scheduled for adoption in the third quarter of 2008, according to

the commitment in the 2007 Ozone Plan . The commenter is encouraged to participate in the rulemaking process.

6. Comment: The District can achieve an additiona l 9 tpd of NOx reductions from Boilers & Dryers (gas & liq uid-fired boilers, solid-fuel boilers: dryers 5MMBTU/HR and below as area/point sources). (CVAQC) Response: District staff is currently devel oping a boiler rule with potential reductions of 5.3 tons of NOx/day. Dis trict staff would be interested to learn what additional control technologies ar e available to obtain the suggested reductions. More information pertaining to this comment is needed. The draft rules are scheduled for adoption in the third quarter of 2008, according to

commitments in the 2007 Ozone Plan . The commenter is encouraged to participate in the rulemaking process.

7. Comment: Costly selective catalytic reduction (SCR) systems would yield very

few emissions reductions while also necessitating additional production, transportation, storage, handling, and us e of ammonia, which generates additional environmental and public safety concerns. (CLFP, WSPA) Response: SCR systems can yield 80 to 95% NOx control efficiencies from

uncontrolled levels and have been in use for some time in industrial

environments. Ammonia is a common industrial and household product that is also in wide use as a fertilizer, anti-fungal treatment, refrigeran t, and disinfectant. State and federal requirement s govern the transportation, storage, and use of the product, mitigating potential safety problems. There is also increased interest in its use as a fuel, making it a more ubiquit ous commodity in the future. The rule may include an Advanced Emission Reduction Option (AERO) to lower cost and

maximize reductions.

8. Comment: The District should provide a ran ge of compliance options so that

facilities can use the most cost efficient and timely way to reduce emissions. The District should consider providing advanc ed early emissions reductions options, incentives, and thorough socioeconomic analysi s. Ensure that rulemaking does not impose a “one size fits all approach.” (CLFP) Response: Where possible, staff tailor the control requirements to account for an industry's unique circumstances. The re cently released draft of Rule 4320 contains Advanced Emission Reduction Op tions (AERO) to provide affected sources with control options while still obtai ning required reductions. Future rules are expected to include similar AERO considerations.

9. Comment: We are opposed to control measures that require the installation of electrostatic precipitators (ESP) or baghouse filt ers on natural gas fired stationarySan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-31 equipment. These types of equipment emit a small amount (0.23 tons/day) of

direct PM2.5. (WSPA) Response: Staff are not currently requiring, or even suggesting, that either ESP or baghouses be installed on all such equipm ent. For larger sources, such as glass-melting furnaces, ESP are currently successfully employed and have been for some time. New, large, oilfield steam generators are required to employ PM10 controls, but nothing limits these controls to either ESP or baghouses.

10. Comment: We are opposed to control measures that require the installation of fuel gas conditioning units or sulfur dioxide scrubbers for natural gas fired equipment. The SOx emissions from this equipment are pr imarily from the beneficial use of gas recovered from digesters and landfills. We believe that the District should encourage the use of these recovered gas streams. (WSPA) Response: During rule development, staff will evaluate the appropriateness of applying controls to a specific source of category. While smaller sources such as digesters or landfills may not wa rrant fuel scrubbing due to low sulfur emissions, sources like oilfield steam generators have considerably higher emissions and are good candidates for such controls. Also, sulfur removal is sometimes required to allow NOx reduction controls, whic h will aid attainment of
both ozone and PM AAQS.

11. Comment: The District, along with other agencies, in conjunction with agriculture, should look at alternatives for the industry other than open vegetative burning that are economically feasible. (Nisei) There shouldn’t be restrictions on the shredding of agricultural prunings because it is the only alternative to burning, which is already banned in the San Joaquin Valley. (CGTFL) Response: Staff are actively involved with the Agricultural Technology

Committee and similar state and local r epresentatives who are researching agricultural issues and air pollution. At this time, there are no planned restrictions on shredding of prunings.

12. Comment: The District has proposed to conduct a “feasibility study” to on “Conservation Management Practices” (CMPs), which is expected to be completed in 18 months. This is not a suff icient amount of time to complete this

task. (Nisei) Response: The District intends to move forward on feasibility studies as expeditiously as possible. These st udies will help show whether emissions reductions opportunities warrant a rule amendment or if additional studies are required. It is possible that the comment is correct and that completion may take longer than the proposed eight een months; however, until t he feasibility study is developed it is difficult to be certain of its duration. The nat ure of a feasibility study may not be as extensive as is antic ipated. The feasibility study may draw on work already completed or in progre ss to assess the emissions potential forSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-32 PM2.5 or may require new research to establish reliable findings. Current CMP

information is based on PM10 and the amount of PM2.5 affected by the CMPs is unknown. If assessment of work currently in progress can be used to establish

that the PM2.5 fraction of PM10 is too sm all to merit attention, such information may be used to conclude the feasibility assessment. If, however, preliminary

information indicates that the PM2.5 frac tion of PM10 from these sources is a percentage that merits att ention for development of pot ential reductions and it is

found that some of the CM Ps have a potential to reduce these emissions, a more thorough evaluation may be requi red to complete the feasibility assessment, new field measurement programs may be r equired and the project may take longer

than the current estimate. The District will coordinate any additionally required field research through the AgTech Co mmittee, which has been established for the purpose of involving stakeholders and qualified scient ists in development and review of agricultural air quality resear ch to ensure accuracy and usefulness of the products and findings of the research.

13. Comment: The District should not increase t he number of CMPs to achieve

PM2.5 emission reductions. Tree and vi ne crop operations are minimal during the winter season when PM2.5 levels are the highest. (CGTFL) Response: Please refer to comment number 12.

14. Comment: The District needs to evaluate how the changes proposed in the “Dryers” control measure (I-41) will affe ct the quality of dry fruit and vegetables. (Nisei) Response: The last rule development projec t did address this issue and it will be considered in any future amendments.

15. Comment: Please review Federal and State labo r and transportation regulations in relation to the proposed “Employer Ba sed Trip Reduction” rule. There are major conflicts with these rules wit hin the agricultural industry. (Nisei) Response: Staff will review the documents and make appropriate allowances during the rule development project for that control measure. District rules cannot, however, resolve any conflicts bet ween the state and federal regulations.

16. Comment: We believe that the tremendous effort that the agricultural sector has made to comply with local, state, and federal regulat ions should be acknowledged. Examples include: t he pump engine rule, CMPs, open burning rule, emergency generator permits, surfac e water regulations, and many others. (CGTFL) Response: Comment noted.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-33 17. Comment: The District should not adopt a rule t hat would require more no burn days for residential wood combustion. Other measures should be implemented

instead. (Murray, Gary) Response: Staff will consider all feasible opt ions during the rule development process for that control measure. District staff would be interested in any

alternatives that could be implemented in addition to t hose already listed in the plan.

Reasonable Further Progress

18. Comment: The PM2.5 Plan does not demonst rate how reasonable further progress (RFP) will occur by 2009 and 2012. There should be further explanation on how RFP will be achieved so that the plan will be approved by

EPA. (CVAQC, ISSRC) Response: EPA’s final rule on RFP stipulates “generally linear progress.” The 2009 and 2012 projected emissions present ed in Chapter 8 of the Proposed

2008 PM2.5 Plan meet RFP requirements.

19. Comment: ARB should project emissions r eductions from their proposed rules

for use in the 2012 RFP calculations. (ISSRC) Response: ARB has made no formal commitment for pre-2014 reductions from

the truck rule now under dev elopment. Their only commit ment from all new state measures is for 2014, regardless of whet her or not reducti ons begin earlier from phased implementation of a rule. Because of this, the Plan cannot take credit for pre-2014 reductions from any ARB rules.

Contingency Measures

20. Comment: The District has only documented a fraction of the contingency measures that are required (approximately 30 tpd of NO x, or the equivalent of one year of RFP). (CVAQC, ISSRC) Response: EPA’s Final Rule implementing the PM2.5 NAAQS (72 FR 20586)

recommends that the level of reductions in contingency measures represent one year’s worth of emissions reducti ons necessary to meet RFP (72 FR 20643). This is strictly a recommendation and is not supported by any regulatory language in 40 CFR 51.1012. It is also a pessimistic scenario that assumes an RFP milestone is missed by a full year’s of emission reductions; in reality, the shortfall could be smaller. In any case, the overarching requirement is for the nonattainment area to remedy the shortfall within one year of th e end of the RFP year in which the shortfall occurred, “without significant further action by the state or EPA.” (40 CFR 51.1012). S ee discussion in Chapter 8.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-34 21. Comment: One of the District’s contingency meas ures (like South Coast’s) is to request that ARB accelerate adoption and implementation of state measures. However, this would require additional ARB staffing and implementation costs. Also, these reductions are not timely. Phase one of the truck rule will be implemented by December 31, 2013. The second phase will begin by 2017, phasing in until 2021. As a result, the ma jor source reduction brought in by the

truck rule will not occur until 2016. (ISSRC) Response: The District’s contingency measure described in the comment is not directed exclusively towards emission reduc tions from the truck rule now under development. It applies to any st ate measure under development and/or implementation, with the goal of accele rating reductions from the measures.

22. Comment: One of the District’s contingency meas ures is to collect fees from stationary sources in the event that the Valley fails to attain the 1-hour ozone standard (District Rule 3170, which has not been approved by EPA). The success of bringing clean air is contingent on the failure to attain clean air. Based on District documents estimating $30 million per year in fees, the most reductions that could be achieved by th is approach is about 1.5 tpd in the first year. Also, these reductions are not timely , since they would not be realized until the beginning of 2013. (ISSRC) Response: The District developed its contingency measures in accordance with EPA’s Final Rule implement ing the PM2.5 NAAQS (72 FR 20586). In this rulemaking, EPA emphasizes that states should make decisions on contingency measures in conjunction with their devel opment of control measures needed to

show RFP or attainment. In particular, EPA notes that “all available measures

needed in order to demonstrate attainment of the standards must be considered first; all remaining measures should then be considered as candidates for contingency measures. It is important not to allow contingency measures to counteract the development of an adequate control strategy demonstration.”

