### Resolution 07-28

September 27, 2007

Attachment A

Technical and Clarifying Modifications to April 26, 2007 Revised Draft Air Resources Board’s Proposed State Strategy for C alifornia’s

2007 State Implementation Plan

and May 7, 2007 Revised Draft Appendices A through GResolution 07-28, Attachment A 2 (This page intentionally left blank.)Resolution 07-28, Attachment A 3 Attachment A

The following are technical modifications to the Re vised Draft of the Proposed State Strategy for California’s 2007 Implementation Plan. The changes are briefly described below, and a strikeout/underlined version of the corresponding page(s) is also attached.

Technical Modifications to April 26, 2007 Revised D raft:

1. Page 4. Changes an error in the description of estimated tons per day NOx

reductions from mobile sources in the South Coast b etween 2006 and 2014.

2. Page 23. Adds reference to federal Bureau of La nd Management.

3. Page 27. Makes a clarifying change describing S Ox reductions from petroleum refining.

4. Page 29. Removes specific reference to federal and international sources.

5. Page 31. Corrects pesticide inventory numbers i n the table, “San Joaquin Valley – Top sources of ROG”. (Note: There is no change to the official planning inventory numbers specified in Appendix A. Incorrect numbers were inadvertently included in the table.)

6. Page 35. Adds clarifying language about ARB’s a nd U.S. EPA’s authority to

control mobile sources.

7. Page 47. Adds clarifying language about ARB’s a nd U.S. EPA’s authority to

control mobile sources.

8. Page 67. Adds clarifying language about ARB’s a nd U.S. EPA’s authority to

control mobile sources.

9. Page 68. Adds clarifying language regarding ARB ’s and U.S. EPA’s authority to control international sources.

10. Page 70. Adds clarifying language to the notes describing the elements of

the attainment demonstration table.Resolution 07-28, Attachment A 4

Technical Modifications to May 7, 2007 Revised Draf t: Appendices A through H

1. Appendix A, Page 100. Corrects a summation erro r for PM2.5 grand total numbers for the San Joaquin Valley.

2. Appendix A, Page 103. Corrects a summation erro r for SOx grand total numbers for the San Joaquin Valley.

3. Appendix C, Pages 1-4. Interstate Transport. A dds clarifying language to long-distance transport, clarifies district heading s and make other wording

clarifications.

4. Appendix D, Page 2. Deletes reference to federa lly-approved transport couples in regards to RFP demonstrations.Resolution 07-28, Attachment A 5

Technical Modifications to Page 4 of the April 26, 2007 Revised Draft

The proposed mobile source strategy and SIP commitm ents are described in Chapter 3. Individual measures are described in mo re detail in Chapter 5. The figure below shows the decrease in emissions for pa ssenger vehicles, heavyduty trucks, and construction equipment between now and 2014 with the proposed State Strategy. Due to increasingly more stringent mobile source controls, emissions from these categories are all o n a downward trend, despite growth in population, travel, and the economy. The new measures in the proposed State Strategy would accelerate these emis sions reductions. ARB staff is proposing an aggressive new emission reduction c ommitment of 122 tons per day of NOx reductions in the South Coast by 2014 in order to meet the region’s PM2.5 attainment needs. This would bring the total mobile source NOx

reductions achieved between 2006 and 2014 to about 450 430 tons per day.



### Impact of State Strategy by 2014

South Coast - NOx

0 50 100 150 200 250

2006 2014

Trucks 2006 2014

Passenger

Vehicles 2006 2014

Construction
Equipment

In contrast to passenger vehicles, trucks, and cons truction equipment that show

substantial emission decreases with natural fleet t urnover, locomotives and ships show an increase in emissions without the proposed State Strategy. Locomotive emissions have been decreasing in the South Coast d ue to the accelerated introduction of the cleanest current technology (Ti er 2). However, as shown below, growth overtakes this benefit by 2014. The proposed State Strategy

includes a measure to accelerate introduction of th e next generation of clean technology once U.S. EPA adopts its proposed new Ti er 4 standards. The 2014 benefits assume Tier 4 engines becoming available i n 2012. The 70 percent reduction projected for 2020 is based on the propos ed measure to accelerate the

introduction of Tier 4 locomotives to California.Resolution 07-28, Attachment A 6

Technical Modifications to Page 23 of the April 26, 2007 Revised Draft

Environmental Justice

The SIPs consist of strategies designed to bring a region’s air quality into compliance with federal standards. SIPs must be de signed to ensure air quality standards throughout the entire region, so achievin g air quality standards provides public health benefits to every community. This makes SIP implementation important to meeting ARB’s community health and environmental justice goals. As part of our environmental justic e program, ARB has initiated air quality studies in several communities and continue s to focus resources on mobile source enforcement in environmental justice communities. ARB’s Air Quality and Land Use Handbook, approved by ARB in M ay 2005, provides guidance to help improve local land use decisions t hat can negatively impact public health at the community level.

ARB’s SIP strategies have a significant nexus to co mmunity health due to the emphasis on cleaning up the legacy fleets of diesel engines. Much of the large equipment and vehicles that help construct our buil dings and highways and move our goods are not well controlled and have very lon g lives. Adopting rules to clean up these fleets will have an immediate and si gnificant effect on the

communities where these sources are concentrated.

