2008 PM2.5 Plan 

Appendix J 

 

Comments and Responses 
2008 PM2.5 Plan 

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San Joaquin Valley Unified Air Pollution 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 received 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 comments are summarized and 

organized by topic in Section J.6. 

The District held workshops on the 2nd Draft 2008 PM2.5 Plan were held on February 25 

and 26, 2008, and the public comment period for 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 Associations requested that the District 

complete a more thorough analysis and response 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. These written comments are summarized and 

organized by topic in Section J.1. 

J.1 WRITTEN COMMENTS ON THE PROPOSED 2008 PM2.5 PLAN 

Comment period held from March 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 Quality Coalition, Fresno Metro Ministry, 

Fresno/Madera Medical Society, 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 Systems Research Center (ISSRC) 

Evan Shipp (Shipp) 
San Joaquin Valley Unified Air Pollution 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 premature death, heart disease, heart 

attacks, cancer, asthma, and other respiratory 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 the 2006 Federal PM2.5 Standard 

2. Comment: Despite repeated requests, the plan doesn’t include information 

about its progress towards the more health protective California PM2.5 standard 

and the 2006 Federal PM2.5 Standard. The plan should include more specific 

information about how and by when this plan 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 the 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, calculated for the federal standard) can provide an estimate of 

progress towards the state standard, it should be noted that the State standard 

uses a different calculation for the form of the standard, and thus the two are not 

directly comparable. 

The District is prohibited by state law (California 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 standard 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 data for the single year immediately preceding the 

attainment date is within the standard (and it planning requirements have been 

met), the area is eligible for a 1-year extension. 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 one-year extensions. It follows that 

in basing attainment on a 2014 carrying capacity, it seems that the District is 
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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 reductions 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 the Federal Clean Air Act for 

failure to attain the standard by April 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 retrospective 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 years 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 projected attainment year, as the year to model for the “final” 

year for planning purposes. In this guidance, 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 the monitors in the area.” For more 

information on design values, please refer 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 emissions projection year is multiplied by 

the design value to predict the future design value. This projected design value 

is used to determine the sufficiency of the plan, from a planning perspective, and 

must meet the standard or be close to the standard and be confirmed as an 

acceptable target through weight of evidence evaluation. Because the projection 

to 2014 was close to the standard, both the District and ARB prepared weight of 

evidence evaluations that conclude that 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 the 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 required 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 achieved. The District believes that the 

progress predicted by the modeling is conservative and has also committed to a 

variety of additional reduction efforts to advance progress for attainment. Many 

of the additional reductions are not quantified in the model due to EPA 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-4 

constraints on accounting for reductions that are not fully funded or are 

conducted through voluntary programs. The District believes 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 progress. 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 included in Table 3-2 as the "Predicted 

Compliance Year" with discussion for each site included in Section 3.4.1 

Discussion of Results. ARB’s regional photochemical modeling was conducted 

for for 2007-2009 and 2012-2014. Table 9-1 shows 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 earlier 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 year based on attaining within the first 5 

year period.” The document goes on to indicate that “Area that request and are 

granted attainment date extensions should consult with their Regional Office 

regarding future year modeling analyses and requirements.” (ISSRC)

Response: The District has followed the procedures of the PM2.5 

Implementation rule as well as EPA modeling guidance. The District and ARB 

have worked very closely with EPA Region 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 (RFP) is important for ensuring 

continuous health benefits as an area progresses towards attainment. (ISSRC)

Response: Comment noted. Based on the analysis of Dr. Jane Hall, the District 

and ARB strategy will result in the elimination of an estimated 460 premature 
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Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-5 

deaths each year when the entire air basin reaches attainment. Before that time 

it is estimated that 1500 premature deaths 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 impost a ‘one-size-fits-all’ approach. ... 

The EPA believes that defining the RFP requirement 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 strict percentage reductions to apply 

nationwide, the PM2.5 Implementation Rule does not preclude regions from 

calculating their own percentage reductions. Table 8-4 helps to demonstrate that 

the Valley’s progress towards attainment is generally linear. 

8. Comment: The plan does not follow the procedure 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 reductions 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. However, EPA also notes (72 FR 20635) 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 implementation, the final increment 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 Rule implementation poses a 

significant challenge to the Valley’s ability to demonstrate RFP milestones in 

2009 and 2012. (CCA)

Response: At ARB’s direction, ARB control measure commitments do not show 

reductions prior to 2014, due to the complexities of implementation. Although the 

District agrees with the commenter that ARB 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 Measures 
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Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-6 

10. Comment: In Comment #22 in for the March 13 draft, the District said that 

ISSRC commented that $30 million in fees would bring 1/5 tpd of NOx 

reductions. In actuality, ISSRC wrote that $30 million would result in 1.5 tpd of 

NOx. Please acknowledge the error. (ISSRC)

Response: This typographical error has been corrected. 

11. Comment: The plan proposes three ways of meeting contingency measure 

requirements. Of the three, only the current program using secured incentive 

funding clearly qualities as a contingency measure. Requesting ARB to 

accelerate implementation of state measures (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 success of bringing clean air to the Valley is 

contingent upon the failure to attain clean 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 feasible measures. No significant 

additional emission reductions have been identified that could be set aside and 

used only if needed for contingency. Because 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 million would generate approximately 8 tpd of NOx, at $25 

million/ton per day. 

The District is not waiting to request timely adoption and implementation 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”) unfairly characterizes this contingency 

measure. The District intends to attain both standards in a timely 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 therefore meet EPA’s criteria for contingency 

measures as given in 72 FR 20643. 

12. Comment: Even with the District proposed contingency measures, the possible 

3.5 tpd of NOx reductions feasible fall short of the required 31.5 tpd. The District 

should consider the following as contingency measures: 
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Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-7 

• Ban the use of pre-tier 3 off-road engines during high pollution days, as 

similarly proposed by the South Coast. In addition, the District should ban 

the use of pre-tier 3 agricultural engines, such as tractors and harvesters 

during high pollution days. 

• Require technologically feasible BACT-level technology on all existing 

stationary sources and allow alternative compliance, such as retrofitting 

mobile sources, which effects equivalent reductions. 

• Furthermore, the District should accelerate the adoption and 

implementation of rules to the extent feasible, as proposed for state 

mobile sources. (ISSRC)

• Operational controls, including limiting 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 embodied 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 increase 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 cumulative reduction would be 18 tpd. 

Requiring technologically-feasible BACT on all existing stationary sources is the 

District’s primary strategy for reducing emissions under its jurisdiction. 

Prohibiting the use of relatively new Tier 1 and Tier 2 engines – which were 

purchased using public funds - on a sporadic, non-predictable basis could be 

disruptive and financially disastrous for smaller businesses. EPA notes that 

unreasonable measures, which are absurd, unenforceable, impractical, or that 

would cause severely disruptive socioeconomic impacts (e.g., gas rationing and 

mandatory source shutdowns), are 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 requires 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 truck rule (the end of 2009). (ISSRC)

Response: The District will be continuously evaluating the situation regarding 

PM2.5. Rather than committing to an early 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. 
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Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-8 

Control Measures 

14. Comment: The Plan’s analysis of control measures that could be deemed 

Reasonably Available Control Technology (RACT) for stationary sources and 

Reasonably Available Control Measures (RACM) for all sources, including area 

sources and stationary sources, is inadequate. Potential measures that are 

reasonably available considering technical and economic feasibility must be 

adopted as RACM if, considered collectively, 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 exemptions for on-field agricultural operations in the 

Fugitive Dust Rules (Regulation VIII) would show that attainment could be 

advance by one year, without serious disruptions of agricultural activities. 