The District’s 2008 PM2.5 Plan emphasizes control measures needed to demonstrate attainment, and lists measur es not needed for RFP or attainment demonstration as contingency measures. One of these measures is the

emission reductions that would resu lt from spending fees collected if the San Joaquin Valley Air Basin fails to attain the former 1-hr ozone NAAQS; Section 185 of the federal Clean Air Act requires co llection of such fees if a severe or

extreme area fails to attain the former standard.

The commenter is incorrect in estimati ng the amount of funds that could be generated. The figure cited by the commenter is based on outdated (though correct at the time) fee cost s; as noted in the federal Clean Air Act, the fee is to be adjusted for inflation and is now close to $8000/ton. The figure will likely be higher in 2010 or 2013 due to continued inflat ion. Also, the District now regulatesSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-35 many more major sources of pollution that was the case when the original

estimate was derived. These factors will increase the amount of total fees possible under the current District-adopted rule to above those cited by the commenter. Also, the estima ted reductions are also higher than those cited by the commenter; using the figure of $25 million per ton of permanent NOx reductions (as given in the 2007 Ozone Plan ), the $30 million cited by the commenter would generate about 1.2 tpd of permanent NOx reductions.

In general, nonattainment areas have one full calendar year after the RFP year in which to remedy any RFP shortfall. Consequently, failing to meet a 2012 milestone would require that a remedy be implemented by December 31, 2013. Since the District has a backlog of well over $100 million worth of incentive projects that are awaiting funding, Distr ict staff is optimistic that emission reduction projects could be put in place in time to correct any RFP shortfall from the 2012 milestone, shoul d the need arise.

23. Comment: The District should ban the use of pre tier-3 off-road engines (including agricultural engines, such as tractors and harvesters) during high pollution days as a contingency measure, as proposed by South Coast. The District should also accelerate adoption and implementation of District rules by one year as a contingency measure. (ISSRC) Response: In the Final Rule implementing the PM2.5 NAAQS, EPA notes that PM2.5 plans should not include unreas onable control measures, ‘such as measures that are “absurd, unenforceable, or impractica l” or that would cause “severely disruptive socioeconomic im pacts (e.g., gas rationing and mandatory source shutdowns); such measures are not required by the Act. 55 FR 38327.’ (72 FR 20613) Many of the Tier III engines in the Distric t are used for irrigating crops, and can’t readily be turned off due to air quality conditions without causing severe economic impacts to the economy.

The District’s rulemaking schedule outli ned in Chapter 6 achieves emission reductions as expeditiously as practic able. The contingency measure regarding

acceleration of emission reductions is geared toward the state because 80% of the NOx emissions, which are a significant precursor to secondary PM2.5, are caused by mobile sources under the c ontrol authority of the California Air

Resources Board.

Transportation Control Measures

24. Comment: The addendum for Chapter 7 indicates that a total of 100.5 tpd of NOx (attributed to Table 9-1) is necessary in 2013 to advance attainment of PM2.5 by one year. However, this doesn’ t account for ARB reductions that start as early as 2009 (the truck rule has a compliance date of December 31, 2012 forSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-36 certain model years). Without proper pr orating of ARB emissions reductions, full consideration is not given to potential s ources of emissions reductions that may actually advance attainment by one year. (ISSRC) Response: ARB has made no formal commitm ent for pre-2014 reductions from

the truck rule now under development. Their only co mmitment from all state measures is for 2014, regardless of whet her or not reducti ons begin earlier from phased implementation of a rule. Because of this, the Plan cannot take credit for pre-2014 reductions from any ARB rules.

25. Comment: The addendum for Chapter 7 (section 7.2.3) states that the plan includes reasonable further prog ress demonstrations for 2009 and 2012. However, the plan does not show RFP in 2009 and 2012, and it does not show attainment by 2015. (ISSRC) Response: The Proposed 2008 PM2.5 Plan does show expeditious progress for RFP and most certainly demonstrates attainment using a variety of EPAapproved approaches and techniques.

Air Quality Data

26. Comment: Design values should be recalcul ated for missing federal reference filter data during events when meteorology and real-time data show exceedances
of the PM2.5 NAAQS. (Shipp, ISSRC) Design values for some highconcentration sites (such as Bakersfield – California) are affected by missing data when meteorological cond itions are conducive to PM2. 5 formation. In years where meteorology produced high concentrati ons of PM2.5, filt er-based data is missing while real-time data is high (2005 data was provided as an example). EPA’s data substitution method may not fully account for this bias, but EPA has

indicated to the commenter that this type of non-reference method analysis

would be allowed under the wei ght of evidence provisions. Correlation to parallel real-time monitors is good, and this dat a can be used to calculate alternate design values for weight of evidence. These alternative design values would be

over the level of the 24-hour standar d for 2004-2006, so additional control

commitments should be made to reduce t hese levels to under the NAAQS. A similar analysis should be made for the annual standard (Shipp) Response: The monitoring data cannot be used in the manner suggested by the commenter. EPA has established proc edures for adjusting the data for differences between the sampler char acteristics (SANDWICH) when using sampler data from monitors that are not equivalent to reference method samplers. The procedure for this method is detailed in the protocol and regional modeling documentation (Appendices F and G). The procedure requires adjustment for speciation differences between FRM and the non-reference method. BAM data does not provide s peciation data and cannot be adjusted in

this manner. Part of the difference between BAM and FRM data is a higherSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-37 amount of captured water that is not removed from the BAM sample. In coastal locations, the water collection has been hi gh enough to cause the filter tape to break, but the SJV has not experienced this mode of sampler failure. Alternative operating procedures are available to driv e off trapped water, but currently this involves heating the air stream, which may also reduce capture of ammonium

nitrate. The District uses data from thes e BAM real time samplers to assist in daily forecasting and smoke management, not for determination of attainment

due to the differences between FRM and BAM samplers. It is not appropriate to

use the data in the manner suggested by the commenter.

27. Comment: Design values should be reca lculated with 2007 data. (Shipp, ISSRC) This should be part of the weight of evidence analysis. Also, the District has been asserting that the District already meets the 24-hour PM2.5 standard.

The commenter is concerned that the Dis trict will be granted attainment status. (Shipp) The District’s claim that 2007 data was analyzed and showed

attainment needs to be documen ted in detail in the main volume of the plan with 2005-2007 design valu es and RRF. (Shipp addendum) Response: The District cannot be granted a ttainment status for the daily

standard for several reasons. Most im portantly, both t he annual and daily standard must be met to receive a redesignation to attainment. Separate findings for attainment are not given unle ss both standards are met. This is true

for both PM10 and PM2.5. T he annual standard is more difficult for the SJV to meet than the daily standard and will det ermine when the District will qualify to request attainment status. From modeli ng contained in the plan, this is not expected to occur before 2014 unless additi onal early reductions are achieved. In addition, the current daily stand ard was superceded (although retained for planning requirements for this submittal) , and no redesignation to attainment will be provided for meeting the previous daily standard.

The daily air quality standard is not as stringent for the SJV to meet as the

annual standard. Note that t he regional modeling, as documented in Appendix G and H, projects a maximum 2014 fu ture annual design value of 14.68 (Bakersfield –Golden State) while projecting a future da ily design value of 44.6 at the same location. Considering that the annual standard is 15.0 and the daily standard effective for this planning require ment is 65, it is clear that more reductions are required to meet the annual standard than are required to meet the daily standard. The District conducted a sensitivity assessment by receptor analysis with both the current design value, as established by EPA guidance, and an estimated design value for 2005-2007 from the uncertified and incomplete data for 2007, which cannot be submitted in detail to EPA precisely because it is based on uncertified and incomplete data. Both of these assessments indicate

that attainment of the daily standard requires much less reductions than is required to meet the annual standar d, confirming the regional modeling

evaluation. Additional te xt has been provided to reflect these findings in theSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-38 District Weight of Evidence determination (C hapter 3 section 3.4.2) in the section “Air Monitoring Data and Trends.”

28. Comment: The 2004-2006 period should be reevaluating for representative meteorology. (Shipp, ISSRC) The meteorology of 2004-2006 was less conducive to PM2.5 formation than previous years. The average stability

correlated to PM2.5 was lower in the last few years than in other years. The District’s responses to previous comment were inadequate, and there should be a full investigation of this subject and a re-evaluation of how this affects the design value and control strategy. (Shipp) Response: The District feels that the res ponse was adequate and it is repeated

below:

The District performed an ex amination of meteorologi cal trends in the San Joaquin Valley. Statistics for 100 year and 20 year meteorological databases were reviewed. Statistical analysis wa s performed to determine the relationship between meteorological indicators and PM2.5 concentrations. The results of these analyses indicate that the re lation between examined meteorological indicators and PM2.5 is poorly correlated and not statistically significant. It would be inappropriate to adjust particulate dat a based on poorly correlated indicators.

In addition, PM2.5 data has been collected for a relatively short time frame, resulting in a database that does not hav e a statistically adequate number of samples for a long term trend compar ison between PM 2.5 and meteorology.

Ozone data has been collected for a much longer time period than PM2.5. The EPA presents meteorological adjusted ozone analyses for Bakersfield and Fresno at the following website:

http://www.epa.gov/air/airtr ends/weather/region09.pdf#page=4

The EPA analyses for Bakersfield and Fresno indicates that there is very little

difference between actual data and in trend adjusted data fo r the period 2004-

2006. This resolves the issue that 2004- 2006 had 'better' meteorology than past years. The District welcomes analyse s developed by the commenter that

addresses these issues.