Regional Haze

The same particulate air pollutants that affect pub lic health also extinguish and scatter light, thereby obscuring visibility. The f ederal Clean Air Act set the farreaching goal of achieving natural visibility condi tions by 2064 in the nation’s most treasured parks and wilderness areas. Of the 156 designated areas, 29 are in California, managed by the National Park Service , the federal Bureau of Land Management, and the U.S. Forest Service. Therefore California is working in

concert with fourteen other western states to reduc e controllable emissions of particulates so that regional haze is reduced in th e western region of the country. In 1999, the U.S. Environmental Protection Agency p ublished rules to guide the preparation of Regional Haze State Implementation P lans to reduce regional

haze.

ARB is currently preparing the first regional haze plan for the entire State, for transmittal to EPA by the December 17, 2007 deadlin e. General trends in

California since the 1990s show that emission contr ols are improving visibility in our parks and wilderness areas. The regional haze plan will show how these controls constitute reasonable progress along the p ath to natural visibility. In 2012, ARB will conduct a mid-course review of measu red visibility changes and analyze how emission reductions implemented to achi eve the 8-hour ozone and

the PM2.5 standards will move the State further alo ng the path to natural visibility

in the future.Resolution 07-28, Attachment A 7

Technical Modifications to Page 27 of the April 26, 2007 Revised Draft

SOx . Sulfur oxide emissions are dominated by the mobi le source category of ships and commercial boats. Evaporative losses fro m petroleum Petroleum refining (a stationary source) are is another significant source of SOx. The other sources that make up 5 percent or more of the SOx i nventory are locomotives and mining and cement manufacturing.

Direct PM2.5 . Directly emitted PM2.5 comes mainly in the form of smoke, soot, and dust particles. Major sources include managed burning and agricultural burning; dust generated by vehicles traveling on pa ved and unpaved roads, residential fireplaces, cooking and fuel combustion ; and particle emissions from diesel-fueled engines on trucks, ships, and constru ction equipment. While soot from diesel engines is not a major portion of the e ntire direct PM2.5 emissions inventory, it is a major health concern, as it is a toxic air contaminant that can cause premature death.

Forecasting Future Emissions

Estimates of projected future emissions depend on t wo independent variables: growth and control. Different methods are used to estimate the future growth of emission sources based on their type. And future e mission controls are incorporated into the projected emissions for each source category based on when the controls are implemented, how much the con trols reduce emissions, and how many units (vehicles, consumer products, et c.) are affected.

The charts on the next page show the change in tota l projected statewide emissions for NOx, ROG, and SOx from 2006 to 2023 a nd the relative emissions change in each of these emission source categories. They reflect projected growth in each category combined with the benefits of the existing control program (those emission controls adopted prior to 2 007). For example, SOx emissions as a category continue to grow due to shi p emission increases. This makes ship SOx emissions a high priority for contro l in the new SIP strategy. NOx and ROG emissions are decreasing as a result of existing control programs despite substantial growth in population, travel, a nd the economy.

ARB uses two computer models to simulate and foreca st emissions for on- and off-road sources. For cars, sport utility vehicles , minivans, and trucks, ARB used EMFAC2007. For off-road vehicles and equipment, AR B used OFFROAD2007. Both models were released for public use in Novembe r 2006 after a multi-year development process. As required by federal guidan ce, EMFAC2007 uses the latest fleet information for vehicles age and popul ation. The data is developed from the California Department of Motor Vehicle reg istration data through 2005. For SIP purposes, as required by State law, vehicle activity is based on local transportation agency projections, or California De partment of Transportation data, if local data are not available.Resolution 07-28, Attachment A 8

Technical Modifications to Page 29 of the April 26, 2007 Revised Draft

Here are some things we have learned by analyzing t he emissions inventory for

these two areas:

• South Coast NOx emissions are significantly impact ed by goods movement, with the ships, trains, trucks, and off-road equipm ent that move goods contributing about 30 percent of all South Coast NO x emissions. Aircraft NOx emissions are also increasing.

• The impact of goods movement in the San Joaquin Va lley is felt mostly by the emissions contribution of heavy-duty trucks, which are projected to remain the largest NOx emitter through 2023.

• Emissions of NOx from manufacturing and industrial sources in the San Joaquin Valley become increasingly significant as e missions from mobile

sources decline in the future.

• The large population in the South Coast is the mai n reason why consumer product emissions are projected to become the numbe r one ROG emissions source by 2014.

• San Joaquin Valley ROG emissions are significantly impacted by agricultural

sources such as livestock waste.

• The existing emission control program will cut hea vy-duty truck NOx emissions about 70 percent in the San Joaquin Valle y and South Coast by 2023, but they need to be cut even more by new stra tegies to attain ozone

and PM2.5 standards.

• Mobile sources under subject to federal and international standards jurisdiction (like ships, locomotives, and aircraft) contribute an increasingly greater proportion of total emissions, especially N Ox, in future years as emission increases due to growth overwhelm the exis ting control program, while emissions of mobile sources under State juris diction decrease due to stringent controls.Resolution 07-28, Attachment A 9

Technical Modifications to Page 31 of the April 26, 2007 Revised Draft

South Coast Air Basin – Top Sources of ROG Summer emissions, tons per day

Source Category 2006 2014 2023

PASSENGER VEHICLES 207 112 76

CONSUMER PRODUCTS 101 103 110

RECREATIONAL BOATS 64 53 51

OFF-ROAD EQUIPMENT (LAWN AND GARDEN) 52 40 38

ARCHITECTURAL COATINGS (PAINTS AND THINNERS) 31 29 31

OFF-ROAD EQUIPMENT (COMMERCIAL, INDUSTRIAL) 28 15 1 2 PETROLEUM MARKETING (GASOLINE EVAPORATIVE LOSSES) 27 28 31 COATINGS (PAINTS AND THINNERS - NON ARCHITECTURAL) 27 25 28