(ISSRC) 

Response: The discussion of RACM in Section 6.2 of the Plan meets federal 

requirements. Appendix I of the Plan identifies 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 attainment by one year. Furthermore, the 

commenter is assuming that reducing agricultural fugitive dust emissions will 

automatically and assuredly improve 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 District understands that the 

highest concentrations of PM2.5 occur during the wintertime in urban areas, 

when and where agricultural fugitive dust concentrations are relatively low. As 

shown in Chapter 6, both agricultural and non-agricultural fugitive dust emissions 

are scheduled for review via feasibility studies to better determine their 

contribution to the PM2.5 emission inventory 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 emissions 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 throughout the development 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. 
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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 stated 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; Construction, Demolition, Excavation & 

Other Earthmoving Activities; Open Areas; Paved & Unpaved Roads; Agricultural 

Sources; and Prescribed Burning & Hazard Reduction Burning. A 10% 

reduction of 2012 emissions from these categories 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 categories without supporting discussion. As 

stated frequently throughout the development 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 these 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 PM2.5 as NOx or SO2

reductions. 

18. Comment: When the more stringent NOx, PM2.5, and VOC reductions 

[Comments 18-20] are evaluated for NOx 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 above 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 measure improvements are possible. 

Response: Please refer to responses previously provided by the District. 
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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 should be further explored. (CCA)

Response: Open burning exceptions are already 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 commitment 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 measures for measures that reduce 

VOC emissions from coatings, solvents, 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 relies almost exclusively on the 

upcoming, not-yet adopted Air Resources Board (ARB) Heavy Duty Diesel Truck 

Rule. While we acknowledge the significance of this rule to help reduce PM2.5 

levels in the Valley, we are concerned that most of the emission reductions from 

this rule will not be actualized in the 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 must be achieved once the statewide 

strategy is approved by EPA. 

Modeling and Technical Issues 

Summary of comments received from Evan Shipp 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-11 

Comments were provided on the PM2.5 SIP regarding meteorological assessments, 

modeling and air quality data to be used for the PM2.5 SIP. In addition to general 

remarks, 27 page identifications were provided where the issues discussed in his 

general remarks were mentioned. Seventeen 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 are 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 worst case and the form of the standard 

is to minimize the influence of meteorological variation on the design of the plan. 

That is why the design value is averaged across three years, to minimize 

exaggeration of control requirements that might be implied by a single year’s 

unusual meteorology or atypical events. The basis of the plan, as recommended 

by EPA guidance, confirmed by consultation with EPA and using EPA 

terminology, is the 2005 design value, representing the averages 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. Modeling 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 (Relative Reduction Factor – 

RRF) being applied to the three year base design value. Note carefully that the 

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

but rather the 98th percentile value averaged across three 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 site. Where data collection has missing 

samples, EPA has established the procedures, which the District has followed, 

that are to be used to provide correction for missing data (see detailed 

explanation in Appendix A.3.2). 

26. There should be more meteorological evaluation. The District indicated that it 

reviewed 100 years of meteorological 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 comments, the trend charts need to reflect 

fluctuations in meteorology by using 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, 
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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 evaluations that provided the most 

probative value as items to be included with the plan. The District has not 

received other requests for the 100-year meteorological analysis but will consider 

issuing the information as a separate document in the near future to be available 

on public request. The District completed this analysis, speciation data analysis, 

persistence evaluation and a variety of technical 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 for 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 through A-24 follow standard methods. 

The suggestion for meteorological indexing of trend data is innovative and has 

been attempted in a few journal publications but generally requires a larger set of 

data for acceptable determination of uncertainty. 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 the 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 humidity 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 implies 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 the 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 (determined by the daily variation of the 

meteorology parameter of the difference between 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 to 
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Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-13 

eleven days reached similar values (slightly less than 60 micrograms per cubic 

meter) with one twelve-day event reaching 71 micrograms per cubic meter. 

The increase in humidity during a subsidence 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 change 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 should 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 time 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 submitted as the basis for the plan. 

At this point it can only be used as a sensitivity evaluation, which has been done 

and is discussed in the plan in Section 3.4.2 “Weight of Evidence” in the 

paragraph on Air Monitoring Data and Trends. The procedure recommended in 

the comment is not in accordance with EPA Guidance. The use of uncertified 

data and commingling data sets from two different types of monitors is not 

appropriate and does not comply with established guidance for the processing of 

air monitoring data. Differences between real time monitors used to advise daily 

forecasting and federal reference method samplers used to assess compliance 

with the health standard must be carefully considered. Real time monitors have 

a higher capture rate for water, VOC artifact that the FRM would consider as 

gaseous material, and collection of semivolatiles of nitrate, sulfate and organic 

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

has been used to establish the health standard limits. 

29. Comment: Because the 2004-2006 period had missing data, these design 

values are non-representative. Quarter 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 high 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, see Section 3.4.2 “Weight of Evidence” in 

the paragraph on Air Monitoring Data and Trends. The Design Values and the 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-14 

calculation of reductions needed to achieve the PM2.5 annual standard follow 

EPA methodology. 

30. Comment: The plan references PM10 attainment (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 predict natural events, which are 

by EPA definition excluded from consideration in determining attainment. Natural 

events are not an appropriate basis for determining the amount of anthropogenic 

controls that should be imposed. The requirement for natural events is to 

establish and impose BACT for sources that are commonly affected by natural 

events. Imposing BACT is intended to minimize 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 from causing an exceedance of the 24-hour 

standard, only to have a reasonable level 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 involved that produces high annual averages. 

More documentation is needed on what drives the annual average (highest days, 

moderate episodes, etc). (Shipp) 

Response: The figures referenced are not species trends. They are reaction 

rate evaluations examining the strength of correlation between observed NOx 

throughout the Valley and local PM2.5 nitrate concentrations. This provides an 

evaluation of the formation dynamics of ammonium nitrate 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, figure H-23 and H-24 examine the atmospheric 

presence of nitric acid and ammonia showing that ammonia is ubiquitous in the 

Valley and nitric acid, formed from the reaction 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 District does not have enough 

data to determine compliance. On page H-27, it states that 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 designation. Page 3-22, Section 3.4 says that 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-15 

some sites already comply with the NAAQS, but this should not be stated without 

rigorous analysis and EPA approvals. (Shipp)

Response: Section 3.3.3 identifies that the fact that the FRM monitoring 

network has been in place for only a few years makes it improper to use certain 

statistical methods as corroboration for a finding that attainment will be achieved 

in the weight of evidence determination required for sites where the predicted 

future design value is close to the standard. It only requires three years or more 

of data to establish District compliance or exceedance of the standard. There is 

sufficient data to establish that the District does not currently comply with the 

annual PM2.5 standard. Compliance with the standard is the correct terminology 

when one or more sites is within specified standard limits and the use of this 

terminology does not require an EPA designation. 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 District does not automatically 

receive an attainment designation from EPA when monitoring data shows 

compliance with the standards. An official request for redesignation must be 

submitted and must comply with a wide variety of requirements 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 attainment year, to show steady progress toward 

attainment. (Shipp) 

Response: This task was completed by receptor modeling analysis after 

determining strong agreement between receptor and regional modeling results, 

see section 3.4 Table 3-2 where the intervening 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 both parts of the PM2.5 standard and EPA 

redesignation is granted) 

34. Comment: The plan does not include a full photochemical 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 should be noted that EPA modeling guidance 

(Section 18.5.3) also recognizes the method of using multi-variate source 

apportionment models (CMB and PMF) to evaluate the uncertainty of the 

regional model. This process was completed by the District and is included in 
San Joaquin Valley Unified Air Pollution 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 correlation of the modeling methods is extremely 

good with results that are nearly identical as shown in Table 3-5. 