The 2006 PM2.5 Standard

29. Comment: The District has failed to plan for the 2006 standard in this plan. (CVAQC) Response: This 2008 PM2.5 Plan addresses the 2006 PM2.5 daily NAAQS of 35 μg/m3 in several ways. First, the Plan contains a commitment to re-open theSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-39 residential wood combustion rule to c onsider a number of changes, including establishing the threshold for wood burni ng prohibitions at t he level of the 2006 standard (35 μg/m3). Sec ondly, modeling results presented in Appendix G illustrate progress toward the 35 μg/ m3 standard. As dictated by the requirements of the federal Clean Air Ac t, preparation of a formal plan dedicated

to the 2006 standard will be linked to the timing of EPA’s official designations

under the 2006 standard. Plans will be due in either 20 12 or 2013, and the final attainment year for the 2006 st andard will be 2019 or 2020. The 2008 PM2.5

Plan will result in quantifiable prog ress towards the 2006 standard by 2014.

Modeling and Emissions Inventory

30. Comment: The latest version of the plan indi cates that our previous comments

did not include measured PM 2.5 data from farming ope rations. The document “Interim Report: Sources and Sinks of PM10 in the San Joaquin Valley” was

included and contained s pecific PM2.5 data for cotton picking, cotton stalk cutting, almond pickup and sweeping, and fi g sweeping and pickup. The District did not respond to the cotton gin data that was provided for the previous draft of

the PM2.5 Plan. We incl uded two studies that show ed specific “measured PM2.5 levels” from cotton gins and the Dis trict must recognize them. (CCGGA) Response: The data submitted is under review and will be incorporated in any feasibility studies. It is premature to dismiss any sour ces from consideration prior to conducting a thorough technical revi ew. The District will consult with stakeholders through the Ag Tech co mmittee to address these issues.

31. Comment: The CRPAQS clearly indicated that fu gitive dust is not a significant

contributor to the formation of PM2.5. Also, PM2.5 leve ls are highest during the months of November through February, when agricultural activity is the lowest. The District should focus on combustion sources, and not fugitive dust. (CCGGA) District staff should review the Fugitive PM10/2.5 studies that have been done by ARB and the San Joaquin Vall ey over the past 10 years. The studies deal with open areas, paved and unpaved roads as well as agricultural sources under Rule

8081. (Nisei) CRPAQS indicated that dust from agr icultural sources is larger in

size than PM2.5. This contradict s the data used by the District and ARB. (CGTFL) Response: Some geologic sources may have bigger contributions to PM2.5 than others. Right now, a single average number represents all sources. A closer look is needed to identify the mo st significant contributors to PM2.5.

32. Comment : The plan needs to provide a full photochemical model evaluation. (Shipp, ISSRC) This evaluation has full bea ring on the uncertainty of theSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-40 estimation of the emissions reductions needed to achieve the NAAQS. ARB has indicated that this is forthcoming. (Shipp) Response: The photochemical model output is analyzed in accordance with EPA guidance for speciated modeled attainment test (SMAT). This is a complex process that involves separate analysis of the main chemical groups processed by the model (ammonium sulfate, ammoni um nitrate, carbon) and use of the model results for each of these separat e contributions using the relative response factors (RRF) from 2005 to 2014. More detail of this process is included in the modeling protocol (Appendix F) and A ppendix G that presents the regional model methodology and results. The uncertainty estimation for the model can be directly evaluated by perfo rmance analysis (in progress by ARB) and by comparing the results to other analytical approaches including the receptor modeling and weight of evidenc e evaluation in Chapt er 3 of the Plan and in Appendix H to the Plan. These co mparisons confirm the findings of the regional modeling results. The regional model projec tions and receptor analyses are in close agreement and are supported by other weight of evidence analysis.

33. Comment: The plan needs to document whet her the photochemical modeling

verifies whether PM2.5 formation is NOx limited on all days. (Shipp, ISSRC) It

seems that the NOx limitation statem ents in the plan are based on severe episodes, and those do not necessarily drive the magnitude of the annual

standard. There should be an assessment of individual days in the model to determine whether some days show majo r sensitivity to VOC and/or ammonia

controls. (Shipp) Response: The NOx limitation is documented by evaluation of two prior seasonal modeling evaluations and by research finding from the CRPAQS project. Much of this has been documented in the modeling prot ocol Appendix F. Current regional modeling provides a modeling assessment of each day of a fourteen-month period and continues to establish an annual dominance of ammonium nitrate. Many days during the year have very low levels of ammonium nitrate and are dominated by directly emitted particulate and

ammonium sulfate. It w ould not matter on these days whether ammonium nitrate

is NOx or ammonia limited when it forms in very small amounts. For ammonium nitrate reduction of consequence to the annual PM2.5 standard, we must concentrate on the winter period of high concentration of ammonium nitrate, which has already been well establis hed by research and modeling as NOx

limited.

34. Comment : EPA’s method of applying Relative Response Factors (RRF) needs to be used with the direct photochemical model output. (Shipp, ISSRC) RRFs
from the CMAQ model s hould be analyzed as an alternative to the rollback method. Since the protocol and EPA gui delines recommend the use of straight photochemical derived RRFs, the District shoul d at least show these calculations

as an alternative. (Shipp) Calculations using RRF obtained directly from theSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-41 photochemical model need to be show n. Both 2005-2007 and 2004-2006

attainment should be demonstrated fo r speciated rollback and direct photochemical model RRFs. (Shipp addendum) Response: EPA methods were used for the r egional modeling analysis. Table 3-3 reflects these calculations, which are also documented in Appendix G and H. The most recent version of the regional model calculation files completed by ARB have been requested by the District; however , these files will not be printed or incorporated in the plan document due to t he size of the files (approximately 54 megabytes). The calculations use the design value years required by EPA. The suggested alternative 2005- 2007 period does not have co mplete data available to allow its use as discussed more extensively in response to a previous comment. (See response to Comment 27)

35. Comment: The role of VOCs and ammonia should be further evaluated, specifically in regions pr one to PM2.5 pollution, such as the Bakersfield area.

Studies in PM2.5 formati on have not adequately investigated this in more limited geographic areas. (ISSRC) Response: Because these pollutants are considered to be sub-regional in nature, forming over time and traveling between areas within the Valley, it is

unclear whether a limited geographic area analysis would be technically valid. However, it is possible to study limited areas to identify how they differ from general Valley conditions. CRPAQS pr ojects included a number of special

studies conducted in more limited geographic areas to answer specific technical questions. The findings of these specia l studies were used to develop our regional measurement progr am. Special studies were used to determine how much particulate forms from VOC emissi ons. These documents are available from the ARB Airways websit e of CRPAQS published results.

36. Comment: By just modeling attainment fo r 2014, the District is not addressing the need to show attainment as a three-y ear average. It appear s that the District is expecting to request a 1-year ext ension (although RFP has to have been met for said extension to be granted). How c an the Valley attain by 2015 if many

reductions will not be implemented until 2014? (CVAQC, ISSRC) Response: The District and ARB followed E PA guidance, which identifies how to model the design value three-year per iods. In addition, the District modeled each three-year design value period from 2009 to 2014. In accordance with EPA Guidance (page 33, EPA 454/B-07-002) t he base year used for the modeling projection is “the middle year of the baseline average design value” and the future design value year to be pr ojected is the “single year/season immediately preceding the attainment date” (page 35, emphasis as contained in the guidance document). The m odel projections are used wi th methods that project a three-year design value av erage for the required years.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-42 J.5 VERBAL COMMENTS, DECEMBER 18-1 9, 2007 PUBLIC WORKSHOPS ON THE

DRAFT 2008 PM2.5 PLAN

J.5.1 December 18, 2007, 6:30p m Workshop

Approximately 27 people in attendance (25 Fresno, 2 Bakersfield, and 0 Modesto)

1. Comment : Will ARB’s regional modelin g include emissions inventory adjustments for new control measures? Response : Yes, and a new inventory will be available at a future date.

2. Comment Rather than focusing on the PM2.5 standards as set by EPA in 1997,

the District should focus on the 2006 standards. Perhaps this could be done in an Appendix or as a separ ate Community Plan that goes beyond the SIP. Response : This is not an “either-or” sit uation where we c hoose which PM2.5

standard to address. The District is ta rgeting both standards. This plan will make major progress in attaining the new standard well ahead of EPA’s deadline. The idea of a community plan is interesti ng, similar to the “Fast Track” approach to implement programs beyond the SIP to help the Valley attain the 8-hour ozone

standard sooner. The District is worki ng on several efforts to accelerate

attainment that are not st rictly SIP creditable, incl uding Healthy Air Living and Fast Track. Taken as a whole, these are the start of the “Community Plan” concept suggested by the commenter.

3. Comment: The more health-protective stat e standards should be addressed. Response : The proposed control measures will provide significant progress toward meeting California standards. Ca lifornia has no specific dates by which state air quality standards must be attai ned. California Health and Safety Code (CH&SC) Section 39602 says, “Notwithst anding any other provision of this division, the state implementation plan shall only include those provisions necessary to meet the requirements of t he [federal] Clean Ai r Act.” As such, state implementation plans (SIPs) are lim ited to those measures necessary to attain the federal standards. However, progress towards federal standards also brings areas closer to the lower, Stat e standards. Furthermore, the District has fully complied with California planning r equirements for state particulate matter standards, in accordance with Section 396 14 of the California Health and Safety Code (see the June 2005 SB656 PM Implementation schedule).

4. Comment: Lowering the no-burn threshold for Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters) is a good idea.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-43 Response : Comment noted.

5. Comment: The modeling in the draft is inco mplete. There needs to be RRF (relative response factors). More meteorological analysis is needed. Response : The District included RRF in the receptor modeling (see Chapter 3 and Appendix F), and ARB is using RRF in the regional modeling that will be available in the next draft of the plan. Extensive meteorological analysis is available in Appendix E of the draft plan.

6. Comment: The recent days with concentrations over 65 μg/m3 should be looked

at. Response : The data for 2007 will not be official until all of the filters have been weighed and there has been adequate ti me for quality assurance and certification. Typically, data for a year becomes official by July 1 st of the following year. However, the District is consider ing approaches for incl uding a preliminary discussion of 2007 data in the plan.