GASOLINE-FUELED COMMERCIAL TRUCKS 24 13 8

GAS CANS 21 10 7

OFF-ROAD EQUIPMENT (CONSTRUCTION AND MINING) 20 12 8

TOTAL OF TOP CATEGORIES 600 441 399

TOTAL 732 567 534

TOP CATEGORIES PERCENT OF TOTAL 82% 78% 75%

San Joaquin Valley – Top Sources of ROG Summer emissions, tons per day

Source Category 2006 2014 2023

PASSENGER VEHICLES 62 37 24

WASTE DISPOSAL/COMPOSTING 57 72 80

LIVESTOCK WASTE (DAIRY CATTLE) 40 33 41 OIL AND GAS PRODUCTION (EVAPORATIVE LOSSES/FLARING) 28 26 23

CONSUMER PRODUCTS 24 26 30

PESTICIDES 22

18 20

18 20

18

HEAVY DUTY DIESEL TRUCKS 20 13 8

RECREATIONAL BOATS 20 17 17 FOOD AND AGRICULTURE (CROP PROCESSING AND WINERIES) 13 12 13

ARCHITECTURAL COATINGS (PAINTS AND THINNERS) 11 12 13

OFF-ROAD EQUIPMENT (COMMERCIAL, INDUSTRIAL) 10 6 4

FARM EQUIPMENT (COMBINES AND TRACTORS) 10 5 3

TOTAL OF TOP CATEGORIES 317

313 279

277 277

275

TOTAL 452 410 414

TOP CATEGORIES PERCENT OF TOTAL 70% 68% 67%

Note: Emissions do not include impact of Sta te Strategy proposed new measures.Resolution 07-28, Attachment A 10

Technical Modifications to Page 35 of the April 26, 2007 Revised Draft



### 3. ARB’s 2007 SIP STATE STRATEGY

The State Strategy maps out how to achieve the emis sion reductions necessary to meet federal air quality standards. The two mai n emission reduction components of the State Strategy are the adopted SI P measures and proposed new measures. The adopted SIP measures include tho se adopted through 2006. Proposed new measures include those to be ad opted after 2006.

Responsibility for implementing emission reduction measures is shared between the agencies with primary responsibility for contro lling air pollution in California: the Air Resources Board, 35 local air pollution con trol and air quality management districts, and the U.S. Environmental Pr otection Agency. However, given the current status of statewide emissions, AR B has the lion’s share of responsibility, followed by U.S. EPA.

Agency Roles in SIP Measure Development

Local Measures

Local air districts are primarily responsible for c ontrolling emissions from stationary and areawide sources (with the exception of consumer products) through rules and permitting programs. Examples in clude industrial sources like factories, refineries, and power plants; commercial sources like gas stations, dry cleaners, and paint spray booth operations; residen tial sources like fireplaces, water heaters, and house paints; and miscellaneous non-mobile sources like emergency generators. Districts also inspect and t est fuel vapor recovery systems to check that such systems are operating as certified.

State Measures

ARB is responsible for controlling emissions from m obile sources (except where federal law preempts ARB’s authority) and consumer products, developing fuel specifications, establishing gasoline vapor recover y standards and certifying vapor recovery systems, providing technical support to the districts, and overseeing local district compliance with State and federal law. The Department of Pesticide Regulation is responsible for control of agricultural, commercial and structural pesticides, while the Bureau of Automoti ve Repair runs the State’s Smog Check programs to identify and repair pollutin g cars.

Federal Measures

U.S. EPA has the authority to control emissions from certain mobile sources, including sources all or partly under exclusive fed eral jurisdict ion (like interstate trucks, some farm and construction equipment, aircr aft, marine vessels, and locomotives based in this country) which it shares in many cases with local

districts and ARB . U.S. EPA also has oversight authority for state air programsResolution 07-28, Attachment A 11

as they relate to the federal Clean Air Act. Inter national organizations develop

standards for aircraft and marine vessels that operate outside the U.S.Resolution 07-28, Attachment A 12

Technical Modifications to Page 47 of the April 26, 2007 Revised Draft

SOx, 49 tons per day of NOx, and about 4 tons per d ay of direct PM2.5 in the South Coast by 2014.

Ships

Emissions from ocean-going vessels, unlike most maj or pollution sources, are not projected to decrease in future years, since sh ips have little or no emission controls and run on high-emitting bunker fuel, and shipments of cargo containers are projected to grow significantly over the next t wo decades. Ships currently emit half the statewide SOx emissions, and it is es timated that ships will jump from the sixth to the second highest statewide NOx producer by 2023. It is essential to reduce ship emissions as they are ente ring our ports and when they are docked through application of demonstrated cont rol technologies, use of cleaner fuels, and operational efficiencies. Since ARB does not have authority to set ship engine emission standards, we For maximum effectiveness, ARB needs

to must work with national and international authorities, as well as the ports, as well as coordinate with national and international authorities, to implement many of the control measures necessary to clean up these sources

.

ARB took a big step in reducing emissions from ship s in December 2005 by adopting a rule phasing in the use of cleaner low-s ulfur fuel in ship auxiliary engines that will reduce SOx emissions from auxilia ry engines by 96 percent and PM2.5 emissions by 83 percent beginning in 2010.

