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 California’s 

2007 State Implementation Plan 

and 

May 7, 2007 Revised Draft Appendices A through G
Resolution 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 Revised 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 Draft: 

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

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

2. Page 23. Adds reference to federal Bureau of Land Management. 

3. Page 27. Makes a clarifying change describing SOx reductions from 

petroleum refining. 

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

5. Page 31. Corrects pesticide inventory numbers in 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 and U.S. EPA’s authority to 

control mobile sources. 

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

control mobile sources. 

8. Page 67. Adds clarifying language about ARB’s and 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 Draft: Appendices A through H 

1. Appendix A, Page 100. Corrects a summation error for PM2.5 grand total 

numbers for the San Joaquin Valley. 

2. Appendix A, Page 103. Corrects a summation error for SOx grand total 

numbers for the San Joaquin Valley. 

3. Appendix C, Pages 1-4. Interstate Transport. Adds clarifying language to 

long-distance transport, clarifies district headings and make other wording 

clarifications. 

4. Appendix D, Page 2. Deletes reference to federally-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 commitments are described in 

Chapter 3. Individual measures are described in more detail in Chapter 5. The 

figure below shows the decrease in emissions for passenger 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 on a downward trend, despite 

growth in population, travel, and the economy. The new measures in the 

proposed State Strategy would accelerate these emissions reductions. ARB staff 

is proposing an aggressive new emission reduction commitment 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 construction equipment that show 

substantial emission decreases with natural fleet turnover, locomotives and ships 

show an increase in emissions without the proposed State Strategy. Locomotive 

emissions have been decreasing in the South Coast due to the accelerated 

introduction of the cleanest current technology (Tier 2). However, as shown 

below, growth overtakes this benefit by 2014. The proposed State Strategy 

includes a measure to accelerate introduction of the next generation of clean 

technology once U.S. EPA adopts its proposed new Tier 4 standards. The 2014 

benefits assume Tier 4 engines becoming available in 2012. The 70 percent 

reduction projected for 2020 is based on the proposed 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 designed to ensure air quality 

standards throughout the entire region, so achieving 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 justice program, ARB has initiated air 

quality studies in several communities and continues to focus resources on 

mobile source enforcement in environmental justice communities. ARB’s Air 

Quality and Land Use Handbook, approved by ARB in May 2005, provides 

guidance to help improve local land use decisions that can negatively impact 

public health at the community level. 

ARB’s SIP strategies have a significant nexus to community 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 buildings and highways and move 

our goods are not well controlled and have very long lives. Adopting rules to 

clean up these fleets will have an immediate and significant effect on the 

communities where these sources are concentrated. 

Regional Haze 

The same particulate air pollutants that affect public health also extinguish and 

scatter light, thereby obscuring visibility. The federal Clean Air Act set the farreaching goal of achieving natural visibility conditions 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 reduce controllable emissions of 

particulates so that regional haze is reduced in the western region of the country. 

In 1999, the U.S. Environmental Protection Agency published rules to guide the 

preparation of Regional Haze State Implementation Plans 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 deadline. General trends in 

California since the 1990s show that emission controls are improving visibility in 

our parks and wilderness areas. The regional haze plan will show how these 

controls constitute reasonable progress along the path to natural visibility. In 

2012, ARB will conduct a mid-course review of measured visibility changes and 

analyze how emission reductions implemented to achieve the 8-hour ozone and 

the PM2.5 standards will move the State further along 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 mobile source category of 

ships and commercial boats. Evaporative losses from 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 inventory 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 paved and unpaved roads, 

residential fireplaces, cooking and fuel combustion; and particle emissions from 

diesel-fueled engines on trucks, ships, and construction equipment. While soot 

from diesel engines is not a major portion of the entire 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 two independent variables: 

growth and control. Different methods are used to estimate the future growth of 

emission sources based on their type. And future emission controls are 

incorporated into the projected emissions for each source category based on 

when the controls are implemented, how much the controls reduce emissions, 

and how many units (vehicles, consumer products, etc.) are affected. 