7. Comment: Wineries, digesters, asbestos dust, almond harvesting, track-out, anhydrous ammonia, fireworks, and population increases should all be considered in the plan. Response : Fireworks, amendments to Conservation Management Practices (which include almond harvesting and tr ack-out), and amendments to Regulation VIII (Prohibitions for Fugiti ve Dust) are further study measures. Wineries and

other sources of VOCs are cons iderations in the District’s 2007 Ozone Plan , but available evidence suggests that VOCs ar e not a major precur sor to PM2.5.

Ammonia reductions are not as effect ive as NOx reductions for reducing ammonium nitrate, since NO x is the limiting precursor in the Valley. Projected population increases from the California D ept. of Finance are incorporated in the plan’s emissions inventories.

8. Comment: Fireplaces should be banned completely in urban areas, and more inspectors are needed. Response : Comment noted.

9. Comment: There are lot of NQ (not quantifi able) and TBD (to be determined)

entries in the control measure eval uations. More information is needed. Response : Some of the values cannot be dete rmined at this time due to lack of reliable quantitative information on feasib le control technologies for directlyemitted PM2.5. More deta iled information will have to await the results of the Feasibility Study or Rule Development project. If the information can beSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-44 determined prior to the pl an's adoption, that informa tion will be included in the

later drafts.

10. Comment: Some of the feasibility studies should be control measure

commitments. Response: Staff would be glad to review suggestions for feasibility studies that

could be converted to cont rol measures with quantifi able reductions. The feasibility studies are commitments to fu rther examine the source category and

determine if there ar e opportunities for future emi ssion reductions. Feasibility Studies will engage the public and industry in identifying new potential emission reductions. Some of these studies, based on possible future control technique advancements, will be developed in a public process culminating in a public hearing before the Gove rning Board.

11. Comment: The District should focus more on meteorological criteria for Rule 4901 burning prohibitions instead of just forecasted AQI. Response: The District will consider this comment in the rule amendments for

Rule 4901.

12. Comment: Several commenters expressed appreciation for the evening (12/18/07) workshop and fo r the availability of Spanish materials. Response: Comment noted.

13. Comment: Is there a PM2.5 monitor in Merced? Response: There is an FRM (federal referenc e method) monitor in Merced, but

not a real-time monitor. The FRM is the type of monitor used to determine compliance with the air quality standard, and the data from this monitor are used to calculate design values.

FRM data is not available until months a fter the sample was collected, since FRM filters must undergo l aboratory analysis. FRM data is therefore not

available on a real time basis to estab lish current air quality, so the District has deployed real time monitors to provide daily forecasting capability. These supplemental monitors are currently sit ed in locations expected to experience peak values. The District’s goal is to eventually have at least one real-time monitor in each of the eight counties in the San Joaquin Valley. The District

forecasts PM2.5 levels for Merced Count y based on the real time data from the Turlock monitor, which is approximately 2 miles from the Merced county line. The District expects to site a real-tim e PM2.5 monitor in Merced in the near

future.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-45 14. Comment: What is meant by “adjusted NOx” in the graphic in slide 14 and in the Executive Summary? Response: The initial emissions inventory pr ovided by ARB includes reductions from regulations adopted th rough May 2005. The Distric t subtracted reductions from rules adopted between May 2005 and De cember 2006 from these initial

inventories and then made addi tional adjustments for me thodology revisions to derive “Adjusted Inventories,” including Ad justed NOx. See Appendix B for more

information.

15. Comment: The District should keep the lay person in mind when putting together plans and presentations. Response: The District strives to keep lay peopl e in mind as much as possible while meeting technical and legal planni ng requirements. District staff is available to provide further clarification and explanation.

J.5.2 December 19, 2 007, 2:00 pm workshop

Approximately 31 people in attendance (8 Fresno, 8 Bakersfield, and 15 Modesto)

16. Comment : Karen Magliano of the Califor nia Air Resources Board (ARB) commented that she was encouraged by the a ttainment outlook of the receptor modeling and the amount of CR PAQS (California Regional Particulate Air Quality Study) research that was included. S he noted that ARB’s regional, grid-based modeling was in progress. She pointed out that in South Coast, the grid-based model was even more conservative; mo re reductions may be needed than the receptor modeling in the cu rrent draft plan anticipates. Response : Comment noted.

17. Comment: Is the District working on an environmental document? Response : Yes, an Initial Study/Proposed Negative Declaration is being prepared to meet CEQA requirements and s hould be available for public review in February 2008.

18. Comment: With regard to the feasibility studies for conservation management practices and cotton gins, what percent of fugitive dust is PM2.5? There are studies that say the percentage is very lo w, and these studies will be submitted

to the District as a written comment. Response: Approximately 25% of PM10 from the Farming Operations and Cotton Gins categories are PM2.5, accord ing to the ARB emissions inventory. District staff will be looking to these estima tes in the feasibility studies for CMPs and cotton gins.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-46 19. Comment: Have you found any upwind sources that may be contributing to nonattainment? Response: In general the SJV’s PM2.5 concent rations are not dominated by a single source or facility or even by a clus ter of large sources sufficient to impact local air quality to the degree that would necessitate special modeling or analysis (though emissions from wild fires and prescribed fires in other air basins can

contribute to PM2.5 levels in the Va lley). As with ozone, the particulate concentrations in the Valley are regional in nature, formed by contributions from a variety of sources. Annual average conc entrations in the Valley are dominated by ammonium nitrate, which is formed se condarily rather than emitted directly. The limiting precursor for ammonium nitrat e is NOx, which is emitted from motor

vehicles as well as from industrial and commercial combustion processes. Regional mixing and delayed atmospheric fo rmation of PM from these precursor emissions make it impossible to evaluat e the precise contribution of a single facility.

20. Comment: Has the Valley’s degree of PM2.5 nonattainment been characterized (i.e., serious, etc.)? Response: EPA has chosen not to use classifications for areas not attaining the

PM2.5 standard.

21. Comment: Many dust control measures require watering. We need to be ready for impacts of drought on these measures. Response: Dust control is discussed in the pl an as future/feasibility studies.

Should these studies lead to rule amendments, the am endments would be

evaluated under the California Environm ental Quality Act (CEQA); potential

effects on water resources would be evaluated under the CEQA review.

22. Comment: The plan should show how the Distric t plans to bring the Valley into

attainment of the 2006 standard. Response: The District is targeting both standar ds. This plan will make major progress in attaining the new standar d well ahead of EPA’s deadline. The District has incorporated as many control measures as possible at this time.

23. Comment: What are the three Fres no PM2.5 monitoring sites? Is the BAM data

available? Which site is worst? Response: Federal reference method (FRM) monitors are sited in Fresno County at Fresno-1 st , Fresno-Winery, and Clovis. Fresno-Winery (located at Fresno Pacific College) has the highest design values by a small margin. Design

values calculated for the other two Fres no County monitoring sites are within oneSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-47 microgram per cubic meter of the Fresno- Winery design value. See Appendix A for air quality data and calculations.

24. Comment: How much benefit could there be from revising the fireplace rule? Response: The District is looking at the po ssibility of lowering the No Burn

threshold to a PM2.5 concentration of 35 μg/m3. This could have a benefit of reducing about 14.8 tons of PM2.5 emissions on a si ngle, Valley-wide no-burn night. As an annual, Valley-wide average, the benefit would be about 0.7 tons per day.

25. Comment: The District should not allow people to burn in their fireplaces all the way up to the 35 μg/m3 standard. Response: Comment noted. This issue will be addressed fully in the upcoming

amendments to Rule 4901.

26. Comment: Not much is known about PM2.5 and its effects. Response: A large body of scientific evidenc e documents the serious health

effects of PM2.5. EPA cites a large amount of evi dence in its criteria document

to show the extent of the serious health e ffects of PM2.5. See Section 2.2 of the

Draft PM2.5 Plan as well as www.epa.gov/oar/par ticlepollution for more

information.

27. Comment: Restrictions against wood burning should allow exemptions during power outages in foothill areas lo wer than 3000 feet. Major electrical

transmission line maintenance and transformer work in the winter that caused power outages in foothill homes in areas lower than 3000 feet, and woodburning in many of these residences would pr ovide a back-up heat source that would prevent property damage due to cold temperatures. Response: See response to Comment 25.

28. Comment: Will most recent data on heavy-dut y mobile sources be in the Appendix B emission inventory? Response: The District is using the most re cently available emissions data finalized by ARB. Further updates to the mobile source emissions inventory are anticipated to be available with the next release of ARB’s on-road motor vehicle emissions model [EMFAC] (possibly in 2009).

29. Comment: Are farm tractors impo rtant sources of NOx?San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-48 Response: As shown in the NOx emissions in ventory in Table B-4, in 2010, about 41.7 tons per day (tpd) of farm equipment emissions Valley-wide as an annual average. Of this, about 39.8 tpd are from tractors.

J.6 WRITTEN COMMENTS, DECEMBER 18 -19, 2007 PUBLIC WORKSHOP ON THE

DRAFT 2008 PM2.5 PLAN

Comment period held through January 9, 2008

Comments were received from the following people and organizations:

California Cotton Ginners and Gr owers Associations (CCGGA) International Sustainable Syst ems Research Center (ISSRC) Kern Oil and Refining Co. (KOR) Thomas Menz (Menz) Nisei Farmers League (Nisei) Evan Shipp (Shipp) San Joaquin Refining Co., Inc. & Tricor Refining, LLC (SJR) Steven Weil (Weil)

Control Measures -

1. Comment: S-COM-1 and S-COM-2 should not be on the District’s control measures list. Boilers, heaters, and steam generators have been controlled to the maximum extent feasible, and the point of diminishing returns has been met. Further controls on this category are not cost effective, and they have not been

demonstrated to achieve reductions or to be technologically feasible. As noted in the plan, the proposed control devises have not been used for gaseous or liquidfired units. The cost per ton of reductions could exceed $300,000. (KOR, SJR) Response: Those control measures reflec t the current rule development projects that were commitments in the 2007 Ozone Plan . Staff will examine feasibility and cost as part of that rule development project, which is currently underway.

