San Joaquin Valley Unified Air Pollution Control Di strict June 20, 2013

PM2.5 Contingency Quantification
1 2008 PM2.5 Plan 

### Quantification of Contingency Reductions for the 2008 PM2.5 Plan

Section 1: Introduction

The San Joaquin Valley Air District’s (District) 2008 PM2.5 Plan is a comprehensive and innovative strategy demonstrating expeditious attainment of the U.S. Environmental Protection Agency’s (EPA) 19 97 air quality standards for PM2.5 (particulate matter that is 2.5 microns or le ss in diameter). On November 9, 2011, EPA approved this plan and related submitt als, with the exception of the plan’s contingency measures 1 

### . This contingency disapproval triggers Clean Air Act (CAA) sanction clocks running from the effectiv e date of the final Federal Register action (January 9, 2012). The goal of thi s document is to demonstrate sufficient contingency measure emissions reductions to meet federal requirements and stop the sanction clock.

Contingency measures are extra emissions reductions that go into effect without further regulatory action 2 

### . In an attainment plan, the measures must be “ext ra” in the sense that the reductions are not accounted for in reasonable further progress (RFP) or in the attainment demonstration. The purpose of contingency measures is to continue progress in reducing emissi ons should the State Implementation Plan (SIP) need to be revised to mee t a missed RFP milestone or correct continuing nonattainment.

Contingency measure emissions reductions are demons trated for the RFP milestone years and for the attainment year. The d iscussion in EPA’s PM2.5 implementation rule suggests that the amount of con tingency reductions should be equivalent to about one year of reductions neede d for RFP 3 

### , although this is not embodied in regulatory requirements related to contingency measures (40 CFR 51.1012 or in CAA §172(c)(9)). For the 1997 PM 2.5 standard, this is based on the overall level of reductions needed to demons trate attainment divided by the number of years between the base year (2005) an d the attainment year (2014) (9-year timespan). Table 1 shows the result ing contingency need for each pollutant for the 2008 PM2.5 Plan

.

1 EPA, Approval and Promulgation of Implementation P lans; California; 2008 San Joaquin Valley PM2.5 Plan and 2007 State Strategy; Final Rule. 76 Fed. Reg. 217, pg 69896-69926. (2011, November 9). Retrieved from http://www.gpo.gov/fdsys/pkg/FR-2011-11-09/pdf/2011 -27232.pdf

2 Clean Air Act Section 172(c)(9), 40 CFR 51.1012.

3 EPA, Clean Air Fine Particle Implementation Rule [ PM2.5 Implementation Rule]. 72 Fed. Reg. 79, pp. 20586–20667. At 20642-43. (2007, April 25). Retrieved from http://www.gpo.gov/fdsys/pkg/FR-2007-04-25/pdf/E7-6 347.pdf#page=1San Joaquin Valley Unified Air Pollution Control Di strict June 20, 2013

PM2.5 Contingency Quantification
2 2008 PM2.5 Plan 

### Table 1: Contingency Reductions Target (in tons per day, or tpd)

Contingency Target = “One year’s worth of
RFP” 4



### PM2.5 2.5 NOx 31.6
SO2 0.2

Section 2: RFP milestone years

RFP contingencies are used if planned emissions con trols fail to reach the emissions targets specified in the SIP for RFP. Th e need to implement RFP contingencies is based on the emissions occurring i n the RFP milestone year. For the 2008 PM2.5 Plan , the RFP milestone years are 2009 and 2012; howeve r, EPA noted that only 2012 needed to be evaluated for purposes of correcting the contingency disapproval. If the 2012 RFP targets w ere met, then 2012 contingency reductions are not needed.

All control measure commitments from the 2008 PM2.5 Plan have been adopted by the District and ARB except one: Rule 4905 (Natu ral, gas-fired, fan-type residential central furnaces) is to be amended in 2 014, but emissions reductions from this rule amendment were not quantified or cre dited in the 2008 PM2.5 Plan

. Table 2 is based on the most recent annual planning inventories available, from ARB’s 2011 RFP tables for the Valley with updates f rom EPA’s September 2011 TSD. Since the actual 2012 emissions levels are at or below the approved RFP levels, RFP was met for 2012, and contingencies for the RFP year are not needed.