Proposed New Ship Measures

In addition to the 2005 auxiliary engine fuel rule, the State Strategy proposes to reduce emissions from ship auxiliary engines throug h cold ironing and other clean technology. Cold ironing allows ships to tur n off their auxiliary engines and instead plug into an electrical system for power wh en they are docked at a port. This measure would phase in the number of ships cap able of using cold ironing and other at-dock technologies such as the “hood”, which fits onto a ship’s
exhaust stack and cleans the emissions, and is esti mated to reduce NOx emissions about 19 tons per day in 2014 and 28 tons per day in 2020.

The State Strategy proposes to reduce emissions fro m ship main engines through a variety of measures. A main engine fuel rule, patterned after the auxiliary engine fuel rule, would help reduce emiss ions by introducing a cleaner, low-sulfur fuel beginning no later than 2010. Incr easing the use of cleaner new engines or retrofitted engines beginning in 2010 co uld be implemented via regulation, incentives, voluntary agreements, or a combination of these approaches. Higher ship speeds cause much higher e missions. So a measure is proposed that would strengthen a current volunta ry program by requiring ships to reduce their speeds to 12 knots within 40 nautic al miles of the Ports of Los Angeles and Long Beach. The combination of ship ma in engine measures would reduce both NOx and SOx emissions by 20 tons per da y and direct PM2.5 emissions by over 2 tons per day in 2014. These re ductions would increase substantially through 2023.Resolution 07-28, Attachment A 13

Technical Modifications to Page 67 of the April 26, 2007 Revised Draft

Role of Funding and Incentive Programs

Over the past 40 years, California has steadily imp roved air quality in the face of tremendous economic and population growth. The vas t majority of that progress has come from effective regulations. Accordingly, ARB staff expects State and federal regulations to play the primary role in imp lementing the State Strategy. In the regulatory paradigm, polluting sources pay for the necessary emission controls as part of doing business. Regulated indu stries may pass these costs on to consumers in the form of higher prices, altho ugh competition and other factors may prevent some companies from recouping a ll of their control costs. Low-interest loans with extended payment periods ar e available to aid smaller businesses that need upfront capital to comply.

In recent years, regulatory programs have been supp lemented with financial incentives to accelerate voluntary actions, such as replacing older equipment. Incentive programs like the Carl Moyer Program are both popular and effective. They also help to demonstrate emerging technologies that then can be used to set a tougher emissions benchmark for regulatory re quirements. Most of the existing incentive programs are designed to pay for the incremental cost between what is required by regulation and advanced technol ogy that exceeds that level. The incentive programs are publicly funded through fees paid by California vehicle owners as part of their annual registration s, smog inspections or new tire purchases. California is currently investing up to $140 million per year to clean up older, higher emission sources.

The support for clean air incentive funding from Go vernor Schwarzenegger, the Legislature, and California’s voting public is refl ected in the passage on November 7, 2006, of the Highway Safety, Traffic Re duction, Air Quality, and Port Security Bond Act of 2006. The Bond Act inclu des $1 billion to accelerate the cleanup of air pollution caused by goods moveme nt activities in California. With appropriation by the Legislature, and subject to such conditions and criteria contained in a statute that it will enact, ARB will appropriate this money to fund

emission reductions from activities related to the movement of freight along

California’s trade corridors.

Federal Actions Needed

Measures in the State Strategy to reduce emissions from interstate and international sources rely on the federal governmen t to develop more stringent emission standards and to ensure these standards go into effect as soon a s possible. Emission reductions from locomotives, off-road eq uipment, marine auxiliary engines, and harbor craft are a significa nt part of the State Strategy. Proposed State measures would accelerate the introd uction of cleaner engines and equipment, but the emission reductions rely on the availability of cleaner new engines. U.S. EPA has primary, and in some cases e xclusive, authority to establish new engine emission standards for these s ources.Resolution 07-28, Attachment A 14

CAA section 209(e)(2) allows California to seek aut horization to adopt and

enforce emission standards for some non-road mobile sources. However, it is not likely that ARB could consult with affected par ties, develop and adopt regulations, and secure U.S. EPA approval to enact the regulations in time to ensure that resulting cleaner engines will be widel y available by 2014. Therefore, M measures in the State Strategy to reduce emissions from interstate and international sources rely on the federal gover nment to develop more stringent emission standards and to ensure these st andards go into effect as soon as possible.

ARB is proposing several measures to reduce ship em issions through a combination of regulations, incentives, and actions by ports and the privateResolution 07-28, Attachment A 15

Technical Modifications to Page 68 of the April 26, 2007 Revised Draft

sector. However, national and international action to clean up shipping fleets is also needed to fully realize our clean air goals. And aircraft emissions, which will become one of the South Coast’s top five NOx source s by 2020, are unaddressed in the State Strategy due to the lack o f effective international

standards.

California must rely on U.S. EPA plays an important role in to representing its

California’s interests before foreign or international regulatory bodies that negotiate minimum global standards governing have the ability to reduce emissions from international goods movement sources such as ocean-going

vessels . In this role, U.S. EPA should advocate for the a doption of cleaner ship emission standards and less polluting practices by the International Maritime Organization.