35. Comment: The Plan provides poor documentation 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 plan occur at the attainment year, so the 

modeling system using the base and end year inventories is not sufficient. If the 

documentation files are too big to download 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 procedures follow EPA guidance with use of 

the base and end year required as the methodology for SMAT. However, 

additional modeling was conducted for intermediate 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 the 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 modeling files for the year 2014 are posted and the 

receptor files for other years are available 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 the 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 the District will perform the SMAT analyses, but 

ARB performed these analyses. More documentation 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 documentation of the SMAT 

procedure is included in the Appendix F SJV PM2.5 Modeling Protocol and 

Appendix G Regional Air Quality 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 technical calculations into tables provided 

in Chapter 3 and Appendix G. 
San Joaquin Valley Unified Air Pollution 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 calculations that are flawed. PMF and CMB 

corroborate, but more corroboration is needed, perhaps 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 calculations 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 using 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. Regional modeling is 

prognostic – replicating the accumulation of particulate from emissions inventory 

inputs and photochemical, chemical and equilibrium equations. The observed 

data is an input for receptor techniques but is not an input for the regional 

approach where the observed PM2.5 concentration data is only used for 

performance evaluation. The two modeling approaches do not rely on the same 

techniques or inputs and these differences make them independent from each 

other. Additional corroboration 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 provisions of the EPA modeling guidelines. 

(Shipp) 

Response: A variety of analyses have been considered by ARB and the District 

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). The weight of evidence guidance provided by EPA is not intended to 

require that every possible approach be used; 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 analyses meet this requirement.

40. Comment: Without a meteorological evaluation, 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-representative. Method 2 

projections may be misleading. (Shipp) 
San Joaquin Valley Unified Air Pollution 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 every analysis and modeling approach has 

uncertainties and limitations. Individual assessments within a weight 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 assurance that the overall findings are 

reasonable, despite the uncertainties and data 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 SO2 needs to be performed. It is the District’s 

and/or ARB’s responsibility to condense this information into an easily 

understandable format showing the output of the photochemical model before 

and after control for each chemical species 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 inventory or just the 50% cuts as has been 

used in the past. In addition, the District 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 intermediate years. In addition, a run 

containing the attainment inventory 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 for PM2.5 requires modeling more days 

and determining relative response from a base modeling year to the projected 

attainment year for each specified component of the particulate concentration. 

The results of the regional modeling provide results for each day of the fourteenmonth period with each day having a specific 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 modeling process of 

revising emissions until a specific attainment run is generated, rather the relative 

response of the model is used to determine 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 incorporates at least an entire year and 

establishes variation in response by component on a quarterly or monthly basis. 

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

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-19 

basis for each required component. Regional modeling allows use of equilibrium 

equations to reflect aerosol chemistry in a more dynamic manner. The CMB 

receptor modeling incorporated twelve monthly evaluations for two different sets 

of years with a component breakdown that is more extensive than required by 

guidance. Receptor methods allow analysis 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 authorized or commissioned to establish additional 

health based standards. The most that the District is able to do is support health 

studies in our area that might identify additional health concerns. The District is 

proactive in this regard by supporting and facilitating health based research in the 

SJV. Furthermore, although the SJV experiences protracted stagnation events 

that last from a few days to two weeks, the particulate levels are not extreme for 

the entire duration of these events. 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 for NOx limitation. There is still a 

question as to whether moderate days that affect the annual average are NOx 

limited. Document whether the NOx limitation on PM2.5 is verified by the 

photochemical model for all days. (Shipp) 

Response: This comment is based on an incorrect premise that all days must 

have similar NOx response and that the strategy must have the same effect each 

and every day. This is not a requirement or a reasonable expectation. The 

District has included reduction programs for days dominated by other source 

contributions including carbon, geologic material and sulfate particulate. The 

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

ammonia. These issues have been thoroughly 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 investigated 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 should be presumed as not dominant and 

should not be the focus of the plan unless technical evaluation shows domination 

by these processes. All of the technical evaluations for CRPAQS and prior 

assessments of regional particulate models have indicated that NOx is the 

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

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-20 

J.2 RE-EVALUATION OF COMMENTS AND RESEARCH SUBMITTED BY THE 

CALIFORNIA COTTON GINNERS AND GROWERS ASSOCIATIONS, JANUARY 7, 

2008 

The California Cotton Ginners and Growers Association (CCGGA) letter dated January 

8, 2007, and technical documents accompanying the letter, have been reviewed by 

District staff. 

1. Comment: CCGGA requests removal of all fugitive dust candidate control 

measure proposals and feasibility studies from the PM2.5 Plan. This request 

is based on various recent studies that show fugitive dust is a major 

component of PM10 annually and in autumn, but PM2.5 is only a small 

fraction of that PM10 (five to ten percent). This is supported by a recent study 

on the fig and almond PM10/PM2.5 harvest emissions that 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 (ammonium + 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 presentation from the ARB project manager 

for CRPAQS, Karen Magliano, that identified geologic emissions from the 

combination of urban and rural sources as a contribution of approximately 

one microgram to the PM2.5 annual average. Furthermore, the FRM 

(Federal Reference Method) PM2.5 sampler was designed for accuracy of 

particles generally found in urban environments, which generally have two to 

four times smaller mass median diameters (MMD) than do agricultural 

processing emissions. This sampler design adversely affects the FRM 

sampling which then produces a higher than actual PM2.5 for agricultural 

processing facilities. This is further supported 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 overestimating 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 may be dismissed from consideration 

without further study. The impact on attainment must be assessed for all 

contributing sources. The PM-10 annual standard of 50 micrograms per 

cubic meter was given a de minimus limit of one microgram as a guiding 

standard for sources large enough to require 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 must be assessed for its contributing 

sources and potential for identifiable reductions. Feasibility studies will assist 

the District in determining the actual contribution of PM2.5 from urban and 

rural sources, identify if rural contributions contribute measurably to the peak 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-21 

levels, improve the accuracy of emission factors for PM2.5 emissions from 

agricultural activities, determine which PM10 control measures provide PM2.5 

emission reductions and establish whether PM2.5 reductions 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 emissions for a variety of 

agricultural practices. Improvement of the emissions inventory requires 

feasibility studies to determine the actual magnitude of PM2.5 contributions 

from agricultural activities and to determine 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 variation in reported results for different 

activities, PM2.5 emission factors applicable to agricultural 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, experts and approving agencies, the District 

will employ a scientific quality assurance program for data collected as part of 

the feasibility studies, including assessment and documentation of sampler 

bias. 

J.3 VERBAL COMMENTS, FEBRUARY 25-26, 2008 PUBLIC WORKSHOPS ON THE 

2ND DRAFT 2008 PM2.5 PLAN 

J.3.1 February 25, 2:00pm Workshop 

Approximately 34 people in attendance (18 Fresno, 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 will 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 similar 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 Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-22 

Response: Population growth estimates (as 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 cold 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 regulation 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 final rule on RFP stipulates “generally 

linear progress.” The 2009 and 2012 projected emissions presented in Chapter 

8 of the Proposed 2008 PM2.5 Plan meet RFP requirements. 

6. Comment: The plan does not satisfy the contingency 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 contingency measures in conjunction with 

determinations of RACM. EPA also emphasizes 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 identifying control measures for PM2.5 and its 

precursors; as shown in Chapter 9, these measures are needed to demonstrate 

attainment in 2014. Remaining measures (those with reductions not used in 

demonstrating RFP or attainment) were used for contingency, in accordance with 

EPA’s Final Rule implementing 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 because attainment is 

based on three-year averages.

Response: The District expects that the Valley will attain by 2014, with no 

extension required. The modeling projects attainment based on design values, 

which are three-year averages, as specified in Federal modeling guidance. 

8. Comment: The plan should include evaluation of 2007 data and real-time data. 

Also, the plan reports that District staff evaluated 100 years of meteorological 

data; where is this documented? 
San Joaquin Valley Unified Air Pollution 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 dust 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 delaying 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 control measures for directly 

emitted PM2.5 and SO2 should be feasibility studies. Control measures for 

directly emitted PM2.5 are very costly.

Response: In accordance with federal regulations (40 CFR 51.1002), this 2008 

PM2.5 Plan identifies and evaluates sources of PM2.5 direct, SO2, and NOx for 

potential control measures. The modeling conducted for this plan shows that the 

District’s projected PM2.5 and SO2 reductions are important contributors to 2014 

attainment; without these reductions, many more NOx reductions would be 

needed. The rule development process will allow for further evaluation of costeffectiveness of controls of direct PM2.5, SO2, and NOx. 