Table 2: 2012 RFP Benchmarks 5

Approved RFP Level Actual 2012 emissions RFP benchmark met?

PM2.5 71 70 Yes
NOx 336 336 Yes
SOx 20 20 Yes

4 This data is consistent with EPA’s determination i n its September 20, 2011 Technical Support Document and Responses to Comments, Final Rule on t he San Joaquin Valley 2008 PM2.5 State Implementation Plan, page 132. http://www.regulations.gov/#!documentDetail;D=EPA-R 09- OAR-2010-0516-0175

5 Based on EPA’s September 2011 TSD, page 120. http://www.regulations.gov/#!documentDetail;D=EPA-R 09-OAR-2010-0516-0175San Joaquin Valley Unified Air Pollution Control Di strict June 20, 2013

PM2.5 Contingency Quantification
3 2008 PM2.5 Plan 

### Section 3: Attainment year

Attainment contingencies are implemented if a regio n fails to attain a federal standard by the final attainment date 6 

### . The need to implement attainment contingencies is based on ambient air quality data as of the end of the attainment year. This is contrasted against RFP contingencies , which are needed if emissions reductions targets are not met. The Dist rict and ARB have already adopted all plan control measures that included emi ssions reductions commitments to assure that the emissions levels nee ded for attainment will be achieved in 2014.

However, if EPA finds that an area fails to attain a standard on time, contingency reductions must be implemented automatically. An a rea often must adopt a new attainment plan, and sometimes other penalties appl y as well, depending on the requirements associated with the standard in questi on.

3.1 What Qualifies as a Contingency Measure?

As noted in the introduction (Section 1 of this doc ument), contingency measures are extra emissions reductions that go into effect without further regulatory action. The amount of contingency reductions shoul d be equivalent to about one year of reductions needed for RFP 7 

### . The plan should contain trigger mechanisms and a schedule for the contingency measu re implementation. Contingency measures can include measures already a dopted and scheduled for implementation, as long as these measures are not r elied on to provide emissions reductions needed to provide for RFP or e xpeditious attainment.

Based on these general contingency requirements, th e District is utilizing three types of contingency measures in this contingency q uantification:

• Surplus reductions from implementation of traditio nal regulations

• Regulations with a contingency trigger

• SIP-creditable incentive-based emissions reduction s

Each of these contingency measures was discussed in either Chapter 9 of the 2008 PM2.5 Plan 8 

### or ARB’s resolution adopting the plan. 9 

### As such, this

6 However, Clean Air Act Section 172(a)(2)(C) and EP A’s Fine Particle Implementation Rule allow for two one-year attainment date extensions in the event that there is “clean data” in the attainment year, but not in the preceding two years that also factor into the three-year average attainment determinations.

7 EPA, Clean Air Fine Particle Implementation Rule [ PM2.5 Implementation Rule]. 72 Fed. Reg. 79, pp. 20586–20667. At 20642-43. (2007, April 25). Retrieved from http://www.gpo.gov/fdsys/pkg/FR-2007-04-25/pdf/E7-6 347.pdf#page=1

8 District’s (April 30, 2008) 2008 PM2.5 Plan , Chapter 9, pages 9-7 through 9-9. http://www.valleyair.org/Air_Quality_Plans/docs/AQ_ Final_Adopted_PM2.5/13%20Chapter%209. pdf

9 ARB (May 22, 2008). Resolution adopting the 2008 PM2.5 Plan , page 6. http://www.arb.ca.gov/planning/sip/sjvpm25/resoluti on_sjv08.pdfSan Joaquin Valley Unified Air Pollution Control Di strict June 20, 2013

PM2.5 Contingency Quantification
4 2008 PM2.5 Plan 

### document is not adding new contingency measures to the plan, but is more accurately quantifying the benefit of these measure s to demonstrate that sufficient contingency reductions are being achieve d.