The charts on the next page show the change in total projected statewide 

emissions for NOx, ROG, and SOx from 2006 to 2023 and 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 2007). For example, SOx 

emissions as a category continue to grow due to ship emission increases. This 

makes ship SOx emissions a high priority for control in the new SIP strategy. 

NOx and ROG emissions are decreasing as a result of existing control programs 

despite substantial growth in population, travel, and the economy. 

ARB uses two computer models to simulate and forecast emissions for on- and 

off-road sources. For cars, sport utility vehicles, minivans, and trucks, ARB used 

EMFAC2007. For off-road vehicles and equipment, ARB used OFFROAD2007. 

Both models were released for public use in November 2006 after a multi-year 

development process. As required by federal guidance, EMFAC2007 uses the 

latest fleet information for vehicles age and population. The data is developed 

from the California Department of Motor Vehicle registration data through 2005. 

For SIP purposes, as required by State law, vehicle activity is based on local 

transportation agency projections, or California Department 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 the emissions inventory for 

these two areas: 

• South Coast NOx emissions are significantly impacted by goods movement, 

with the ships, trains, trucks, and off-road equipment that move goods 

contributing about 30 percent of all South Coast NOx emissions. Aircraft NOx 

emissions are also increasing. 

• The impact of goods movement in the San Joaquin Valley 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 emissions from mobile 

sources decline in the future. 

• The large population in the South Coast is the main reason why consumer 

product emissions are projected to become the number 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 heavy-duty truck NOx 

emissions about 70 percent in the San Joaquin Valley and South Coast by 

2023, but they need to be cut even more by new strategies 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 NOx, in future years as 

emission increases due to growth overwhelm the existing control program, 

while emissions of mobile sources under State jurisdiction 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 12 

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 State 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 emission reductions necessary 

to meet federal air quality standards. The two main emission reduction 

components of the State Strategy are the adopted SIP measures and proposed 

new measures. The adopted SIP measures include those adopted through 

2006. Proposed new measures include those to be adopted after 2006. 

Responsibility for implementing emission reduction measures is shared between 

the agencies with primary responsibility for controlling air pollution in California: 

the Air Resources Board, 35 local air pollution control and air quality 

management districts, and the U.S. Environmental Protection Agency. However, 

given the current status of statewide emissions, ARB 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 controlling emissions from 

stationary and areawide sources (with the exception of consumer products) 

through rules and permitting programs. Examples include industrial sources like 

factories, refineries, and power plants; commercial sources like gas stations, dry 

cleaners, and paint spray booth operations; residential sources like fireplaces, 

water heaters, and house paints; and miscellaneous non-mobile sources like 

emergency generators. Districts also inspect and test fuel vapor recovery 

systems to check that such systems are operating as certified. 

State Measures 

ARB is responsible for controlling emissions from mobile sources (except where 

federal law preempts ARB’s authority) and consumer products, developing fuel 

specifications, establishing gasoline vapor recovery 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 Automotive Repair runs the State’s 

Smog Check programs to identify and repair polluting cars. 

Federal Measures 

U.S. EPA has the authority to control emissions from certain mobile sources, 

including sources all or partly under exclusive federal jurisdiction (like interstate 

trucks, some farm and construction equipment, aircraft, 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 programs 
Resolution 07-28, Attachment A 11 

as they relate to the federal Clean Air Act. International 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 day of direct PM2.5 in the 

South Coast by 2014. 

 Ships

Emissions from ocean-going vessels, unlike most major pollution sources, are 

not projected to decrease in future years, since ships 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 two decades. Ships currently 

emit half the statewide SOx emissions, and it is estimated 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 entering our ports and when they 

are docked through application of demonstrated control 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 ships in December 2005 by 

adopting a rule phasing in the use of cleaner low-sulfur fuel in ship auxiliary 

engines that will reduce SOx emissions from auxiliary 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 through cold ironing and other 

clean technology. Cold ironing allows ships to turn off their auxiliary engines and 

instead plug into an electrical system for power when they are docked at a port. 