Possible Federal Actions

Adopt more stringent standards for sources under subject to federal control. U.S. EPA should move as fast as possible to lower standa rds for sources that it can regulate under its control , keeping in mind California’s air quality challeng e and attainment deadlines. There are categories of emis sion sources that we do not have the authority to regulate operational controls on these sources at the State

level. We also do not have the ability to regulate such sources in markets

outside of California that then when they operate within California. However, for

these sources and for other sources under exclusive or concurrent federal jurisdiction, federal regulation would enable great er and faster emission reductions than otherwise would be possible with on ly State action. Not only

would federal action lower emissions for new source s, but it would allow State and local actions to lower emissions from existing sources by setting in-use rules that speed up the integration of the cleaner engine s and technology into California fleets. These sources include: ships, l ocomotives, harbor craft, aircraft, and off-road equipment and vehicles.

Federal incentives for cleaner technology. Federal funding sources for clean air projects, as well as federal tax incentives promoti ng the manufacture, sale, and purchase of cleaner vehicles, equipment, and techno logy, could enhance California’s aggressive incentive programs.Resolution 07-28, Attachment A 16

Technical Modifications to Page 70 of the April 26, 2007 Revised Draft

Setting the Ozone Emission Reduction Target (tons per day)

Nonattainment Area

South Coast (2023) San Joaquin

Valley (2023)

NOx ROG NOx ROG

2006 Emissions Inventory 972 732 650 454

Carrying Capacity 114 420 160 342

Emission Reduction Target 858 312 490 112

(2006 Emissions Inventory) – (Carrying Capacity) = (Emission Reduction Target)

2006 Emissions Inventory = Amount of ozone-forming emissions. Carrying Capacity

= Pollutant emissions limit that ensures air quali ty standards are met. Emission Reduction Target = Amount of emissions that must be reduced to meet the standard.

Meeting the Ozone Emission Reduction Target (tons per day)

Nonattainment Area

South Coast (2023) San Joaquin

Valley (2023)

NOx ROG NOx ROG

Emission Reduction Target 858 312 490 112

Emission Reductions from Adopted SIP Measures 467 199 355 43

Emission Reductions from

New Local Measures 9 19 8 47

Emission Reductions from

New State Measures 141 54 46 25

Long-Term Measures 241 40 81 --

Total Reductions 858 312 490 115

Emission Reductions from Adopted SIP Measures = Emissions reduced from State and local measures adopted through 2006.

Emission Reductions from New Measures = Emissions reduced from measures in the State Strategy or new local measures adopted after 2006. Long-Term Measures

= Emissions reduced from measures adopted after 20 20 that rely on new or evolving technology, as allowed in section 182(e)(5 ) of the Clean Air Act.Resolution 07-28, Attachment A 17

Technical Modifications to Appendix A, Page 100 of the May 7, 2007 Revised

DraftOn-Road MobileLIGHT DUTY PASSENGER (LDA) 0.77 0.77 0.78 0.80 0.83 0.86 0.89 0.90 0.92 0.93 0.95 0.99 1.00 1.05 1.15LIGHT DUTY TRUCKS - 1 (LDT1) 0.27 0.27 0.27 0.27 0.28 0.28 0.29 0.29 0.30 0.30 0.31 0.31 0.32 0.33 0.36LIGHT DUTY TRUCKS - 2 (LDT2) 0.54 0.65 0.66 0.68 0.71 0.74 0.77 0.79 0.81 0.82 0.84 0.88 0.89 0.93 1.04MEDIUM DUTY TRUCKS (MDV) 0.24 0.35 0.35 0.37 0.39 0.41 0.43 0.44 0.46 0.47 0.48 0.50 0.51 0.54 0.60LIGHT HEAVY DUTY GAS TRUCKS - 1 (LHDV1) 0.04 0.04 0.040.04 0.04 0.05 0.05 0.05 0.05 0.05 0.05 0.06 0.06 0.06 0.07LIGHT HEAVY DUTY GAS TRUCKS - 2 (LHDV2) 0.01 0.01 0.010.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.02MEDIUM HEAVY DUTY GAS TRUCKS (MHDV) 0.01 0.01 0.01 0.010.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01HEAVY HEAVY DUTY GAS TRUCKS (HHDV) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.01 0.01 0.01 0.01 0.01 0.01LIGHT HEAVY DUTY DIESEL TRUCKS - 1 (LHDV1) 0.01 0.06 0.06 0.05 0.05 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.03 0.03LIGHT HEAVY DUTY DIESEL TRUCKS - 2 (LHDV2) 0.03 0.04 0.04 0.04 0.04 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.02 0.02MEDIUM HEAVY DUTY DIESEL TRUCKS (MHDV) 0.56 0.63 0.62 0.56 0.56 0.55 0.53 0.51 0.49 0.47 0.45 0.42 0.41 0.39 0.38HEAVY HEAVY DUTY DIESEL TRUCKS (HHDV) 8.92 9.01 10.81 8.69 8.13 7.56 7.01 6.48 5.96 5.47 5.00 4.17 3.81 3.23 2.68MOTORCYCLES (MCY) 0.02 0.04 0.04 0.04 0.04 0.04 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03HEAVY DUTY DIESEL URBAN BUSES (UB) 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04HEAVY DUTY GAS URBAN BUSES (UB) 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00SCHOOL BUSES (SB) 0.08 0.09 0.09 0.09 0.09 0.10 0.10 0.10 0.10 0.10 0.10 0.11 0.11 0.11 0.11OTHER BUSES (OB) 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02MOTOR HOMES (MH) 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01On-Road Subtotal11.5612.0513.8611.7011.2310.7410.279.779.288.818.387.627.306.826.58Other MobileAIRCRAFT1.33 1.36 1.43 2.02 2.08 2.19 2.31 2.35 2.39 2.44 2.48 2.57 2.62 2.72 2.72TRAINS0.60 0.60 0.59 0.54 0.54 0.54 0.53 0.53 0.53 0.53 0.53 0.53 0.53 0.54 0.54SHIPS AND COMMERCIAL BOATS 0.07 0.06 0.07 0.04 0.04 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.04 0.05RECREATIONAL BOATS 0.71 0.79 0.83 0.92 0.97 1.02 1.08 1.14 1.20 1.27 1.33 1.48 1.55 1.70 1.98OFF-ROAD RECREATIONAL VEHICLES 0.05 0.05 0.05 0.05 0.05 0.06 0.06 0.06 0.06 0.07 0.07 0.07 0.07 0.08 0.09OFF-ROAD EQUIPMENT 3.81 3.52 3.41 2.99 2.81 2.64 2.46 2.26 2.07 1.89 1.73 1.43 1.31 1.10 0.91FARM EQUIPMENT 4.03 3.63 3.48 3.03 2.89 2.79 2.64 2.42 2.19 1.99 1.82 1.50 1.34 1.06 0.73FUEL STORAGE AND HANDLING 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Other Mobile Subtotal10.6010.029.859.609.389.279.118.798.478.217.997.617.477.247.02Grand Total94.1688.0186.2284.9585.2382.4682.3782.3682.3482.3882.4882.8082.9983.4484.22121.98 116.94 117.17 113.92 113.84 110.72 110.26109.85 109.48 109.17 108.99 108.94 109.04 109.41110.34Resolution 07-28, Attachment A 18