2. Comment: S-COM-11 , Dryers: Before developi ng stricter regulations on facilities that use natural gas dryers, it must be shown that products will not be damaged during processing. Low NOx burne r manufacturers have stated that the burners have not been tested on all pr oducts. New burners have also been reported to use more gas. (Nisei) Response: Technical limitations of the va rious control technologies will be examined during the feasibilit y study for this control measure to determine if a rule development project would lead to additional reductions. During the recent rule making project, the listed concerns were used to set appropriate limits for the dryers used as food dehydrators.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-49 3. Comment: S-AGR-2 , Conservation Management Pr actices/CAFOs (Confined Animal Feeding Operations): Lowering CAFO thresholds is a concern, in light of research already conducted t hat shows that farming dust is more a contributor for PM10, not PM2.5. The proposed research to evaluate PM2.5 controls on agricultural operations will take more than two years. (Nisei) Response: At this time, that category is not included in the PM2.5 Plan since the emissions from those sources are pr imarily VOC. This category will be

addressed under the 2007 Ozone Plan for opportunities to control VOC, based on current research projects.

4. Comment: S-AGR-2 , Conservation Management Prac tices: Past and present research on CMP activities done through UC Davis, Fresno State, Texas A&M, Washington State University, and the USDA ARS Research Division should be reviewed and evaluated before determining t he contribution of CMPs to PM2.5. The Agriculture Industry is interested in m eeting with District staf f on this topic. (Nisei) Response : Currently, the CMPs rule tar gets PM10 reductions, and the District has not yet determined the associated PM2. 5 reductions. A feasibility study will help show whether there is a quantifi able PM2.5 benefit and whether there are any CMP options that woul d optimize PM2.5 reductions. For example, CMPs that reduced field passes reduce both fugitive PM10 from reduced field activity as

well as PM2.5 from reduced fuel combustion.

The District is reviewing all availabl e data to determine the effectiveness and feasibility of conservati on management practices in reducing PM2.5 emissions. Although PM2.5 might be a relatively sma ll portion of fugitive dust, the Valley’s cumulative fugitive dust levels may still contribute to t he Valley’s PM2.5 nonattainment. The District would be happy to meet with all interested parties to

discuss this issue.

5. Comment: Cotton gins and fugitive dust controls for farming operations should

not be considered as PM2.5 f easibility studies. There is already ample evidence indicating that fugitive dust is not a si gnificant contributor to PM2.5: Karen Magliano’s (ARB) presentation at the District’s May 2006 Symposium, CRPAQS (California Regional Partic ulate Air Quality Study) r eports, USDA studies, U.S. EPA documents, and numerous other studies. Extensive documentation was

submitted to the District wit h this comment. This shou ld be acknowledged by the District, and the Plan should be modified accordingly. (CCGGA) Response: The extensive documentation submi tted with this comment did not provide data on measured PM2.5 levels fr om farming operations. Consequently,

the District still believes that a feasibility study is warranted. The submittedSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-50 documentation will form an exce llent starting point for the study. Also see the response to Comment 4.

6. Comment: S-AGR-2 , Conservation Management Prac tices: Amend Rule 4550

to increase the number of required CMP for each appl icable CMP category that will provide for a 50% reduction of current levels of PM2.5, by the year 2012. (ISSRC) Response: Merely increasing the number of required CMPs will not necessarily

result in a 50% reduction since some ar e mutually exclusive or are redundantly controlling the same emissions. Please al so refer to the re sponse to Comment

4.

7. Comment: S-AGR-1 , Open Burning: Amend Rule 4103 to include a requirement

that all alternatives to burning biomass that are curr ently feasible, such as chipping and composting, are thoroughly cons idered before resorting to burning. Prospective burners must be required to use alternatives to burning for portions of the biomass whenever possible. (ISSRC) Response: The state-required changes to Ru le 4103 will effectively ban open burning by 2010 except where required fo r disease control or where economic alternatives, such as composting, are not available. Staff will consider those issues as part of implementing this control measure.

8. Comment: S-COM-1, Boilers, Steam Generators, and Process Heaters >5 MMBtu/hr: Amend Rule 4306 to require a NO x limit of 5 PPM for units less than 20 MMBtu/hr and 2 PPM for units greater than 20 MMBtu/hr, with a scheduled compliance by the year 2012. (ISSRC) Response: The rule amendments for this cont rol measure are currently in development. The limits and timetables suggested by the commenter will be considered during the rulema king project. State la w requires the District to consider technological and economical feasibility when developing rules.

9. Comment: S-COM-2 , Boilers, Steam Generators, and Process Heaters from 2 to 5 MMBtu/hr: Amend Rule 4307 to require a NOx limit of 9 PPM for all units, with a scheduled compliance by the year 2012 or electrification of units by the year 2014. (ISSRC) Response: Please refer to the response to Comment 8.

10. Comment: S-COM-3, Boilers, Steam Generators, and Process Heaters from

.075 to 2 MMBtu/hr: Amend Rule 4308 to r equire a NOx limit of 30 PPM for all units, with scheduled compliance by the year 2012 or electrification of units bySan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-51 the year 2014. As a minimum, Rule 4308 must be upgraded to BARCT level by making it as stringent as Sout h Coast AQMD Rule 1146.2. (ISSRC) Response: State law requires the District to consider technological and economic feasibility when developing rules. During rule development, staff will consider the suggested control le vels and implementation schedules.

11. Comment: S-COM-4 , Solid-Fuel Boilers, Steam Generators, and Process Heaters: Require baghouses and SCRs (a s used in a biomass power plant in Ulm, Germany) on units burning biomass for f uel to meet 40 PPMV at 3% O2 for all units except municipal waste units. Municipal waste units should be required to use baghouses and meet 70 PPMV at 3% O2, which can be attained by using SNCR or SCRs, as done in many units in Germany. (ISSRC) Response: Current Valley solid fuel fired facilities are equipped with SNCR, scrubbers, and/or particulate controls. The German units may represent levels achievable only by the newest facilit ies and may not be reasonable for add-on controls. Attempting to meet lower NO x limits for one Valley facility has resulted in excessive ammonia slip and increased PM in the form of a detached plume.

Staff is committed to reexam ining the potential controls for this category and will

consider the latest available controls f easible at the time of rule development.

12. Comment: S-COM-6, Reciprocating Internal Combustion Engines: At a minimum, upgrade Rule 4702 to BARCT level by making it as stringent as South
Coast AQMD Rule 1110.2. (ISSRC) Response: The South Coast rule is based on the wholesale replacement of existing engines with new lean-burn engi nes or electrical motors. Valley stakeholders have made great strides in moving to electrical motors, where possible, but the limitations of fixed electrical and natur al gas supply lines do not allow this for all operations. The curr ent rule reflects technologically and economically available control options, but staff is committed to reexamining this

issue in the future to take advant age of future control technologies.

13. Comment: S-COM-7 , Glass Melting Furnaces: Since SCRs have been used successfully in Europe and Japan and will soon be the control technology for a glass manufacturer in the San Joa quin Valley, these devices are proven technology and should be required for all glass making facilities in the San Joaquin Valley Air Basin. (ISSRC) Response: The rule development project for this control measure is in progress and SCR-level limits are currently propos ed, as was discussed in the Plan, page

I-31.

14. Comment: S-COM-11 , Dryers, Ovens, Dehumidif iers, and Other Process Equipment Used in Industrial Processes (excluding glass products production):San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-52 This category includes dryers, ovens, and dehumidifiers that are 5 MMBtu/hr and above that are subject to Rule 4309. In ARB’s emission inventory used for the

2007 Ozone Plan , the category also covers smaller units that appear as area sources, whose emissions are estimated us ing fuel delivery reports (specifically, it is reported as Unspecified Agricultur al Processing Losses, with NOx emissions totaling approximately 9 Tons Per Day). Rule 4309 should be expanded to cover

these area sources and which should be re quired to emit no more than 30 PPM

at 3% O2---similar to the small boiler ru le requirements. In the South Coast AQMD Ozone Plan, CMB-1 addresses thes e small units and will be required to

use low-NOx burners. Units similar to t hose covered currently under District Rule 4309 have been subject to requirements th rough RECLAIM and other facilities improvement programs, not through a prohibitory rule. Other permitted units not covered by RECLAIM programs have NOx em ission limits, which at the time of permitting was the BACT/LAER standard. (ISSRC) Response : As a feasibility study measure, District staff will be re-examining this category to verify the current emissions inventory estimate and assess control feasibility. "Uns pecified Agricultural Processi ng Losses" cannot be regulated without more information on what type of equipment is generating those emissions. This notation by the ARB is ju st a way to account for emissions that

are too small to otherwise fall into one of the other categories. District staff will reexamine this category and take into a ccount any controls that the SCAQMD may develop for these units on the schedule proposed in the plan.

15. Comment: S-GOV-1, Prescribed Burning and Hazard Reduction Burning: Amend Rule 4106, Section 5.2.3.11 to r equire a more vigorous evaluation of alternatives to burning. The current pr ovision stating that those that have met NEPA and CEQA requirements are consider ed to have satisfied this requirement is inadequate, since it does not reflec t up-to-date conditions and technological

advancements for alternatives to bur ning. Although burning may not be avoidable for certain circumstances, it s hould not preclude using alternatives for certain portions of the biom ass that can be handled by alternative methods, such as chipping and composting. (ISSRC) Response: The Feasibility Study for this ca tegory is underway and will examine alternatives, including those currently used to minimize burning. It is important to note that such burns are controlled by the District's Smoke Management System and are not allowed when air quality is fore cast to be unhealthy. It is also important to note that fi re is a natural part of the wilderness ecology.