13. Comment: When will the 2006 PM2.5 standard 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 contains a commitment to re-open 

the residential wood combustion rule to consider a number of changes, including 

establishing the threshold for wood burning prohibitions for when the PM2.5 air 

quality is predicted to be at or above the 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 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 2012 or 2013, and the final attainment year for the 2006 standard 
San Joaquin Valley Unified Air Pollution 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, worst PM2.5 levels are expected to be 

more than 50% closer to the 2006 standard (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 industry to investigate alternatives to 

open burning. 

15. Comment: Additional incentive money is needed.

Response: District continues work to identify more sources of incentive funding. 

The District aggressively pursued allocation 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 research findings from the CRPAQS project. 

Much of this has been documented in the 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 would 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 consequence to the annual PM2.5 standard, 

we must concentrate on the winter period of high concentrations of ammonium 

nitrate, which has already been well established by research and modeling as 

NOx limited. 

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, ammonium nitrate, carbon) and use of the model results for 

each of these separate 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 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 nitrate 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-25 

that have been scientifically analyzed by research project evaluation and several 

modeling analyses as being NOx limited. 

17. Comment: The plan uses straight relative response 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, ammonium nitrate, carbon) and use of the 

model results for each of these separate 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 Appendix 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 modification in the modeling protocol. The 

District has not identified any alternative calculation procedures for the 

attainment demonstration that merit amendment of the protocol. The District did 

identify in the modeling protocol, in part from EPA sources, elements of the 

approved methodology that are not ideal for California or the San Joaquin Valley; 

however, that does not provide an alternative 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 receptor modeling and weight 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; SO2, PM2.5, 

and NOx should have separate rules. The control measures should focus on 

NOx and designate SO2 and PM2.5 measures as feasibility studies. 

Response: See response to comment number 12. The modeling conducted for 

this plan shows that the District’s projected PM2.5 and SO2 reductions are 

important contributors to 2014 attainment; without these reductions, many more 

NOx reductions would be needed. The District 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 rulemaking 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 Pollution 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 presented in the plan (calculated for the 

federal standard) can provide an estimate of progress towards the state 

standard, it should be noted that the State 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 indicated 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 contingency 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 Fresno, 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, 2nd paragraph. 

Response: The District has conducted a thorough review of said guidance. The 

District expects that the Valley 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 lead the District to expect that 

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

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-27 

25. Comment: How will the current plan impact 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 from reductions in NOx emissions. 

ISR is expected to achieve about 4.2 tpd of NOx reductions 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 burning 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, based on 2006 PM2.5 concentrations). 

29. Comment: The District should do more to coordinate 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 identical to smoke from other types of 

vegetative burning. In the emissions inventory, 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 incorporated into the District’s CEQA projects, 

and the District may help collect emissions inventory data for AB32. 
San Joaquin Valley Unified Air Pollution 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 Growers 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, Madera Coalition for Community Justice, 

Merced-Mariposa Asthma Coalition, and the Center on Race, Poverty, and the 

Environment 

Chevron U.S.A. Inc. (CUSA) 

International Sustainable Systems Research Center (ISSRC) 

Nisei Farmers League (Nisei) 

Western States Petroleum 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 opportunity to participate. (CVAQC)

Response: Comment noted. 

2. Comment: The time period for review for the 2nd Draft was too short (20 days). 

(CVAQC)

Response: The comment period on the first draft was 36 days, and there will be 

a 30-day public comment period on the Proposed Plan beginning on March 13, 

2008. 

Control Measures 

3. Comment: The District’s proposal to incorporate PM10 and SO2 control 

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

that PM10 and SO2 reductions are not needed to attain the 1997 PM2.5 Ambient 

Air Quality Standard (AAQS). The proposed PM10 & SO2 control measures do 

not conform to federal guidelines which states that measures that are not 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-29 

necessary to satisfy Reasonable Further Progress (RFP) or expeditious 

attainment are also not required RACT/RACM for the area, and any measures 

that collectively, would not advance attainment by at least one year are not 

required for PM2.5 RACT/RACM. Therefore, PM10 and SO2 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 SO2 controls are required to attain federal AAQS by 

2014. This finding was reflected in the ARB modeling, which was recently 

received; federal regulations (40 CFR 51.1002) require their inclusion in the Plan. 

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

reflect that because the annual PM2.5 concentration 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 always included the reductions of directly 

emitted PM2.5 and other precursors including SOx. The text of the plan has 

been improved to reflect this comprehensive 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 additional 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; application includes powering 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 reductions. Unlike the more urbanized Los 

Angeles area, the San Joaquin Valley does not have the electrical distribution 

infrastructure needed to support a rapid switch to electric motors. The current 

rule incorporates feasible controls for this category, based on technological and 

economic considerations. The Plan does commit the District to revisit this rule 

and incorporate new technology that is available or planned at that time. The 

commenter is encouraged to participate in the rulemaking process. 

5. Comment: The District can achieve an additional 2 tpd of NOx reductions from 

Glass Furnaces. The proposed rule for industrial glass manufacturers should be 

adopted. (CVAQC) 

Response: District staff is currently developing a rule with potential reductions 

of 3.4 tons of NOx/day from glass-melting furnaces. District staff would be 

interested to learn what additional control technologies are available to obtain the 

suggested reductions. More information pertaining to this comment is needed. 
San Joaquin Valley Unified Air Pollution 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 additional 9 tpd of NOx reductions from 

Boilers & Dryers (gas & liquid-fired boilers, solid-fuel boilers: dryers 5MMBTU/HR 

and below as area/point sources). (CVAQC) 

Response: District staff is currently developing a boiler rule with potential 

reductions of 5.3 tons of NOx/day. District staff would be interested to learn 

what additional control technologies are 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 use 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, refrigerant, and disinfectant. 

State and federal requirements 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 ubiquitous 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 range of compliance options so that 

facilities can use the most cost efficient and timely way to reduce emissions. The 

District should consider providing advanced early emissions reductions options, 

incentives, and thorough socioeconomic analysis. 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 recently released draft of Rule 4320 

contains Advanced Emission Reduction Options (AERO) to provide affected 

sources with control options while still obtaining 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 filters on natural gas fired stationary 
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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 equipment. 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 primarily 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 warrant 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, which 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 representatives 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 sufficient amount of time to complete this 

task. (Nisei) 

Response: The District intends to move forward on feasibility studies as 

expeditiously as possible. These studies 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 eighteen months; however, until the feasibility study is 

developed it is difficult to be certain of its duration. The nature of a feasibility 

study may not be as extensive as is anticipated. The feasibility study may draw 

on work already completed or in progress to assess the emissions potential for 
San Joaquin Valley Unified Air Pollution 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 small to merit attention, such information 

may be used to conclude the feasibility assessment. If, however, preliminary 

information indicates that the PM2.5 fraction of PM10 from these sources is a 

percentage that merits attention for development of potential reductions and it is 

found that some of the CMPs have a potential to reduce these emissions, a more 

thorough evaluation may be required to complete the feasibility assessment, new 

field measurement programs may be required and the project may take longer 

than the current estimate. The District will coordinate any additionally required 

field research through the AgTech Committee, which has been established for 

the purpose of involving stakeholders and qualified scientists in development and 

review of agricultural air quality research to ensure accuracy and usefulness of 

the products and findings of the research.

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

PM2.5 emission reductions. Tree and vine 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 affect the quality of dry fruit and vegetables. 

(Nisei) 

Response: The last rule development project did address this issue and it will 

be considered in any future amendments.

15. Comment: Please review Federal and State labor and transportation regulations 

in relation to the proposed “Employer Based Trip Reduction” rule. There are 

major conflicts with these rules within 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 between 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 regulations should be 

acknowledged. Examples include: the pump engine rule, CMPs, open burning 

rule, emergency generator permits, surface water regulations, and many others. 

(CGTFL) 

Response: Comment noted. 
San Joaquin Valley Unified Air Pollution 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 that would require more no burn 

days for residential wood combustion. Other measures should be implemented 

instead. (Murray, Gary) 

Response: Staff will consider all feasible options during the rule development 

process for that control measure. District staff would be interested in any 

alternatives that could be implemented in addition to those already listed in the 

plan. 