Technical Modifications to Appendix A, Page 103 of the May 7, 2007 Revised

DraftOn-Road MobileLIGHT DUTY PASSENGER (LDA) 0.26 0.18 0.18 0.17 0.18 0.18 0.19 0.19 0.20 0.20 0.21 0.22 0.22 0.23 0.25LIGHT DUTY TRUCKS - 1 (LDT1) 0.12 0.09 0.09 0.06 0.06 0.06 0.07 0.07 0.07 0.07 0.07 0.08 0.08 0.08 0.09LIGHT DUTY TRUCKS - 2 (LDT2) 0.13 0.11 0.11 0.10 0.11 0.11 0.11 0.12 0.12 0.12 0.12 0.13 0.13 0.14 0.15MEDIUM DUTY TRUCKS (MDV) 0.09 0.09 0.09 0.08 0.09 0.09 0.09 0.09 0.09 0.09 0.10 0.10 0.10 0.10 0.11LIGHT HEAVY DUTY GAS TRUCKS - 1 (LHDV1) 0.02 0.02 0.020.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.03LIGHT HEAVY DUTY GAS TRUCKS - 2 (LHDV2) 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.01 0.01 0.01 0.01MEDIUM HEAVY DUTY GAS TRUCKS (MHDV) 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00HEAVY HEAVY DUTY GAS TRUCKS (HHDV) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00LIGHT HEAVY DUTY DIESEL TRUCKS - 1 (LHDV1) 0.00 0.05 0.04 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00LIGHT HEAVY DUTY DIESEL TRUCKS - 2 (LHDV2) 0.02 0.03 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00MEDIUM HEAVY DUTY DIESEL TRUCKS (MHDV) 0.18 0.23 0.23 0.02 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.04HEAVY HEAVY DUTY DIESEL TRUCKS (HHDV) 1.47 1.76 2.20 0.22 0.23 0.23 0.24 0.24 0.25 0.26 0.27 0.28 0.29 0.31 0.33MOTORCYCLES (MCY) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00HEAVY DUTY DIESEL URBAN BUSES (UB) 0.02 0.03 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00HEAVY DUTY GAS URBAN BUSES (UB) 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00SCHOOL BUSES (SB) 0.02 0.02 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00OTHER BUSES (OB) 0.01 0.01 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00MOTOR HOMES (MH) 0.01 0.01 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00On-Road Subtotal2.362.623.040.710.730.750.770.780.800.820.840.890.910.951.02Other MobileAIRCRAFT0.42 0.45 0.45 0.50 0.51 0.52 0.54 0.54 0.55 0.56 0.57 0.58 0.59 0.60 0.61TRAINS0.68 0.71 0.73 0.07 0.07 0.07 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02SHIPS AND COMMERCIAL BOATS 0.25 0.31 0.33 0.12 0.13 0.08 0.08 0.09 0.09 0.10 0.10 0.12 0.12 0.14 0.16RECREATIONAL BOATS 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01OFF-ROAD RECREATIONAL VEHICLES 0.08 0.06 0.07 0.07 0.08 0.08 0.08 0.09 0.09 0.09 0.10 0.10 0.11 0.11 0.13OFF-ROAD EQUIPMENT 0.46 0.48 0.49 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.06 0.06FARM EQUIPMENT 0.51 0.51 0.51 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05FUEL STORAGE AND HANDLING 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Other Mobile Subtotal2.412.532.580.870.890.860.830.840.860.880.900.930.950.991.05Grand Total3.633.743.792.072.102.062.032.042.062.072.092.122.142.182.2327.14 28.55 29.29 25.6 25.85 26.13 26.41 26.73 27.07 27.4 27.75 28.34 28.65 29.24 30.12Resolution 07-28, Attachment A 19

Technical Modifications to Appendix C, Pages 1-4 of the May 7, 2007 Revised

Draft

Introduction

Sections 110 (a)(1) and (2) of the Clean Air Act re quire states to submit SIPs that implement, maintain, and enforce a new or revised n ational ambient air quality standard within 3 years following promulgation of t he standard. Among the SIP elements identified in Section 110(a)(2) is the req uirement to address the transport of pollutants between states. This secti on also requires states to

ensure that their SIP does not interfere with anoth er state’s program to prevent significant deterioration of its air quality or int erfere with visibility in another state.