This measure would phase in the number of ships capable 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 estimated 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 from ship main engines 

through a variety of measures. A main engine fuel rule, patterned after the 

auxiliary engine fuel rule, would help reduce emissions by introducing a cleaner, 

low-sulfur fuel beginning no later than 2010. Increasing the use of cleaner new 

engines or retrofitted engines beginning in 2010 could be implemented via 

regulation, incentives, voluntary agreements, or a combination of these 

approaches. Higher ship speeds cause much higher emissions. So a measure 

is proposed that would strengthen a current voluntary program by requiring ships 

to reduce their speeds to 12 knots within 40 nautical miles of the Ports of Los 

Angeles and Long Beach. The combination of ship main engine measures would 

reduce both NOx and SOx emissions by 20 tons per day and direct PM2.5 

emissions by over 2 tons per day in 2014. These reductions 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 improved air quality in the face of 

tremendous economic and population growth. The vast majority of that progress 

has come from effective regulations. Accordingly, ARB staff expects State and 

federal regulations to play the primary role in implementing the State Strategy. In 

the regulatory paradigm, polluting sources pay for the necessary emission 

controls as part of doing business. Regulated industries may pass these costs 

on to consumers in the form of higher prices, although competition and other 

factors may prevent some companies from recouping all of their control costs. 

Low-interest loans with extended payment periods are available to aid smaller 

businesses that need upfront capital to comply. 

In recent years, regulatory programs have been supplemented 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 requirements. Most of the 

existing incentive programs are designed to pay for the incremental cost between 

what is required by regulation and advanced technology that exceeds that level. 

The incentive programs are publicly funded through fees paid by California 

vehicle owners as part of their annual registrations, 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 Governor Schwarzenegger, the 

Legislature, and California’s voting public is reflected in the passage on 

November 7, 2006, of the Highway Safety, Traffic Reduction, Air Quality, and 

Port Security Bond Act of 2006. The Bond Act includes $1 billion to accelerate 

the cleanup of air pollution caused by goods movement 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 government to develop more stringent 

emission standards and to ensure these standards go into effect as soon as 

possible. Emission reductions from locomotives, off-road equipment, marine 

auxiliary engines, and harbor craft are a significant part of the State Strategy. 

Proposed State measures would accelerate the introduction 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 exclusive, authority to 

establish new engine emission standards for these sources. 
Resolution 07-28, Attachment A 14 

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

enforce emission standards for some non-road mobile sources. However, it is 

not likely that ARB could consult with affected parties, develop and adopt 

regulations, and secure U.S. EPA approval to enact the regulations in time to 

ensure that resulting cleaner engines will be widely available by 2014. 

Therefore, Mmeasures in the State Strategy to reduce emissions from interstate 

and international sources rely on the federal government to develop more 

stringent emission standards and to ensure these standards go into effect as 

soon as possible. 

ARB is proposing several measures to reduce ship emissions through a 

combination of regulations, incentives, and actions by ports and the private 
Resolution 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 sources by 2020, are 

unaddressed in the State Strategy due to the lack of 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 adoption 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 standards for sources that it can 

regulate under its control, keeping in mind California’s air quality challenge and 

attainment deadlines. There are categories of emission 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 greater and faster emission 

reductions than otherwise would be possible with only State action. Not only 

would federal action lower emissions for new sources, 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 engines and technology into 

California fleets. These sources include: ships, locomotives, 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 promoting the manufacture, sale, and 

purchase of cleaner vehicles, equipment, and technology, 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 quality 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 2020 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 

On-Road Mobile LIGHT DUTY PASSENGER (LDA) 0.77 0.77 0.78 0.80 0.83 0.86 0.89 0.90 0.92 0.93 0.9LIGHT DUTY TRUCKS - 1 (LDT1) 0.27 0.27 0.27 0.27 0.28 0.28 0.29 0.29 0.30 0.30 0.3LIGHT DUTY TRUCKS - 2 (LDT2) 0.54 0.65 0.66 0.68 0.71 0.74 0.77 0.79 0.81 0.82 0.8MEDIUM DUTY TRUCKS (MDV) 0.24 0.35 0.35 0.37 0.39 0.41 0.43 0.44 0.46 0.47 0.4LIGHT HEAVY DUTY GAS TRUCKS - 1 (LHDV1) 0.04 0.04 0.04 0.04 0.04 0.05 0.05 0.05 0.05 0.05 0.0LIGHT HEAVY DUTY GAS TRUCKS - 2 (LHDV2) 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.0MEDIUM HEAVY DUTY GAS TRUCKS (MHDV) 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.0HEAVY 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 0.0LIGHT 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 0.0LIGHT 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 0.0MEDIUM 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 0.4HEAVY 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 5.0MOTORCYCLES (MCY) 0.02 0.04 0.04 0.04 0.04 0.04 0.03 0.03 0.03 0.03 0.0HEAVY 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 0.0HEAVY DUTY GAS URBAN BUSES (UB) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0SCHOOL BUSES (SB) 0.08 0.09 0.09 0.09 0.09 0.10 0.10 0.10 0.10 0.10 0.1OTHER BUSES (OB) 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.0MOTOR HOMES (MH) 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.0