Reasonable Further Progress 

18. Comment: The PM2.5 Plan does not demonstrate 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 presented in Chapter 8 of the Proposed 

2008 PM2.5 Plan meet RFP requirements. 

19. Comment: ARB should project emissions reductions 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 development. Their only commitment from all new state 

measures is for 2014, regardless of whether or not reductions 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 NOx, 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 reductions 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 the end of the RFP 

year in which the shortfall occurred, “without significant further action by the state 

or EPA.” (40 CFR 51.1012). See discussion in Chapter 8. 
San Joaquin Valley Unified Air Pollution 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 measures (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 major 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 reductions from the truck rule now under 

development. It applies to any state measure under development and/or 

implementation, with the goal of accelerating reductions from the measures. 

22. Comment: One of the District’s contingency measures 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 this 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 implementing the PM2.5 NAAQS (72 FR 20586). In this 

rulemaking, EPA emphasizes that states should make decisions on contingency 

measures in conjunction with their development 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 measures not needed for RFP or attainment 

demonstration as contingency measures. One of these measures is the 

emission reductions that would result 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 collection of such fees if a severe or 

extreme area fails to attain the former standard. 

The commenter is incorrect in estimating the amount of funds that could be 

generated. The figure cited by the commenter is based on outdated (though 

correct at the time) fee costs; 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 inflation. Also, the District now regulates 
San Joaquin Valley Unified Air Pollution 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 estimated 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, District staff is optimistic that emission 

reduction projects could be put in place in time to correct any RFP shortfall from 

the 2012 milestone, should 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 unreasonable control measures, ‘such as 

measures that are “absurd, unenforceable, or impractical” or that would cause 

“severely disruptive socioeconomic impacts (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 District 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 outlined in Chapter 6 achieves emission 

reductions as expeditiously as practicable. 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 control 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 for 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-36 

certain model years). Without proper prorating of ARB emissions reductions, full 

consideration is not given to potential sources of emissions reductions that may 

actually advance attainment by one year. (ISSRC) 

Response: ARB has made no formal commitment for pre-2014 reductions from 

the truck rule now under development. Their only commitment from all state 

measures is for 2014, regardless of whether or not reductions 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 progress 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 recalculated 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 conditions are conducive to PM2.5 formation. In years 

where meteorology produced high concentrations of PM2.5, filter-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 weight of evidence provisions. Correlation to parallel 

real-time monitors is good, and this data 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 standard for 2004-2006, so additional control 

commitments should be made to reduce these 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 procedures for adjusting the data for 

differences between the sampler characteristics (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 speciation data and cannot be adjusted in 

this manner. Part of the difference between BAM and FRM data is a higher 
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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 high 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 drive off trapped water, but currently this 

involves heating the air stream, which may also reduce capture of ammonium 

nitrate. The District uses data from these 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 recalculated 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 District will be granted attainment status. 

(Shipp) The District’s claim that 2007 data was analyzed and showed 

attainment needs to be documented in detail in the main volume of the plan with 

2005-2007 design values and RRF. (Shipp addendum) 

Response: The District cannot be granted attainment status for the daily 

standard for several reasons. Most importantly, both the annual and daily 

standard must be met to receive a redesignation to attainment. Separate 

findings for attainment are not given unless both standards are met. This is true 

for both PM10 and PM2.5. The annual standard is more difficult for the SJV to 

meet than the daily standard and will determine when the District will qualify to 

request attainment status. From modeling contained in the plan, this is not 

expected to occur before 2014 unless additional early reductions are achieved. 

In addition, the current daily standard 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 the regional modeling, as documented in Appendix G 

and H, projects a maximum 2014 future annual design value of 14.68 

(Bakersfield –Golden State) while projecting a future daily 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 requirement 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 standard, confirming the regional modeling 

evaluation. Additional text has been provided to reflect these findings in the 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-38 

District Weight of Evidence determination (Chapter 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 response was adequate and it is repeated 

below: 

The District performed an examination of meteorological trends in the San 

Joaquin Valley. Statistics for 100 year and 20 year meteorological databases 

were reviewed. Statistical analysis was performed to determine the relationship 

between meteorological indicators and PM2.5 concentrations. The results of 

these analyses indicate that the relation between examined meteorological 

indicators and PM2.5 is poorly correlated and not statistically significant. It would 

be inappropriate to adjust particulate data 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 have a statistically adequate number of 

samples for a long term trend comparison 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/airtrends/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 for the period 2004-

2006. This resolves the issue that 2004-2006 had 'better' meteorology than past 

years. The District welcomes analyses 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 the 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-39 

residential wood combustion rule to consider a number of changes, including 

establishing the threshold for wood burning prohibitions at the 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 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 2012 or 2013, and the final 

attainment year for the 2006 standard will be 2019 or 2020. The 2008 PM2.5 

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

Modeling and Emissions Inventory 

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

did not include measured PM2.5 data from farming operations. The document 

“Interim Report: Sources and Sinks of PM10 in the San Joaquin Valley” was 

included and contained specific PM2.5 data for cotton picking, cotton stalk 

cutting, almond pickup and sweeping, and fig 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 included two studies that showed specific “measured PM2.5 

levels” from cotton gins and the District 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 sources from consideration prior 

to conducting a thorough technical review. The District will consult with 

stakeholders through the Ag Tech committee to address these issues.

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

contributor to the formation of PM2.5. Also, PM2.5 levels 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 Valley 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 agricultural sources is larger in 

size than PM2.5. This contradicts 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 most significant contributors to PM2.5.

32. Comment: The plan needs to provide a full photochemical model evaluation. 

(Shipp, ISSRC) This evaluation has full bearing on the uncertainty of the 
San Joaquin Valley Unified Air Pollution 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, ammonium nitrate, carbon) and use of the 

model results for each of these separate 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 Appendix G that presents the 

regional model methodology and results. The uncertainty estimation for the 

model can be directly evaluated by performance analysis (in progress by ARB) 

and by comparing the results to other analytical approaches including the 

receptor modeling and weight 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. The regional model projections and receptor analyses 

are in close agreement and are supported by other weight of evidence analysis. 

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

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

seems that the NOx limitation statements 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 major 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 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 would 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 established 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 should be analyzed as an alternative to the rollback 

method. Since the protocol and EPA guidelines recommend the use of straight 

photochemical derived RRFs, the District should at least show these calculations 

as an alternative. (Shipp) Calculations using RRF obtained directly from the 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-41 

photochemical model need to be shown. Both 2005-2007 and 2004-2006 

attainment should be demonstrated for speciated rollback and direct 

photochemical model RRFs. (Shipp addendum) 

Response: EPA methods were used for the regional 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 the 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 complete 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 prone to PM2.5 pollution, such as the Bakersfield area. 

Studies in PM2.5 formation 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 projects included a number of special 

studies conducted in more limited geographic areas to answer specific technical 

questions. The findings of these special studies were used to develop our 

regional measurement program. Special studies were used to determine how 

much particulate forms from VOC emissions. These documents are available 

from the ARB Airways website of CRPAQS published results. 

36. Comment: By just modeling attainment for 2014, the District is not addressing 

the need to show attainment as a three-year average. It appears that the District 

is expecting to request a 1-year extension (although RFP has to have been met 

for said extension to be granted). How can the Valley attain by 2015 if many 

reductions will not be implemented until 2014? (CVAQC, ISSRC) 

Response: The District and ARB followed EPA guidance, which identifies how 

to model the design value three-year periods. 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) the 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 projected is the “single year/season immediately 

preceding the attainment date” (page 35, emphasis as contained in the 

guidance document). The model projections are used with methods that project 

a three-year design value average for the required years.
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-42 

J.5 VERBAL COMMENTS, DECEMBER 18-19, 2007 PUBLIC WORKSHOPS ON THE 

DRAFT 2008 PM2.5 PLAN 

J.5.1 December 18, 2007, 6:30pm Workshop 

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

1. Comment: Will ARB’s regional modeling 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 separate Community Plan that goes beyond the SIP. 