In April 2005, the U.S. EPA notified states of thei r failure to make the required SIP submission addressing interstate transport of p ollutants related to ozone and PM2.5. This “failure to submit” finding for the re quired interstate transport SIPs

started a 24-month clock for U.S. EPA to issue a fi nal Federal Implementation Plan (FIP) for any state that does not submit a pla n and receive U.S. EPA approval within that time period.

On August 15, 2006, U.S. EPA issued guidance for su bmitting interstate transport or “Good Neighbor” SIPs. In accordance w ith that guidance, this

document contains docum ents the findings that California meets the requirements of sections 110 (a)(1) and (2) of the Clean Air Act for both the

federal 8-hour ozone standard and the federal PM2.5 standard.

Closest Nonattainment Areas to California

Ozone : The closest 8-hour ozone nonattainment areas are Las Vegas, Nevada,
and Phoenix-Mesa, Arizona.

PM2.5 : The closest PM2.5 nonattainment area is Libby, Mo ntana. Libby is more than 900 miles away from the San Joaquin Valley, th e nearest PM2.5

nonattainment area in California.

Evaluation of significant contribution to nonattain ment or interference with

maintenance of attainment standards in another stat e

U.S. EPA did an analysis for its Clean Air Intersta te Rule or CAIR to identify states that were contributing significantly to nona ttainment of PM2.5 and ozone in adjacent states. In the preamble to that rule, U.S . EPA stated that:

“In analyzing significant contribution to nonattain ment, we

determined it was reasonable to exclude the Western U.S., including the States of Washington, Idaho, Oregon, California

, Nevada, Utah and Arizona from further analysis due to geography, meteorology, and topography. Based on these factor s, we concluded that the PM2.5 and 8-hour ozone nonattain ment problems are not likely to be affected significantl y by pollution transported across these States’ boundaries. There fore, for theResolution 07-28, Attachment A 20 purpose of assessing State’s contributions to nonat tainment in other States, we have only analyzed the nonattainme nt counties

located in the rest of the U.S.” 1 (emphasis added)

The meteorological discussions below provide more d etail.

Ozone : Ozone episodes over the Southwestern United States are normally associated with strong high pressure systems center ed over the Southwest Desert. These meteorological patterns are characte rized by clear skies, warm temperatures, and light winds and result in very st agnant conditions over the region. Ozone is not transported over long distanc es under these conditions. On occasion, the strong high pressure is weakly impact ed by migrating low pressure systems over the Pacific Ocean. This has the dual effect of maintaining stagnant conditions over most of the region while allowing w eak pressure systems to push air that is high above the surface eastward and to transport ozone trapped in this layer over long distances.

PM2.5 : The technical support document for the PM2.5 desig nation of Lincoln County, Montana (containing Libby, Montana) found t hat the nonattainment area is “localized within and around the vicinity of the town of Libby due to topographical features and meteorology in the area impacted by emissions.” Therefore, Libby, Montana’s nonattainment status is not affected by emissions produced in other areas and transported to the Libb y area.

U.S. EPA’s conclusion in CAIR preamble plus the abo ve meteorological summary support the finding that California does no t significantly affect

nonattainment areas in other states.

California’s existing stringent motor vehicle contr ol program, consumer product regulations, stationary source permitting, new sour ce review programs, and new

commitments outlined in the California SIP further strengthened by the 8-hour ozone and PM2.5 SIPs will result in steadily decrea sing emissions. This greatly

reduces the likelihood Even with the occasional possibility of ozone being transported over long distances, California’s air q uality programs greatly reduce

the likelihood that emissions from California will contribute sig nificantly to nonattainment in any downwind state.

1 Rule to Reduce Interstate Transport of Fine Particu late Matter and Ozone (Interstate Air Quality Rule Preamble), 69 FR at 4581, January 30, 2004.Resolution 07-28, Attachment A 21

Evaluation of interference with Prevention of Signi ficant Deterioration Measures of any other State

U.S. EPA guidance 2 for interstate transport SIPs advises states to ma ke a SIP submission to confirm that major sources in the Sta te are currently subject to prevention of significant deterioration (PSD) and n onattainment new source review (NNSR) preconstruction permitting programs t hat apply to the 8-hour

ozone standard.

For the PM2.5 standard, the guidance advises states to provide a SIP submission to confirm that major sources in the Sta te are subject to PSD and NNSR permitting programs implemented in accordance with U.S. EPA’s interim guidance calling for use of PM10 as a surrogate for PM2.5 in the PSD and NNSR

programs.

In California, all areas are subject to some form o f preconstruction program for ozone and PM2.5. These rules are as stringent, or more stringent, than the federal preconstruction programs (PSD and NNSR). F or ozone, California is on track to submit SIPs per the Phase II 8-hour Ozone Implementation Rule. For PM 2.5, California’s preconstruction programs are b eing implemented in accordance with EPA’s interim guidance calling for the use of PM10 as a surrogate for PM2.5 emissions.

The following air districts are in attainment of th e federal 8-hour ozone and PM2.5 standards and have a SIP approved PSD rule.