3.1.1 Surplus Reductions from Implementation of Tra ditional Regulations

The year 2014 was modeled for attainment in the 2008 PM2.5 Plan . As the attainment contingency need would not occur until 2 015 (since attainment would be based on air quality data collected through the end of 2014), the additional reductions occurring between 2014 and 2015 due to f urther implementation of adopted controls and fleet turn-over can serve as a ttainment contingencies (Table 3). ARB documented the emissions reductions occurring between 2014 and 2015 in its May 18, 2011 letter to EPA, and EPA acknowledges this data in its contingency quantification in its TSD 10



### .
Table 3: Attainment Contingencies from Traditional Regulatory Reductions: additional reductions in 2015 (tpd)

Contingency


### NOx 21

PM2.5 0

SOx 3

3.1.2 Regulations with Contingency Trigger

The District’s 2008 Amendment to Rule 4901 (Wood Bu rning Fireplaces and Wood Burning Heaters) included a contingency provis ion (Section 5.6.5 of Rule 4901) that would lower the mandatory wood burning c urtailment threshold if the Valley fails to attain the 1997 PM2.5 standard by A pril 2015. The contingency, if implemented, would lower the curtailment level from a forecast 24-hour level PM2.5 level of 30 μg/m3 to 20 μg/m3. This would re sult in more “No Burn” days and more PM2.5 and NOx emissions reductions from re sidential wood combustion. The trigger for this measure is that t he lower threshold would become effective 60 days after final EPA rulemaking that the Valley failed to attain the federal annual PM2.5 standard set in 199 7 by the applicable attainment deadline (April 2015, based on 2012-2014 data).

As part of the 2012 PM2.5 Plan adopted by the District Governing Board in December 2012, the District has made a local commit ment to lower the wood burning curtailment in 2014, with implementation st arting November 1, 2014.

10 EPA, September 20, 2011 Technical Support Document and Responses to Comments, Final Rule on the San Joaquin Valley 2008 PM2.5 State Imp lementation Plan, page 135, “New” Post Attainment Year Reductions. http://www.regulations.gov/#!documentDetail;D=EPA-R 09-OAR2010-0516-0175San Joaquin Valley Unified Air Pollution Control Di strict June 20, 2013

PM2.5 Contingency Quantification
5 2008 PM2.5 Plan 

### This proactive strengthening of the rule does not c hange the status of the current Rule 4901 contingency, as these additional reductio ns were not relied upon to demonstrate attainment in the 2008 PM2.5 Plan

.

The emissions reductions that would be achieved by this contingency measure are based on the:

• Total emissions reductions that would be achieved by Rule 4901, as an annual average day, under implementation of the con tingency level

• Minus

the annual average emissions reduction plan commit ment for Rule 4901 in 2014 without the contingency, and which was accounted for in the RFP demonstration and the attainment plan modeling.

Based on Tables 4 and 5 below, the emissions reduct ion attributable to the Rule 4901 contingency is, as an annual average, 3.12 tpd of PM2.5 and 0.32 tpd of NOx . This is higher than estimates previously supplie d to EPA and noted in its September 20, 2011 Technical Support Document, page 135. However, previous estimates were based on 2006 air quality d ata, whereas the analysis presented here is based on 2009-2013 air quality da ta (during which the 2008 amendment to Rule 4901 has been fully implemented). Also, the previous estimate did not accurately account for the 2014 em issions reductions commitment from pre-contingency Rule 4901.

This conservative calculation is just one way to ca lculate the contingency benefit. However, this calculation greatly understates the f ull impact of Rule 4901 “No burn” days, which reduce some of the most harmful s pecies of particulates in the times and places where air quality is forecast to r each unhealthy levels. The contingency achieves the greatest benefit during th e winter, when PM2.5 is highest. A Valley-wide no-burn day achieves a direct PM2.5 e mission reduction of 16 tons . No other single regulation achieves this level o f effectiveness.San Joaquin Valley Unified Air Pollution Control Di strict June 20, 2013

PM2.5 Contingency Quantification
6 2008 PM2.5 Plan 

### Table 4: PM2.5 emissions reductions, Rule 4901 contingency

Column 1 Column 2 Column 3 Column 4

County Total “No Burn” days

at contingency level, based on 2009-2013 wood-burning

seasons Direct PM2.5 emissions subject to the rule, tons/day PM2.5 emissions prevented during contingency,
tons (Column 2 x Column 3)
Fresno 85 5.40 459.34 Kern (Valley portion) 78 3.58 278.93 Kings 69 0.52 35.95
Madera 65 1.90 123.70
Merced 55 1.43 78.87 San Joaquin 49 3.51 172.04 Stanislaus 74 3.07 227.18
Tulare 67 2.29 153.10