Response: This is not an “either-or” situation where we choose which PM2.5 

standard to address. The District is targeting 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 interesting, 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 working on several efforts to accelerate 

attainment that are not strictly SIP creditable, including 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 state standards should be addressed. 

Response: The proposed control measures will provide significant progress 

toward meeting California standards. California has no specific dates by which 

state air quality standards must be attained. California Health and Safety Code 

(CH&SC) Section 39602 says, “Notwithstanding any other provision of this 

division, the state implementation plan shall only include those provisions 

necessary to meet the requirements of the [federal] Clean Air Act.” As such, 

state implementation plans (SIPs) are limited to those measures necessary to 

attain the federal standards. However, progress towards federal standards also 

brings areas closer to the lower, State standards. Furthermore, the District has 

fully complied with California planning requirements for state particulate matter 

standards, in accordance with Section 39614 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 Pollution 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 incomplete. 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 time for quality assurance and 

certification. Typically, data for a year becomes official by July 1st of the following 

year. However, the District is considering approaches for including 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 track-out), and amendments to Regulation 

VIII (Prohibitions for Fugitive Dust) are further study measures. Wineries and 

other sources of VOCs are considerations in the District’s 2007 Ozone Plan, but 

available evidence suggests that VOCs are not a major precursor to PM2.5. 

Ammonia reductions are not as effective as NOx reductions for reducing 

ammonium nitrate, since NOx is the limiting precursor in the Valley. Projected 

population increases from the California Dept. 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 quantifiable) and TBD (to be determined) 

entries in the control measure evaluations. More information is needed. 

Response: Some of the values cannot be determined at this time due to lack of 

reliable quantitative information on feasible control technologies for directlyemitted PM2.5. More detailed information will have to await the results of the 

Feasibility Study or Rule Development project. If the information can be 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-44 

determined prior to the plan's adoption, that information 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 control measures with quantifiable reductions. The 

feasibility studies are commitments to further examine the source category and 

determine if there are opportunities for future emission 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 Governing 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 for the availability of Spanish materials. 

Response: Comment noted. 

13. Comment: Is there a PM2.5 monitor in Merced? 

Response: There is an FRM (federal reference 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 after the sample was collected, since 

FRM filters must undergo laboratory analysis. FRM data is therefore not 

available on a real time basis to establish current air quality, so the District has 

deployed real time monitors to provide daily forecasting capability. These 

supplemental monitors are currently sited 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 County 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-time PM2.5 monitor in Merced in the near 

future. 
San Joaquin Valley Unified Air Pollution 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 provided by ARB includes reductions 

from regulations adopted through May 2005. The District subtracted reductions 

from rules adopted between May 2005 and December 2006 from these initial 

inventories and then made additional adjustments for methodology revisions to 

derive “Adjusted Inventories,” including Adjusted 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 people in mind as much as possible 

while meeting technical and legal planning requirements. District staff is 

available to provide further clarification and explanation. 

J.5.2 December 19, 2007, 2:00 pm workshop 

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

16. Comment: Karen Magliano of the California Air Resources Board (ARB) 

commented that she was encouraged by the attainment outlook of the receptor 

modeling and the amount of CRPAQS (California Regional Particulate Air Quality 

Study) research that was included. She 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; more reductions may be needed than the 

receptor modeling in the current 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 should 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 low, 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, according to the ARB emissions inventory. 

District staff will be looking to these estimates in the feasibility studies for CMPs 

and cotton gins.
San Joaquin Valley Unified Air Pollution 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 concentrations are not dominated by a 

single source or facility or even by a cluster 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 Valley). As with ozone, the particulate 

concentrations in the Valley are regional in nature, formed by contributions from 

a variety of sources. Annual average concentrations in the Valley are dominated 

by ammonium nitrate, which is formed secondarily rather than emitted directly. 

The limiting precursor for ammonium nitrate is NOx, which is emitted from motor 

vehicles as well as from industrial and commercial combustion processes. 

Regional mixing and delayed atmospheric formation of PM from these precursor 

emissions make it impossible to evaluate 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 plan as future/feasibility studies. 

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

evaluated under the California Environmental Quality Act (CEQA); potential 

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

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

attainment of the 2006 standard. 

Response: The District is targeting both standards. This plan will make major 

progress in attaining the new standard 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 Fresno 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-1st, 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 Fresno County monitoring sites are within one 
San Joaquin Valley Unified Air Pollution 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 possibility 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 single, 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 evidence documents the serious health 

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

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

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

information. 

27. Comment: Restrictions against wood burning should allow exemptions during 

power outages in foothill areas lower 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 provide 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-duty mobile sources be in the 

Appendix B emission inventory? 

Response: The District is using the most recently 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 important sources of NOx? 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-48 

Response: As shown in the NOx emissions inventory 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 Growers Associations (CCGGA) 

International Sustainable Systems 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 reflect 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 developing stricter regulations on 

facilities that use natural gas dryers, it must be shown that products will not be 

damaged during processing. Low NOx burner manufacturers have stated that 

the burners have not been tested on all products. New burners have also been 

reported to use more gas. (Nisei)

Response: Technical limitations of the various control technologies will be 

examined during the feasibility 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 Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-49 

3. Comment: S-AGR-2, Conservation Management Practices/CAFOs (Confined 

Animal Feeding Operations): Lowering CAFO thresholds is a concern, in light of 

research already conducted that 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 primarily 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 Practices: 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 the contribution of CMPs to PM2.5. 

The Agriculture Industry is interested in meeting with District staff on this topic. 

(Nisei)

Response: Currently, the CMPs rule targets PM10 reductions, and the District 

has not yet determined the associated PM2.5 reductions. A feasibility study will 

help show whether there is a quantifiable PM2.5 benefit and whether there are 

any CMP options that would 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 available data to determine the effectiveness and 

feasibility of conservation management practices in reducing PM2.5 emissions. 

Although PM2.5 might be a relatively small portion of fugitive dust, the Valley’s 

cumulative fugitive dust levels may still contribute to the 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 feasibility studies. There is already ample evidence 

indicating that fugitive dust is not a significant contributor to PM2.5: Karen 

Magliano’s (ARB) presentation at the District’s May 2006 Symposium, CRPAQS 

(California Regional Particulate Air Quality Study) reports, USDA studies, U.S. 

EPA documents, and numerous other studies. Extensive documentation was 

submitted to the District with this comment. This should be acknowledged by the 

District, and the Plan should be modified accordingly. (CCGGA) 

Response: The extensive documentation submitted with this comment did not 

provide data on measured PM2.5 levels from farming operations. Consequently, 

the District still believes that a feasibility study is warranted. The submitted 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-50 

documentation will form an excellent starting point for the study. Also see the 

response to Comment 4. 

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

to increase the number of required CMP for each applicable 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 are mutually exclusive or are redundantly 

controlling the same emissions. Please also refer to the response 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 currently feasible, such as 

chipping and composting, are thoroughly considered 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 Rule 4103 will effectively ban open 

burning by 2010 except where required for 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 NOx 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 control measure are currently in 

development. The limits and timetables suggested by the commenter will be 

considered during the rulemaking project. State law 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 require a NOx limit of 30 PPM for all 

units, with scheduled compliance by the year 2012 or electrification of units by 
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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 South 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 levels and implementation schedules. 

11. Comment: S-COM-4, Solid-Fuel Boilers, Steam Generators, and Process 

Heaters: Require baghouses and SCRs (as used in a biomass power plant in 

Ulm, Germany) on units burning biomass for fuel 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 facilities and may not be reasonable for add-on 

controls. Attempting to meet lower NOx 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 reexamining the potential controls for this category and will 

consider the latest available controls feasible 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 engines or electrical motors. Valley 

stakeholders have made great strides in moving to electrical motors, where 

possible, but the limitations of fixed electrical and natural gas supply lines do not 

allow this for all operations. The current rule reflects technologically and 

economically available control options, but staff is committed to reexamining this 

issue in the future to take advantage 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 Joaquin 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 proposed, as was discussed in the Plan, page 

I-31. 