• Mendocino County Air Pollution Control District

• Monterey Bay Unified Air Pollution Control Distric t

• Northern Sonoma County Air Pollution Control Distr ict

• North Coast Unified Air Quality Management Distric t

• Sacramento Metro Air Quality Management District ( PM2.5)

On a case-by-case basis, U.S. EPA has delegated par tial PSD permitting authority to the following air districts that are i n attainment of the federal 8-hour

ozone and PM2.5 standards.

• Antelope Valley Air Quality Management District

• Bay Area Air Quality Management District

• San Diego Air Pollution Control District

For all other areas that are in attainment of feder al standards, U.S. EPA retains federal PSD permitting authority.

2 Guidance for State Implementation Plan (SIP) Submis sions to Meet Current Outstanding Obligations Under Section 110(a)(2)(D)(i) for the 8 -Hour Ozone and PM2.5 National Ambient Air Quality Standards , memo from William T. Harnett to Regional Air Divi sion Directors dated August 15, 2006, Page 8.Resolution 07-28, Attachment A 22

The following air districts are nonattainment of th e federal 8-hour ozone standard

and have new source review rules or are on track to submit an NSR rules as part of their 8-hour ozone SIP development process. The se rules are or will be equivalent to or more stringent than the federal re quirements.

• Antelope Valley Air Quality Management District (A ntelope Valley and Western Mojave Desert Nonattainment Area)

• Amador County Air Pollution Control District (Cent ral Mountain Counties Nonattainment Area)

• Bay Area Air Quality Management District

• Butte County Air Quality Management District

• Calaveras County Air Pollution Control District (C entral Mountain Counties Nonattainment Area)

• El Dorado County Air Pollution Control District (S acramento Federal Nonattainment Area)

• Feather River Air Quality Management District (Sac ramento Federal Nonattainment Area)

• Imperial Air Pollution Control District

• Kern County Air Pollution Control District (Easter n Kern Nonattainment Area)

• Mariposa County Air Pollution Control District (So uthern Mountain Counties Nonattainment Area)

• Mojave Desert Air Pollution Control District (Ante lope Valley and Western Mojave Desert Nonattainment Area)

• Northern Sierra Air Quality Management District (W estern Nevada County Nonattainment Area)

• Placer County Air Pollution Control District (Sacr amento Federal Nonattainment Area)

• Sacramento Metropolitan Air Quality Management Dis trict (Sacramento Federal Nonattainment Area)

• San Joaquin Valley Unified Air Pollution Control D istrict

• South Coast Air Quality Management District

• Tuolumne County Air Pollution Control District (So uthern Mountain Counties Nonattainment Area)

• Ventura County Air Pollution Control District

• Yolo Solano Air Quality Management District (Sacra mento Federal Nonattainment Area)

The following air districts are nonattainment of th e federal PM2.5 standard and already have NSR rules in place for PM10. These ru les are equivalent to or more stringent than the federal requirements.

• South Coast Air Quality Management District

• San Joaquin Valley Unified Air Pollution Control D istrictResolution 07-28, Attachment A 23

Technical Modifications to Appendix D, Page 2 of the May 7, 2007 Revised

Draft

For RFP, nonattainment areas classified serious and above must demonstrate an 18 percent reduction in ROG and/or NOx emissions fr om the 2002 baseline ROG inventory by 2008. In the years that follow, they must demonstrate, on average, an additional 3 percent per year reduction in ROG a nd/or NOx emissions until their attainment year. Serious areas are: San Joaqu in Valley, Coachella Valley and Sacramento. Note that for the reasons given ab ove, Coachella Valley is subject to a 15 percent ROG-only reduction requirem ent from 2002 to 2008. The

South Coast Air Basin is classified as severe.

For moderate and above 8-hour ozone nonattainment a reas, a limited amount of NOx reductions may also be used, to a point, as a s ubstitution for ROG

reductions for RFP. NOx emission reductions credit able toward the RFP requirement cannot be greater than the cumulative N Ox reductions that are necessary to demonstrate attainment. This attainme nt consistency requirement is meant to prevent the substitution of NOx reducti ons for progress purposes that would not lead toward attaining the ozone standard.

U.S. EPA has taken the position in guidance, and no t in regulation, that for nonattainment areas classified under Subpart 2, red uctions needed for progress in the attainment year should equate to those neede d for attainment. ARB staff disagrees. We believe a plain reading of the Act i ndicates that a 3 percent reduction per year is needed between the next-to-la st milestone year and the attainment year. For example, in a severe-15 area, the next-to-last milestone year is 2017 and the attainment year is 2018. A 45 percent reduction is needed in 2017 for RFP. Therefore, the RFP requirement fo r the next year (2018) is three percent more, or 48 percent – and not the red uctions needed for

attainment.

Upwind Emissions in RFP Demonstrations

Ozone levels are influenced by ROG and NOx emitted both within a nonattainment area and transported from upwind loca tions. U.S. EPA acknowledges this relationship by allowing emission reductions from upwind

locations outside the nonattainment area to be incl uded for RFP, up to 100

kilometers for ROG and 200 kilometers for NOx.

The inclusion of transport contributions of ROG and NOx provides key emission reductions in RFP analyses for the following nonatt ainment areas: Antelope Valley and Western Mojave Desert, Central Mountain Counties, Coachella Valley, Eastern Kern, Southern Mountain Counties an d Western Nevada. Their emission inventories for RFP purposes include ROG a nd NOx emissions from counties that are (1) entirely within the designate d 100km and 200km distances, and (2) part of the area’s established federa lly Board -approved transport couples.

Federal Motor Vehicle Control Program Adjustments