16. Comment: S-IND-4, Fugitive PM10 Prohibitions: Co nsider subjecting on-field agricultural operations to prohibitory regulat ion, specifically requiring curtailment of activities during wind conditions conduciv e to entrainment of dust. Although the portion of PM2.5 in agricultural dust is only around 10%, the months of September, October, November, and ear ly December show above average readings of PM in all size ranges and may c ontribute significantly to violations ofSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-53 the 24-hour PM2.5 standard. If on-field agricultural operations are not done during windy conditions, as part of an operation’s Conservation Management Practices, then the operation can be consid ered exempt from this requirement of

curtailment. (ISSRC) Response : On-field operations are addressed in Rule 4550. Farmers

understand that it is not in their best in terest to conduct such operations during high wind conditions, which can accelerate erosion of valuable topsoil, degrade farm equipment, and create unsafe working conditions. This practice is

considered to be so universal that no credit could be taken for it. Also refer to the response to Comment 4 for further information.

17. Comment: Facility Modernization Program: Si milar to the South Coast AQMD’s proposed measure, identified in the 2007 AQMP as MCS-1, require facilities to modernize permitted equipments and pr ocesses, based on pre-specified equipment useful life, as determined during rule making. In addition, facilities would be required to use super-compliant VO C materials. The objective of such a measure is to upgrade existing equipm ent not subjected to NSR’s BACT requirements by retrofitting with BACT te chnology or to completely replace existing equipment with new equipm ent equipped with the latest BACT technology. Equipment and processes that are not beyond the pre-specified equipment useful life will remain subj ect to existing prohibitory rules. (ISSRC) Response: District BARCT rules are essentially identical to South Coast’s “modernization program.” The District requi res existing equipment to be either retrofit with add-on controls or replaced with lower emitting equipment to meet

BACT levels.

18. Comment: Rule 4692, Commercial Charbroiling : Ban all residential charcoal or wood fueled outdoor barbeques, or limit them to days that would meet the criteria for an ag burn. At the very least, ban use an d sale of kerosene lighter fluid at all times. Electric coil starters work perfectly well. (Menz) Response: Reducing emissions from residentia l sources of pollution requires careful consideration of the public’s behavio r patterns and the public’s willingness to change behavior. Swift, outright bans on widespread public activities are difficult to engage, are hard to equitably enforce, and can result in long-lasting negative impacts and distrust. A historically more successful approach is to raise the public’s awareness of t he problem, and to work steadily for a gradual change in the public’s behavior. A well-designe d and considerate regulation, coming after a meaningful public debate, can re sult in significant and enduring public benefits. District Rule 4901 (Wood Bu rning Fireplaces and Wood Burning Heaters) is an excellent example of this kind of successful process. The District’s Healthy Air Living program is designed to spur comprehensive lifestyle changes and conversations by providing a practical demonstration that change is easier than anticipated and that the changes can result in multiple payoffs.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-54 Residential barbecues will be addressed significantly in the District’s Healthy Air Living program.

19. Comment: Leaf Blowers/Fugitive Dust: Make it illegal for anyone to raise visible dust that leaves one property and trav els to another property or public thoroughfare. (Menz) Response: As required by state law, measures that are not necessary to meet the requirements of the feder al Clean Air Act are not to be included in a State Implementation Plan. The District funded a study of leaf blowers in 2005, and the study showed that the Valley-wide PM2.5 emissions inventory for leaf blowers is 0.26 tpd (whereas the total PM2. 5 inventory in 2005 for the Valley was about 103 tpd). Although controlling leaf blowers may be inappropriate for the Valley as a whole at this time in terms of bringing the Valley into attainment of the PM2.5 standards, it may be appropriate for regul ation at the city or county level.

20. Comment: Residential Wood Burning: Fines for those who violate residential wood burning prohibitions s hould be increased to $1000 for the first offense. In addition, offender’s flues should be filled with urethane foam. (Menz) Response: The District’s fines are set to br ing the offender into compliance.

21. Comment: Residential Wood Burning: The residential wood combustion prohibitions should be based on meteorolog ical criteria that would cause an
exceedance of the NAAQS if residential wood combustion were allowed. The prohibited declaration is the largest singl e action the District can take to protect the NAAQS and public health. (Shipp, ISSRC) Response: The District will consider this comment in the rule amendments for

Rule 4901.

22. Comment: Residential Wood Burning: Lower the threshold for declaring mandatory curtailment. (ISSRC) The District should quantify how much a total ban on urban residential wood burning woul d accomplish. At the very least, prohibit burning when the PM2.5 concentration s are forecast to be at or above 35 μg/m3. (Menz) Restricting all woodburning coul d reduce 1 tpd of NOx and 8 tpd of PM2.5 at virtually no cost. (KOR, SJR) Response: The District is proposing to lower the threshold for declaring mandatory curtailment from 65 μg/m3 to 35 μg/m3, which could reduce 1.4 tpd of emissions as averaged over a winter s eason (October – March), or about 14.8 tons of reductions on any Valley-wide no-burn night.

Incentive programs -San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-55 23. Comment: The District and the Agricultural I ndustry must develop a truck trade down program to replace trucks built pr ior to 1996 to help m eet the need of both agriculture (which cannot pass on incr eased operating costs) and regulations (such as ARB’s Draft Heavy-Duty Truck Rule). Many farmers’ on-road vehicles are very low mileage, special designed/ build, and used in a limited capacity. ( Nisei) Response: The District has held public workshops and meetings with industry to discuss initial concepts for a truck trade dow n program. This District will take into consideration the request to replace trucks built prior to 1996. Please sign up for the District's list serv at http://www.valle yair.org/lists/list.htm to ensure you receive notices regarding meetings and new program development.

24. Comment: Neither the District or the Agricu lture Industry has received any SIP

credit for the emissions reductions achi eved by EQIP funded inventive programs,

such as those focused on conservation t illage programs; oiling, graveling, and other dust suppressing agents on unpaved roads; reduction of agricultural burning through chipping; water m anagement, dust suppression and manure management on livestock facilities; and engi ne replacements. These and future incentive reductions should be credited. ( Nisei) Response: As discussed in Chapter 7 of the 2007 Ozone Plan , the District has embarked on a major new effort to ensur e SIP creditability for incentive-based emission reductions for incentive programs ad ministered by the District. As part of adoption of the 2007 Ozone Plan , the District Governing Board also adopted a separate resolution describing how the District’s incentive programs would be operated in the future to ensure SIP credi tability of emission reductions. The

elements of this resolution were dev eloped with the U.S. Environmental Protection Agency over the course of a ye ar-long pilot project aimed at identifying how an incentive program would need to be operated in order to ensure SIP creditability of emission reductions from the program. The Dis trict is currently implementing the items in the resolution a nd hopes to start seeking SIP credit for

incentive-based reductions after 2009. Programs such as EQIP, which are operated and administered outside of the Dis trict, would need to meet the same operational criteria identifi ed in the resolution referenced above, such that these programs then would be functional equivale nts of the Distric t’s SIP creditable incentive program. If this equivalency was established, then reductions from incentive programs outside of the Distr ict would also be SIP creditable.

25. Comment: The District should take South Coast’s proactive approach to promote and accelerate the installation of mob ile source diesel particulate filters. An AP news article reported that “diesel exhaust alone accounts for 84% of the region's [South Coast] cancer risk," which is undoubtedly similar in the San Joaquin Valley. The District 's PM2.5 Plan should include specific programmatic initiatives, especially outr each, education and facilitati on, to leverage and amplify the effectiveness of ARB progr ams. "Off-the-shelf" diesel particulate filters forSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-56 trucks provide up to 90% of potential PM r eductions at a fraction of the cost of truck replacement. The PM2.5 Plan should reflect the role the District could play

to facilitate utilization of the ARB's in centives (and thereby accelerate the corresponding health benefit s) in the Valley. (Weil) Response: South Coast’s diesel emissions (suc h as those from ports) are more likely to be located near population c enters. More analysis would be needed to determine the cancer risk from diesel exhaust in the Valley.

The District has been proactive promoti ng and accelerating the installation of mobile source diesel particulate filters. The District paid ov er $2.2 million in incentives for mobile source diesel par ticulate filters from 2003-2007. Over 150 particulate filters were installed due to the District's efforts. However, the District believes that it is important to also fund devices that reduce both NOx and PM

emissions because NOx emission reductions assist the District in attaining both

the federal and state ambient air quality standards for bo th particulate matter and

ozone.

Contingency measures –

26. Comment: In light of the uncertainties of the incomplete modeling used for the draft plan, as well as uncertainties in the emissions inventory, it is paramount to adequately document contingency measures in the event that new information

indicates it is more difficult to meet attainment. The contingency measures discussion should consider the following: effectiveness of these contingency measures to expeditiously bring a bout the attainment of the 1997 PM2.5 standards; the timing of impl ementation, especially in the event that the RFP demonstrations are not met; the duration of these c ontingency measures; and an analysis of who will be so cioeconomically disadvantaged or affected by these contingency measures. Several reasonable contingency measures that should be addressed in the plan include:

• Prohibit the operation of the highes t NOx-emitting equipments such as used in agriculture, construction, and other off-road applications on days forecasted to be high PM days.

• Prohibit the operation of lawn and garden equipment on days forecasted to be high PM days.

• Prohibit the operation of fireplac es and other wood-burning devices on days forecasted to cause violations of the higher 24-hour PM2.5 standard of 35 μg/m3.

• Mandatory participation of all employers in alternative transportation programs during the PM season.

• Mandatory 50% reduction of NOx, PM2.5, and SO x by 2017 from all stationary sources. (ISSRC) Response: The District recognizes the contingency measure requirement, as outlined in Chapter 9. The Distric t is already proposing wood burning prohibitions at 35 μg/m3 and a mandatory al ternative transportation program forSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-57 employers, so these cannot also serve as contingencies. Prohibiting certain activities on “high PM” days is problematic under an annual standard (mathematically, it is possible to have m any days over the level of the standard yet still meet the standard w hen an entire year is aver aged). Furthermore, lawn equipment and construction equipment t end to be used more in the summer while the PM levels are typically highest in the winter.