14. Comment: S-COM-11, Dryers, Ovens, Dehumidifiers, and Other Process 

Equipment Used in Industrial Processes (excluding glass products production): 
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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 using fuel delivery reports (specifically, 

it is reported as Unspecified Agricultural 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 required to emit no more than 30 PPM 

at 3% O2---similar to the small boiler rule requirements. In the South Coast 

AQMD Ozone Plan, CMB-1 addresses these small units and will be required to 

use low-NOx burners. Units similar to those covered currently under District Rule 

4309 have been subject to requirements through RECLAIM and other facilities 

improvement programs, not through a prohibitory rule. Other permitted units not 

covered by RECLAIM programs have NOx emission 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. "Unspecified Agricultural Processing Losses" cannot be regulated 

without more information on what type of equipment is generating those 

emissions. This notation by the ARB is just 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 account 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 require a more vigorous evaluation of 

alternatives to burning. The current provision stating that those that have met 

NEPA and CEQA requirements are considered to have satisfied this requirement 

is inadequate, since it does not reflect up-to-date conditions and technological 

advancements for alternatives to burning. Although burning may not be 

avoidable for certain circumstances, it should not preclude using alternatives for 

certain portions of the biomass that can be handled by alternative methods, such 

as chipping and composting. (ISSRC)

Response: The Feasibility Study for this category 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 forecast to be unhealthy. It is also 

important to note that fire is a natural part of the wilderness ecology. 

 

16. Comment: S-IND-4, Fugitive PM10 Prohibitions: Consider subjecting on-field 

agricultural operations to prohibitory regulation, specifically requiring curtailment 

of activities during wind conditions conducive to entrainment of dust. Although 

the portion of PM2.5 in agricultural dust is only around 10%, the months of 

September, October, November, and early December show above average 

readings of PM in all size ranges and may contribute significantly to violations of 
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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 considered 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 interest 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: Similar to the South Coast AQMD’s 

proposed measure, identified in the 2007 AQMP as MCS-1, require facilities to 

modernize permitted equipments and processes, based on pre-specified 

equipment useful life, as determined during rule making. In addition, facilities 

would be required to use super-compliant VOC materials. The objective of such 

a measure is to upgrade existing equipment not subjected to NSR’s BACT 

requirements by retrofitting with BACT technology or to completely replace 

existing equipment with new equipment equipped with the latest BACT 

technology. Equipment and processes that are not beyond the pre-specified 

equipment useful life will remain subject to existing prohibitory rules. (ISSRC)

Response: District BARCT rules are essentially identical to South Coast’s 

“modernization program.” The District requires 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 and sale of kerosene lighter fluid at all 

times. Electric coil starters work perfectly well. (Menz)

Response: Reducing emissions from residential sources of pollution requires 

careful consideration of the public’s behavior 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 the problem, and to work steadily for a gradual change 

in the public’s behavior. A well-designed and considerate regulation, coming 

after a meaningful public debate, can result in significant and enduring public 

benefits. District Rule 4901 (Wood Burning 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 Pollution 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 travels to another property or public 

thoroughfare. (Menz)

Response: As required by state law, measures that are not necessary to meet 

the requirements of the federal 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 regulation at the city or county level. 

20. Comment: Residential Wood Burning: Fines for those who violate residential 

wood burning prohibitions should 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 bring the offender into compliance. 

21. Comment: Residential Wood Burning: The residential wood combustion 

prohibitions should be based on meteorological criteria that would cause an 

exceedance of the NAAQS if residential wood combustion were allowed. The 

prohibited declaration is the largest single 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 would accomplish. At the very least, 

prohibit burning when the PM2.5 concentrations are forecast to be at or above 35 

μg/m3. (Menz) Restricting all woodburning could 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 season (October – March), or about 14.8 

tons of reductions on any Valley-wide no-burn night. 

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

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-55 

23. Comment: The District and the Agricultural Industry must develop a truck trade 

down program to replace trucks built prior to 1996 to help meet the need of both 

agriculture (which cannot pass on increased 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 down 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.valleyair.org/lists/list.htm to ensure you 

receive notices regarding meetings and new program development. 

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

credit for the emissions reductions achieved by EQIP funded inventive programs, 

such as those focused on conservation tillage programs; oiling, graveling, and 

other dust suppressing agents on unpaved roads; reduction of agricultural 

burning through chipping; water management, dust suppression and manure 

management on livestock facilities; and engine 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 ensure SIP creditability for incentive-based 

emission reductions for incentive programs administered 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 creditability of emission reductions. The 

elements of this resolution were developed with the U.S. Environmental 

Protection Agency over the course of a year-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 District is currently 

implementing the items in the resolution and hopes to start seeking SIP credit for 

incentive-based reductions after 2009. Programs such as EQIP, which are 

operated and administered outside of the District, would need to meet the same 

operational criteria identified in the resolution referenced above, such that these 

programs then would be functional equivalents of the District’s SIP creditable 

incentive program. If this equivalency was established, then reductions from 

incentive programs outside of the District would also be SIP creditable. 

25. Comment: The District should take South Coast’s proactive approach to 

promote and accelerate the installation of mobile 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 outreach, education and facilitation, to leverage and amplify 

the effectiveness of ARB programs. "Off-the-shelf" diesel particulate filters for 
San Joaquin Valley Unified Air Pollution 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 reductions 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 incentives (and thereby accelerate the 

corresponding health benefits) in the Valley. (Weil)

Response: South Coast’s diesel emissions (such as those from ports) are more 

likely to be located near population centers. More analysis would be needed to 

determine the cancer risk from diesel exhaust in the Valley. 

The District has been proactive promoting and accelerating the installation of 

mobile source diesel particulate filters. The District paid over $2.2 million in 

incentives for mobile source diesel particulate 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 both 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 about the attainment of the 1997 PM2.5 

standards; the timing of implementation, especially in the event that the RFP 

demonstrations are not met; the duration of these contingency measures; and an 

analysis of who will be socioeconomically disadvantaged or affected by these 

contingency measures. Several reasonable contingency measures that should 

be addressed in the plan include: 

• Prohibit the operation of the highest 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 fireplaces 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 SOx by 2017 from all 

stationary sources. (ISSRC)

Response: The District recognizes the contingency measure requirement, as 

outlined in Chapter 9. The District is already proposing wood burning 

prohibitions at 35 μg/m3 and a mandatory alternative transportation program for 
San Joaquin Valley Unified Air Pollution 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 many days over the level of the standard 

yet still meet the standard when an entire year is averaged). Furthermore, lawn 

equipment and construction equipment tend 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 inventory (about 26% of the 2017 NOx inventory 

and 18% of the PM2.5 inventory). The Valley’s stationary sources are already 

heavily regulated and have achieved significant reductions. In cases where 

foreseeable technology can achieve additional stationary source reductions, the 

District is already proposing additional control measures. Requiring a 50% 

reduction for all stationary sources without identifying proven technologies or 

methods for achieving those reductions would 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 Reduction Rule. However, the rule would 

not be a contingency measure because emissions reductions would start taking 

place after rule implementation and would not need to wait until the Valley failed 

to meet an RFP or attainment milestone. 

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

contingency measures. 