Total tons of direct PM2.5 prevented 1529.1 tons As an annual average day (divide by 365) 4.2 tpd Minus the annual average emissions reductions commi tment accounted for in the EPA’s TSD 11 -1.08

Rule 4901 Contingency Benefit, annual average 3.12 tpd



### Table 5: NOx emissions reductions, Rule 4901 contingency

Column 1 Column 2 Column 3 Column 4

County Total “No Burn” days at contingency level, based on 2009-2013 wood-burning seasons Direct NOx emissions subject to the Rule, tons/day NOx emissions

prevented during contingency,
tons (Column 2 x Column 3)
Fresno 85 0.57 48.37 Kern (Valley portion) 78 0.37 28.47 Kings 69 0.05 3.52
Madera 65 0.23 14.63
Merced 55 0.14 7.92 San Joaquin 49 0.35 16.95 Stanislaus 74 0.31 22.64
Tulare 67 0.28 19.03

Total tons of direct NOx prevented 161.53 As an annual average day (divide by 365) 0.44 Minus the annual average emissions reductions commi tment accounted for in the EPA’s TSD 12 -0.12 tpd

Rule 4901 Contingency Benefit, annual average 0.32 tpd

11 EPA, Technical Support Document and Responses to Co mments, Final Rule on the San Joaquin Valley 2008 PM2.5 State Implementation Plan , page 93 (2011, September 20). http://www.regulations.gov/#!documentDetail;D=EPA-R 09-OAR-2010-0516-0175

12 Ibid.San Joaquin Valley Unified Air Pollution Control Di strict June 20, 2013

PM2.5 Contingency Quantification
7 2008 PM2.5 Plan 

### 3.1.3 SIP-Creditable Incentive-Based Emissions Redu ctions

The District’s successful incentive-based measures have been reducing pollutant emissions above and beyond reductions being achieve d through traditional regulations. Historically, EPA has not granted cre dit for incentive-based reductions for use in SIPs to meet Clean Air Act ob ligations. New District Rule 9610 will establish appropriate mechanisms for the District to take SIP credit for eligible incentive programs achieving surplus, quan tifiable, and enforceable emissions reductions. Once given credit, SIP-credi table, incentive-based emissions reductions will be used alongside regulat ory measures to meet federal Clean Air Act requirements, such as requirements fo r contingency reductions. These criteria and the District incentive programs that meet these criteria are more fully discussed in draft District Rule 9610 an d the accompanying staff report.

The 2013 Annual Demonstration Report shows emission s reductions being achieved across several applicable incentive progra ms. A total of 10.9 tpd of NOx and 0.44 tpd of PM2.5 is available for continge ncy through Carl Moyer, Prop 1B, and NRCS. This total amount of reductions surp asses the amount needed in this quantification: 4.15 tpd of NOx reductions and 0.10 tpd of PM2.5 reductions of SIP-creditable incentive based emissions reducti ons.

Under Section 7.0 of Proposed Rule 9610, the Distri ct must make several commitments for each SIP submission in which the Di strict relies on Rule 9610 reductions:

• Identify incentive program guidelines (as specified in Section 3.0) used to generate projected SIP-creditable emission reductions. (Section 7.1)

The District is using guidelines specifically inclu ded in Section 3.1 of Rule 9610, the 2013 Annual Demonstration Report, and the Manual of Procedures.

• Identify emission reductions not to exceed the amou nt projected to be achieved through the use of secured or reasonabl y anticipated incentive program funding and the estimated availab ility of emission reductions projects and willing participants, based on historical participation and estimates of remaining equipment. (Section 7.2)

Whereas some SIP commitments will be based on proje ctions of expected funding and participation, the SIP-creditable incen tive-based emissions reductions for this contingency demonstration relie s only on alreadyexecuted, legally binding contracts. Therefore, t he emissions reductions commitment here does not exceed the amount achieved through actual incentive program funding and actual program partic ipation.San Joaquin Valley Unified Air Pollution Control Di strict June 20, 2013

PM2.5 Contingency Quantification
8 2008 PM2.5 Plan 

### • Be specifically adopted by the District as a part o f the SIP and accounted for in the annual demonstration report as SIP-creditable emission reductions are achieved through provisions of this rule. (Section 7.3)

The District adopted the use of incentive program r eductions for contingency as part of the SIP in the 2008 PM2.5 Plan . And now, this Rule 9610 emissions reductions commitment is to be adopted by the District as part of the SIP at the June 2013 public hearing, and is specifically accounted for in the 2013 Annual Demon stration Report.