A mandatory 50% reduction of NOx, PM2.5, and SOx by 2017 from all stationary sources is inappropriate for several reasons. Stationary sources comprise a relatively small portion of the invent ory (about 26% of t he 2017 NOx inventory

and 18% of the PM2.5 invent ory). The Valley’s stati onary sources are already heavily regulated and have achieved signifi cant reductions. In cases where foreseeable technology can achieve additio nal stationary source reductions, the District is already proposing additional control measures. Requiring a 50% reduction for all stationary sources wit hout identifying proven technologies or methods for achieving those reductions woul d be unlikely to yield the satisfactory socioeconomic analyses and enforceability necessary for fully adopted control measures. As stipulated in the adopted 2007 Ozone Plan , the District is developing an Employer Based Trip Reduc tion Rule. However, the rule would not be a contingency measure because emi ssions reductions would start taking place after rule implementation and would not need to wait until the Valley failed

to meet an RFP or a ttainment milestone.

Please refer to Chapter 9 in the 2 nd Draft PM2.5 Plan for the District’s contingency measures.

Emissions Inventory –

27. Comment: In mid-2007, new emissions da ta on heavy-duty vehicles has been released that significantly changes t he inventory. This data should be incorporated into the a ttainment demonstration. (ISSRC) Response: The California Air Resources Boar d (ARB), as part of a process to develop an emissions control rule for in-use heavy duty diesel trucks, has been working on a revised mobile source emissions inventory that uses new techniques to estimate em issions from trucks stat ewide. Although ARB has

“released” some of these emission estima tes at workshops for this rule, they have not yet published a peer-reviewed, fully-vetted emissions inventory, incorporating these new data, for use in a federal air quality plan prepared under the federal Clean Air Act (CAA). Furthe rmore, ARB has not yet submitted these new, revised emissions to EPA for approv al for use in State Implementation Plans (SIPs), nor has EPA approved these new, revised emission estimates for use in SIPs or for use in transportati on conformity determinations. On January 18, 2008, EPA approved the State of Califor nia’s latest on road motor vehicle emissions model EMFAC2007 (73 FR 3464). In its approval notice, EPA notes that “CAA section 172(c)(3) and 40 CFR 51.1 12(a)(1) require that SIP inventoriesSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-58 be based on the most current, accurate, and applicable models that are available

at the time the SIP is developed. CAA section 176 (c)(1) requires that the emissions estimates be used in conformity analyses. EPA approves models that fulfill these requirements. Under 40CFR 93.111(a), EPA must approve new versions of EMFAC for SIP purposes bef ore they can be used in transportation conformity analyses.” Section 176(c) of the CAA requires transportation conformity to ensure that federally -supported transportation activities are consistent with (conform to ) the purpose of the SIP. At present, the Federal Highway Administration has directed California transporta tion planning agencies to effectively stop using the previous version of EMFAC (EMFAC2002) and to start using the newest version of EM FAC (EMFAC2007) for all conformity determinations started after August 1, 2007 1 (73 FR 3465). And EPA has directed California transpor tation planning agencies to start using EMFAC2007 for analyses started on or after April 18, 2008. No other federally-approved

emissions model exists at this time for California for use in SIPs or conformity determinations; consequently, the new, prel iminary data “released” by ARB in

mid-2007 can not be used in the 2008 PM2.5 Plan

.

28. Comment: There are several source categor ies where the emissions inventory is documented to be unknown, or highly uncertain. These categories could have a significant impact on the attainment stra tegy. An update of the inventory for the following sources should be completed over the next several months. Upon the completion of the inventory updates, attain ment analysis and strategy should be re-evaluated and the plan updated. The sources recommended to be updated

are:

• Small Spark-Ignited Engines and Agricu ltural Spark Ignited Engines (S-COM6A1) The current inventory does not provide any estimate from this source. To obtain an estimate of this inventory, a survey of businesses and industries is needed to accurately determine the tota l number of small engines and to calculate their emissions, and a survey of agricultural o peration sources is needed to accurately determine the total number of spark-ignited engines.

• Fugitive PM10 Prohibitions (S-IND-10) The current inventory does not provide any PM2.5 emissions estimate from

these sources. District staff recomm ends that a Feasibility Study, to

determine PM2.5 emission factors and appropriate PM2.5 controls, be completed by 2009. It is recommended t hat this be conducted immediately,

since the emissions from this source may be significant.

• Flares (S-IND-21)

1 On February 1, 2007 the Federal Highway Administration directed California transportation planning agencies to use more recent vehicle activity data consistent with la test planning assumptions for conformity determinations requiring a new regional emissions analysis and begun afte r August 1, 2007. Since the vehicle activity data are
embedded in EMFAC, this was a de facto dire ctive to use EMFAC 2007 after August 1, 2007.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-59 Although there is an estimate of the emissions from th is source, District staff

indicates that current NOx emissi ons appears to be low and may have only accounted for the emissions generated by the gas fuel used by the flare pilot

flame. It is recommended that an inve stigation on the emissions generated during emergency flaring events be conduc ted in the next few months and updated in the inventory.

• Farm Equipment (M-IND-1)
The farm equipment category is a very la rge source of NOx emissions, and is not well understood in terms of the activity rates by tractor types and times of day/year from the current farm tracto r inventory. It is recommended that

District staff over the next few months conduct a study to estimate these items, update the inventor y, and conduct cost analysis for control options, including retrofit and replac ement, and episodic controls. (ISSRC) Response: As discussed in Appendix B, em issions inventories undergo continuous updating and changing to improve accuracy, respond to new scientific and engineering developments, and to address changes to laws and regulations. A snapshot of the inventory is used to develop air quality plans. Future plans and midcourse reviews will provide additiona l opportunities to incorporate new

emissions inventories into the attainment evaluation process.

(S-COM-6A1) The Small Spark-Ignited Engines and the Agricultural Spark Ignited Engines are currently being reported in the area source inventory. The

area source emissions estimates for nat ural gas-fired industrial and commercial equipment were updated last year (EICs 050-040-0110- 0000 and 060-995-0110- 0000). Area source estimates for agr icultural spark ignited engines and commercial and industrial engines using other fuel types are in the process of being updated (EICs 050-040-0012- 0000, 050-995-0120-0000, 052-042-0110- 0000, 060-995-0120-0000).

(S-IND-10) The District is already re viewing currently available data.

(S-IND-21) The District apprec iates that this issue in the draft plan has been noted. After re-examination, it has been determined that all flares within the Valley are required to report the total amount of gas flared to the District’s emissions inventory program. The District will continue to work with permit

holders to insure that emissions from both the pilot gas and flaring events are reported and included in the inventory.

(M-IND-1) The California Air Resources Bo ard is in the proc ess of updating the emissions inventory for this category, and expects to release a revised estimate by December 31, 2008. Although the Dis trict has no regulat ory authority over these sources, we will continue to purs ue opportunities for emissions reductions through our grants and in centives programs.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-60 Modeling and Meteorology –

29. Comment : The plan needs complete regional photochemical modeling, as required by EPA. Without this modeling, the NOx based approach is an over generalization of what it ta kes to get to attainment. (ISSRC, Shipp) Response: ARB is preparing the regional modeling evaluation in accordance with EPA guidance. The attainment demons tration is not meant to be solely based on the regional model, but on a we ight of evidence of all supporting technical assessments and other types of modeling. The PM2.5 Modeling

Protocol identifies the c ontributing evaluations. Tw o prior regional modeling evaluations conducted for the prior PM10 plans evaluated small particle

formation of nitrates and sulfates and cons istently identify NOx reduction as the essential pathway to particulate reduction in the Valley. Due to the conservative approach provided by receptor analysis li near methods, the r egional model may provide a lower estimate of reductions needed to achieve attainment. However, the model should not be expected to alter the finding that nitr ates are the key portion of PM2.5 in the Valley, as such a result would be in conflict with observed speciated samples collected at monitoring sites as well as every other technical evaluation and scientific air quality study conducted in the Valley.

30. Comment: The role of VOCs and ammonia in PM2.5 formation has not been adequately addressed. (ISSRC) Response: The role of VOC and ammonia in PM2.5 formation has been evaluated as a component of the 2003 PM10 Plan and through scientific third party evaluations performed as part of the CRPAQS project. Findings from these

studies and evaluations are documented in the Modeling Chapter of the PM2.5 Plan, the Modeling Protocol for th e Plan, Appendix E to the Plan, and a worksheet within the Recept or Modeling analysis (see Control Effectiveness). These findings represent the results of tw o regional modeling evaluations as well as a variety of scientific research. All of these materials are available to the public on the District web site, and CRPAQ S study documents are available on

the ARB web site.

31. Comment: Since the plan lacks photochemical modeling, there is no model evaluation as specified in the SJV protocol and EPA guidelines. (Shipp) Response: The protocol identifies a series of technical evaluations that contribute to the weight of evidence det ermination of attainment. Results of ARB’s photochemical modelin g are expected for the nex t draft of the plan. Receptor modeling based on both CMB and PMF models has already been completed. The modeling protocol also identifies how the receptor analysis meets or exceeds the EPA guidance requirements for the speciated modeled

attainment test.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-61 32. Comment: The plan does not address meteor ological representativeness. The years the plan is based on (2004-2006) have had better meteorology than past

years. (ISSRC, Shipp) Response: The District performed an examinati on of meteorological trends in the San Joaquin Valley. Statistics for 100 year and 20 year meteorological

databases were reviewed. These statistics did not indicate that meteorology for

2004-2006 was abnormal.

Statistical analysis was performed to determine the relationship between meteorological indicators and PM2.5 c oncentrations. The results of these analyses indicate that the relationsh ip between examined meteorological indicators and PM2.5 is poorly correlated and not statistically significant. It would be inappropriate to adjust particulate dat a based on poorly correlated indicators.