Emissions Inventory – 

27. Comment: In mid-2007, new emissions data on heavy-duty vehicles has been 

released that significantly changes the inventory. This data should be 

incorporated into the attainment demonstration. (ISSRC)

Response: The California Air Resources Board (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 emissions from trucks statewide. Although ARB has 

“released” some of these emission estimates 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). Furthermore, ARB has not yet submitted these 

new, revised emissions to EPA for approval for use in State Implementation 

Plans (SIPs), nor has EPA approved these new, revised emission estimates for 

use in SIPs or for use in transportation conformity determinations. On January 

18, 2008, EPA approved the State of California’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 51.112(a)(1) require that SIP inventories 
San Joaquin Valley Unified Air Pollution 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 before 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 transportation planning agencies 

to effectively stop using the previous version of EMFAC (EMFAC2002) and to 

start using the newest version of EMFAC (EMFAC2007) for all conformity 

determinations started after August 1, 20071

 (73 FR 3465). And EPA has 

directed California transportation 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, preliminary data “released” by ARB in 

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

28. Comment: There are several source categories where the emissions inventory 

is documented to be unknown, or highly uncertain. These categories could have 

a significant impact on the attainment strategy. An update of the inventory for the 

following sources should be completed over the next several months. Upon the 

completion of the inventory updates, attainment analysis and strategy should be 

re-evaluated and the plan updated. The sources recommended to be updated 

are: 

• Small Spark-Ignited Engines and Agricultural 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 total number of small engines and to 

calculate their emissions, and a survey of agricultural operation 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 recommends that a Feasibility Study, to 

determine PM2.5 emission factors and appropriate PM2.5 controls, be 

completed by 2009. It is recommended that 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 latest planning assumptions for conformity determinations 

requiring a new regional emissions analysis and begun after August 1, 2007. Since the vehicle activity data are 

embedded in EMFAC, this was a de facto directive to use EMFAC 2007 after August 1, 2007. 
San Joaquin Valley Unified Air Pollution 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 this source, District staff 

indicates that current NOx emissions 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 investigation on the emissions generated 

during emergency flaring events be conducted in the next few months and 

updated in the inventory. 

• Farm Equipment (M-IND-1) 

The farm equipment category is a very large 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 tractor inventory. It is recommended that 

District staff over the next few months conduct a study to estimate these 

items, update the inventory, and conduct cost analysis for control options, 

including retrofit and replacement, and episodic controls. (ISSRC) 

Response: As discussed in Appendix B, emissions 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 additional 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 natural gas-fired industrial and commercial 

equipment were updated last year (EICs 050-040-0110-0000 and 060-995-0110-

0000). Area source estimates for agricultural 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 reviewing currently available data. 

(S-IND-21) The District appreciates 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 Board is in the process of updating the 

emissions inventory for this category, and expects to release a revised estimate 

by December 31, 2008. Although the District has no regulatory authority over 

these sources, we will continue to pursue opportunities for emissions reductions 

through our grants and incentives programs. 
San Joaquin Valley Unified Air Pollution 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 takes to get to attainment. (ISSRC, Shipp) 

Response: ARB is preparing the regional modeling evaluation in accordance 

with EPA guidance. The attainment demonstration is not meant to be solely 

based on the regional model, but on a weight of evidence of all supporting 

technical assessments and other types of modeling. The PM2.5 Modeling 

Protocol identifies the contributing evaluations. Two prior regional modeling 

evaluations conducted for the prior PM10 plans evaluated small particle 

formation of nitrates and sulfates and consistently identify NOx reduction as the 

essential pathway to particulate reduction in the Valley. Due to the conservative 

approach provided by receptor analysis linear methods, the regional model may 

provide a lower estimate of reductions needed to achieve attainment. However, 

the model should not be expected to alter the finding that nitrates 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 the Plan, Appendix E to the Plan, and a 

worksheet within the Receptor Modeling analysis (see Control Effectiveness). 

These findings represent the results of two 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 CRPAQS 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 determination of attainment. Results of 

ARB’s photochemical modeling are expected for the next 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 Pollution Control District April 30, 2008

Appendix J: Comments and Responses 

2008 PM2.5 Plan 

Appendix J-61 

32. Comment: The plan does not address meteorological representativeness. The 

years the plan is based on (2004-2006) have had better meteorology than past 

years. (ISSRC, Shipp)

Response: The District performed an examination 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 concentrations. The results of these 

analyses indicate that the relationship between examined meteorological 

indicators and PM2.5 is poorly correlated and not statistically significant. It would 

be inappropriate to adjust particulate data 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 have a statistically adequate number of 

samples for a long-term trend comparison 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/airtrends/weather/region09.pdf#page=4 

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

difference between actual data and trend-adjusted data for the period 2004-2006. 

This contradicts the comment that 2004-2006 had 'better' meteorology than past 

years. The District welcomes information developed by the commenter that 

addresses this issue. 

33. Comment: The more recent high PM2.5 concentrations 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 quality control review (performed annually) is complete. 

In addition, EPA specified the years of data expected to be used for this analysis 

and did not include 2007. Despite those 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 rescinded 1997 24-hour PM2.5 standard at two 

sites, and possibly at a third site that collects filter samples (for which preliminary 

values are not available). However, the District’s preliminary evaluation also 

indicates that even without control measures from the adopted 2007 Ozone Plan

or the draft PM2.5 Plan, the 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 Valley 
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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 meteorologically adjusted trends analyses 

to determine whether there is a statistical significance to the recent, lower PM2.5 

concentrations. The District should provide 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 the effect of controlling for the 

annual standard on the 24-Hour NAAQS. Although numerous exceedances of 

the 65 μg/m3 24-Hour PM 2.5 NAAQS have occurred 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 cause 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 required 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 appropriately addressed by the control strategy. As 

previously discussed, the annual standard requires more reductions to achieve 

compliance and sets the timeline for expected attainment. 

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

hour and annual standard needs to be addressed 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 analysis needs to be incorporated into the 

plan. There is enough data at the Fresno-1st 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 levels to variations in the contributing 

sources. Since only a few years of certified data are available (2002, 2003, 
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2008 PM2.5 Plan 

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2004, 2005 and 2006), and since SIPs use three-year averages to help control 

for meteorological variation, only three 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 available 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 Industry to identify a viable alternative to 

burning agricultural waste besides biomass facilities. In 2007, biomass facilities 

couldn’t process all of the agricultural waste, due to unforeseen circumstances. 

(Nisei)

Response: The District understands that the discontinuation of open burning is 

a major financial concern to several sectors within the agricultural industry. The 

District is committed to continuing to explore and encourage alternative practices 

in partnership with the industry and ARB. It is noted that SB 705 prohibits the 

burning of surface harvested orchard prunings and vineyard removals 

commencing June 1, 2010. The District will work 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 Strategy 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 27th state strategy only included updated reductions 

for 2017, so 2014 reductions must come from the April 26, 2007 version of the 

state SIP. 

39. Comment: Please explain the basis for assuming 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 progression of ARB reductions as an 

initial, draft assessment. ARB has thus for committed to only 2014 reductions 

beginning in 2014 thus far. Future versions of the plan will reflect ARB 

commitments as opposed to linear prorating. 
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2008 PM2.5 Plan 

Appendix J-64 

40. Comment: Please explain the statement that efforts done for this plan will assist 

in the attainment of the more stringent future 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 bring the Valley much closer to the 35 μg/m3 24-hour 

standard as set in 2006. Also, the District is proposing to set the Wood burning 

curtailment to the level of the 2006 standard. 

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

states: 

“As a result, a simplified modeling exercise 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 statutory attainment date of April 5, 2015. Based on 

simplified modeling exercises 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 highly flawed, since attainment of the 1997 

PM2.5 standards was only made possible 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 examine possibilities for the earlier attainment of the 1997 

PM2.5 standards. It is an admission that planning for the 1997 PM2.5 standard 

was not done for the purpose of meeting the 2010 deadline. (ISSRC) 

Response: The inventory adjustments are based on based thorough, periodic 

reviews of emissions inventory methodologies. 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 years. Also, future drafts of the plan 

will incorporate these adjustments 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, the District is examining the possibility of 

attainment in every possible attainment year. As the commenter notes in another 

comment, part of the challenge in demonstrating attainment before 2014 is the 

need for commitments for ARB reductions before 2014. The District will continue 
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2008 PM2.5 Plan 

Appendix J-65 

to consider the earliest attainment possible with updated reductions and 

attainment targets. 

42. Comment: The District should examine the possibility 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 the 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 coinciding 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 attainment of the primary 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. 
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