• State that if either the District or EPA finds that there is a SIP shortfall for a particular year, the District will adopt and submit to EPA, by specified dates, substitute rules and measu res that will achieve equivalent emission reductions as expeditio usly as practicable and no later than any applicable implem entation deadline in the Clean Air Act or EPA’s implementing regulati ons. (Section 7.4)

Whereas some SIP commitments will be based on proje ctions of expected funding and participation, the SIP-creditable incen tive-based emissions reductions for this contingency demonstration relie s only on alreadyexecuted, legally binding contracts. Since the re ductions relied upon in this contingency quantification and documented in t he 2013 Annual Demonstration Report are based on legally-binding c ontracts and corresponding already-implemented emissions reducti ons, there is no shortfall. In fact, the 2013 Annual Demonstration Report quantifies more than double the total emissions reductions needed f or this contingency demonstration. In addition, contracts executed bet ween now and the end of 2014 will provide additional emissions reduction s for 2015. The District’s ongoing project tracking of executed agr eements ensures that no shortfall results as these projects continue to be implemented. The District would remedy any shortfall in a timely man ner, per Section 7.4.

3.2 Sufficient Contingency Reductions

Areas like the Valley that have significant nonatta inment challenges have developed several generations of aggressive and far -reaching emission reduction measures to meet various Clean Air Act re quirements. The result of this “no stone left unturned” policy is that when v iable emission reductions are identified, they are implemented to contribute to e xpeditious attainment. Reductions are not usually held in reserve to be us ed only if an area fails to meet a milestone. As a result, contingency measure demo nstrations in the Valley have been a challenge, historically.San Joaquin Valley Unified Air Pollution Control Di strict June 20, 2013

PM2.5 Contingency Quantification
9 2008 PM2.5 Plan 

### However, this document has outlined three types of contingency measures being used to meet the contingency reductions required fo r the 2008 PM2.5 Plan :

• Surplus from traditional regulations (see Section 3.1.1)

• Regulations with contingency trigger (see Section 3.1.2)

• SIP-creditable incentives (see Section 3.1.3) Table 6 shows how these approaches together generat e enough emissions reductions to meet the contingency reductions requi red for this plan.

Table 6: Demonstration of Sufficient Contingency R eductions
2015
PM2.5 Contingency reductions required 2.5 Demonstration of contingencies achieved Surplus from traditional regulations 0.0 Regulations with contingency trigger (Rule 4901) 3.12 SIP-creditable incentives (up to 0.44 tpd available) 0.10 Subtract PM2.5 reductions, trade for NOx* -0.72

Total contingency reductions achieved 2. 5 Contingency need met? Yes

NOx Contingency reductions required 31.6 Demonstration of contingencies achieved Surplus from traditional regulations 21.0 Regulations with contingency trigger (Rule 4901) 0.3 SIP-creditable incentives (up to 10.9 tpd available) 4.15 Substitute PM2.5* 6.48

Total contingency reductions achieved 31. 93 Contingency need met? Yes

SOx Contingency reductions required 0.2 Demonstration of contingencies achieved Surplus from traditional regulations 3.0 Regulations with contingency trigger 0.0 SIP-creditable incentives 0.0

Total contingency reductions achieved 3.0 Contingency need met? Yes

* 1 ton of direct PM2.5 emissions reductions is equ ivalent to 9 tons of NOx reductions in the 2008 PM2.5 Plan. See Appendix A to this contingency quantification documentSan Joaquin Valley Unified Air Pollution Control Di strict June 20, 2013