In addition, PM2.5 data has been collected for a relatively short time frame, resulting in a database that does not hav e a statistically adequate number of samples for a long-term trend compar ison between PM 2.5 and meteorology.

Ozone data has been collected for a much longer time period than PM2.5. The EPA presents meteorological adjusted ozone analyses for Bakersfield and Fresno at the following website: http://www.epa.gov/air/airtr ends/weather/region09.pdf#page=4

The EPA analyses for Bakersfield and Fresno indicates that there is very little difference between actual data and trend-adj usted data for the period 2004-2006.

This contradicts the comm ent that 2004-2006 had 'bette r' meteorology than past years. The District welcomes informa tion developed by the commenter that

addresses this issue.

33. Comment: The more recent high PM2.5 c oncentrations in 2007 may show that the San Joaquin Valley Air Basin has not met the 1997 24-hour PM2.5 standard, as claimed in the “draft” plan. (ISSRC, Shipp) Response: Air monitoring data collected in 2007 is not available for reliable evaluation until standard qualit y control review (performed annually) is complete. In addition, EPA specified the years of dat a expected to be used for this analysis and did not include 2007. Despite thos e issues that prevent an immediate assessment of 2007 data, the District has reviewed available data prior to completion of the quality assurance. It is possible that 2007 data will cause design values to exceed the resci nded 1997 24-hour PM2.5 standard at two sites, and possibly at a third site that colle cts filter samples (for which preliminary values are not available). However, t he District’s preliminary evaluation also

indicates that even without contro l measures from the adopted 2007 Ozone Plan or the draft PM2.5 Plan, t he forecast 2014 emissions contain sufficient reductions to attain the daily standard. Because additional reductions are needed to attain the annual standard, the annual standard will set the carrying capacity for ValleySan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-62 emissions, and the higher design values caused by 2007 monitoring data will not require a revision to the control strategy or identification of additional required

reductions. A more detailed discussion of this finding will be provided in the next draft of the plan.

34. Comment: The plan should include meteorolog ically adjusted trends analyses

to determine whether there is a statistica l significance to the recent, lower PM2.5 concentrations. The District should provi de meteorologically adjusted averages

for both annual and winter PM2.5 seasons and the number of exceedances of the 24 Hour NAAQS per year. (Shipp) Response: Please refer to the response to Comment 32.

35. Comment: The plan does not adequately address t he effect of controlling for the

annual standard on the 24-Hour NAAQS. Although numer ous exceedances of the 65 μg/m3 24-Hour PM 2.5 NAAQS have o ccurred during the last five years, the plan dismisses these. EPA has not officially designated the Valley as attainment for the 65 μg/m3 NAAQS. Also , the District has not proven that major weather stagnation events will not c ause more NAAQS violations. (Shipp) Response: (See also the response to Comment 33) The daily values have not

been dismissed. The amount of reductions required to comply with the 65 μg/m3 standard is significantly less than is requi red to achieve the annual standard even if available uncertified 2007 monitoring data is considered.

Data analysis indicates that recent PM2.5 levels associated with stagnation events are not as high as concentrations recorded in the past when stagnation

events of similar duration occurred. This indicates that particulate levels have been responsive to the prior implementation of reductions. As emissions continue to decline in future years, it is appropriate to conclude that the stagnation events are appropria tely addressed by the control strategy. As previously discussed, t he annual standard requires more reductions to achieve compliance and sets the timeli ne for expected attainment.

36. Comment: Weight of evidence using trends and data analysis for both the 24-

hour and annual standard needs to be address ed in the plan. Although the plan

stated that there is not enough data to do trends analyses, fine particulate data does exist back many years, and this anal ysis needs to be incorporated into the plan. There is enough dat a at the Fresno-1 st Street site to look at trends for several years of nitrate and carbon data. (Shipp) Response: Speciated data has only been collected since 2001 in Fresno and since 2002 in Bakersfield, Modesto and Visalia. Speciated data (which subdivides PM into component parts, such as carbon, nitrate, sulfate or geologic material) links changes in particulate mass le vels to variations in the contributing sources. Since only a few years of ce rtified data are available (2002, 2003,San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-63 2004, 2005 and 2006), and since SIPs use thr ee-year averages to help control for meteorological variation, only th ree data points (2002 -2004, 2003-2005, and 2004-2006) are available for trends analysis. The extent of the data record is not comparable to the historical data ava ilable to evaluate ozone trends. South Coast used dichotomous sampler data to establish trend evaluation; however, this type of sampler was withdrawn from operation in the Valley several years ago and is not available for this purpose for the Valley.

Other –

37. Comment: (Regarding information in page E-32, section 3.c) The District and ARB need to work with the Agriculture Indus try to identify a viable alternative to burning agricultural waste besides biomass fa cilities. In 2007, biomass facilities couldn’t process all of the agricultura l waste, due to unforeseen circumstances. (Nisei) Response: The District understands that th e discontinuation of open burning is a major financial concern to several sector s within the agricultural industry. The District is committed to continuing to ex plore and encourage alternative practices in partnership with the industry and ARB. It is noted that SB 705 prohibits the burning of surface harvested orchar d prunings and vineyard removals commencing June 1, 2010. The District will wo rk with agricultural stakeholders to investigate and develop non- open burning alternatives well in advance of the

2010 deadline.

38. Comment: The District used ARB reductions for 2014 that came from ARB’s Revised Proposed State Stra tegy for California's 2007 SIP, April 26, 2007, page 63. The more recent adopted September 27th state strategy should be used, addressing the new commitments. (ISSRC) Response: The September 27 th state strategy only included updated reductions for 2017, so 2014 reductions must come fr om the April 26, 2007 version of the

state SIP.

39. Comment: Please explain the basis for assu ming that ARB’s reductions (line 8, Table 9-1) follows a linear progression. An appropriate prorating of ARB emissions reductions, documenting compliance schedules and rulemaking

documents should be followed for the new commitments. (ISSRC) Response: The District used a linear progre ssion of ARB reductions as an initial, draft assessment. ARB has thus for committ ed to only 2014 reductions beginning in 2014 thus far. Future ve rsions of the plan will reflect ARB commitments as opposed to linear prorating.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-64 40. Comment: Please explain the statement that e fforts done for this plan will assist in the attainment of the more stringent fu ture standard. If facilities comply with requirements now, then are asked again to change to more effective controls, won’t this increase the compliance cost for these facilities over the long term? (ISSRC) Response: The District is proposing the most effective, feasible controls possible, based on current technology. As future versions of the plan will show, the reductions needed to bring the Valley into attainment of the 15 μg/m3 annual standard will also help br ing the Valley much closer to the 35 μg/m3 24-hour standard as set in 2006. Also, the Distr ict is proposing to set the Wood burning

curtailment to the leve l of the 2006 standard.

41. Comment: Page 3-29 of the Decem ber 4, 2007 draft of the 2008 PM2.5 Plan

states:

“ As a result, a simplified modeling ex ercise was conducted by ARB to help estimate the Valley’s carrying capacity for PM2.5. Evaluation of the San Joaquin Valley ozone control strategy to attain the federal 8-hr ozone standard determined that the ozone plan include NOx emissions reductions

that are close to what is needed for attainment of the 1997 PM2.5 standards by the maximum possible statutor y attainment date of April 5, 2015. Based on simplified modeling exerci ses performed at the time the ozone plan was completed, the ozone control strategy was determined to have a design that would provide most – if not all - of the reductions needed to attain the PM2.5

annual standard.” Based on Table 9-1, this assertion is hi ghly flawed, since attainment of the 1997 PM2.5 standards was only made possibl e by inventory adjustments of approximately 40 TPD of NOx (Line 3). It should be noted that this adjustment was discovered by ISSRC after the 2007 Ozone Plan was approved by the District and ARB governing boards. The quoted statements show that District planning efforts did not exam ine possibilities for the earlie r attainment of the 1997

PM2.5 standards. It is an admission t hat planning for the 1997 PM2.5 standard was not done for the purpose of meeting the 2010 deadline. (ISSRC) Response: The inventory adjustm ents are based on based thorough, periodic reviews of emissions inventory methodol ogies. These adjustments were also incorporated in the modeling (which sets the targets listed in Table 9-1), and the adjustments occur in past as well as future y ears. Also, future drafts of the plan will incorporate these adjustm ents into the baseline inventories, so these off-line adjustment tables and references will be removed.

Although 2010 is the initial attainment deadline, EPA allows up to a five-year extension. As shown in Table 9-1, t he District is examini ng the possibility of attainment in every possible attainment y ear. As the commenter notes in another comment, part of the chal lenge in demonstrating attainment before 2014 is the

need for commitments for ARB reductions be fore 2014. The District will continueSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

2008 PM2.5 Plan Appendix J-65 to consider the earliest attainm ent possible with updated reductions and attainment targets.

42. Comment: The District should examine the po ssibility of earlier attainment of the 1997 PM2.5 standard by considering the control measure comments. A 2013 attainment year (through additional NOx reductions from District, State, and federal sources, in combination with t he PM2.5 and SOx reductions) should be examined thoroughly. (ISSRC) Response: The District will continue to consider the earliest attainment possible with updated reductions and attainment targets.

43. Comment: The plan has very complex topics that require adequate review time by qualified experts. There should be a 30-day comment period once the release of a complete draft document is available. (ISSRC) Response: There will be additional opportunities for public comment. There will be a brief public comment period coincidi ng with a second round of workshops. This will be followed by a final 30-day comment period and a public hearing.

44. Comment : The plan should address the length of PM2.5 episodes in the SJV and their effect on public health. (Shipp) Response: Bringing the Valley into attainm ent of the primar y federal PM2.5 standards will protect public health. EPA’s health-based standards are based on long term (i.e., annual) and short term (i .e., 24-hour) average exposure as opposed to intermediate durations like episodes.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix J: Comments and Responses

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