PM2.5 Contingency Quantification
10 2008 PM2.5 Plan 

### Appendix A 9:1 Trading Ratio, NOx:PM2.5

ARB provided the following “Attachment 3” to EPA on May 18, 2011 to document inter-pollutant trading ratios that depict the rela tive effectiveness of reductions in different precursors contributing to ambient PM2.5 levels in the San Joaquin Valley Air Basin (as well as South Coast). In the 2008 PM2.5 Plan , as approved by EPA, the 9:1 trading ratio was used only for tra nsportation conformity

purposes 13 

### , because that was the need at that time. However, the analysis generating this trading ratio was based on the emis sions inventory as a whole, and not just mobile source emissions, as described in “Attachment 3.” Since EPA has already accepted this non-source-specific d emonstration, the resulting trading ratio is available for use beyond transport ation conformity.

13 ARB, 2011 PM2.5 SIP Revisions, Appendix D: Transpor tation Conformity Budgets, page 2 (2011, March 29). Retrieved from http://www.arb.ca.gov/planning/sip/sjvpm25/appd.pdfAttachment 3

Precursor Effectiveness

In order to understand the relative effectiveness of reductions in different precursors contributing to ambient PM2.5, staff of the Air Resources Board (ARB) and the South Coast Air Quality Management District (SCAQMD) conducted air quality modeling sensitivity runs using the modeling conducted for the attainment demonstrations. These relative effectiveness ratios were used to guide control strategy development as well as to normalize the benefits of multiple precursors so they can be reflected in terms of a single equivalent precursor. This method also provides a uniform metric for tracking progress relative to the attainment emissions targets. Documentation on the methodologies used for calculating the effectiveness ratios in each area is provided below.

South Coast

A description of the methodology used by SCAQMD staff is provided in Appendix C of ARB'S staff report on the SCAQMD 2007 State Implementation Plan which can be found
at:

San Joaquin Valley

In order to evaluate precursor effectiveness, ARB staff focused on the response in the Bakersfield metropolitan area where the highest PM2.5 concentrations in the San Joaquin Valley occur. Staff conducted two grid-based modeling sensitivity runs where the NOx and primary PM2.5 emissions were reduced, one at a time, by 10% relative to the future-year modeled attainment scenario. From these sensitivity runs we calculated

a future year modeled design value reflecting the further 10% emission reduction assumptions. The difference between the attainment scenario (before 10% reduction in emissions) and adjusted (after 10% reduction in emissions) design values were then compared. Table 1 shows results for NOx and primary PM2.5 emission reductions as well as the efficacy of reducing primary PM2.5 relative to that for NOx.

The 

### lS' column of Table 1 lists the Bakersfield area monitoring sites and the 2" column contains the monitored 2006 design value for those sites. The 3rd column contains the 2014 modeled design values taking into account all of the reductions in the attainment strategy. The 4Ih and 5'h columns list the adjusted 2014 design values with additional 10% emissions reductions for NOx, and primary PM2.5, respectively. The 6'h column lists the effectiveness of controlling primary PM2.5 relative to that of controlling NOx. This analysis showed that controlling primary PM2.5 is approximately nine times more effective than controlling NOx based on the average across the three Bakersfield area sites.Attachment 

### 3

The precursor effectiveness values were calculated by determining the difference between the modeled 2014 attainment design value (3rd column) and the design value of the sensitivity run (4th or 5th col~~mns). This difference was then divided by the tonnage of each precursor corresponding to a 10% domain-wide reduction in emissions
to develop the respective precursor effectiveness ratios. 'The 

### PM2.5 effectiveness value was then divided by the NOx effectiveness value to determine a relative ratio (6th column).

Table 1: The effectiveness of precursor controls on the 2014 design value.

Site Measured
2006 Design Value (uglm3) Modeled 2014 Design Value With SIP Attainment

Strategy (uglm3) Modeled 2014 Design Value With
Additional 10% NOx Reduction

(uglm3) Modeled 2014 Design Value With
Additional 10% PM2.5 Reduction

(uglm3) Effectiveness Relative to NOx

Site 1 (Bakersfield-California
Site 2 (Bakersfield-Planz)
Site 3 (Bakersfield-Golden) 18.5

18.9

18.6 14.3

14.7

14.4 -

14.1

14.6

14.2 13.6

14.0

13.7 8.7

9.3

8.6