On-Road Subtotal 11.56 12.05 13.86 11.70 11.23 10.74 10.27 9.77 9.28 8.81 8.3

Other MobileAIRCRAFT 1.33 1.36 1.43 2.02 2.08 2.19 2.31 2.35 2.39 2.44 2.4TRAINS 0.60 0.60 0.59 0.54 0.54 0.54 0.53 0.53 0.53 0.53 0.5SHIPS AND COMMERCIAL BOATS 0.07 0.06 0.07 0.04 0.04 0.03 0.03 0.03 0.03 0.03 0.0RECREATIONAL BOATS 0.71 0.79 0.83 0.92 0.97 1.02 1.08 1.14 1.20 1.27 1.3OFF-ROAD RECREATIONAL VEHICLES 0.05 0.05 0.05 0.05 0.05 0.06 0.06 0.06 0.06 0.07 0.0OFF-ROAD EQUIPMENT 3.81 3.52 3.41 2.99 2.81 2.64 2.46 2.26 2.07 1.89 1.7FARM EQUIPMENT 4.03 3.63 3.48 3.03 2.89 2.79 2.64 2.42 2.19 1.99 1.8FUEL STORAGE AND HANDLING 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0

Other Mobile Subtotal 10.60 10.02 9.85 9.60 9.38 9.27 9.11 8.79 8.47 8.21 7.9

Grand Total 94.16 88.01 86.22 84.95 85.23 82.46 82.37 82.36 82.34 82.38 82.4

121.98 116.94 117.17 113.92 113.84 110.72 110.26 109.85 109.48 109.17 108.9
Resolution 07-28, Attachment A 18 

On-Road Mobile LIGHT 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 LIGHT 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 LIGHT 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 MEDIUM 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 LIGHT HEAVY DUTY GAS TRUCKS - 1 (LHDV1) 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02 LIGHT HEAVY DUTY GAS TRUCKS - 2 (LHDV2) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 MEDIUM HEAVY DUTY GAS TRUCKS (MHDV) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 HEAVY 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 LIGHT 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 LIGHT 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 MEDIUM 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 HEAVY 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 MOTORCYCLES (MCY) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 HEAVY 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 HEAVY DUTY GAS URBAN BUSES (UB) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 SCHOOL BUSES (SB) 0.02 0.02 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 OTHER BUSES (OB) 0.01 0.01 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 MOTOR HOMES (MH) 0.01 0.01 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

On-Road Subtotal 2.36 2.62 3.04 0.71 0.73 0.75 0.77 0.78 0.80 0.82 0.84 

Other MobileAIRCRAFT 0.42 0.45 0.45 0.50 0.51 0.52 0.54 0.54 0.55 0.56 0.57 TRAINS 0.68 0.71 0.73 0.07 0.07 0.07 0.02 0.02 0.02 0.02 0.02 SHIPS 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 RECREATIONAL BOATS 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 OFF-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 OFF-ROAD EQUIPMENT 0.46 0.48 0.49 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 FARM EQUIPMENT 0.51 0.51 0.51 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 FUEL 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 

Other Mobile Subtotal 2.41 2.53 2.58 0.87 0.89 0.86 0.83 0.84 0.86 0.88 0.90 

Grand Total 3.63 3.74 3.79 2.07 2.10 2.06 2.03 2.04 2.06 2.07 2.09 

27.14 28.55 29.29 25.6 25.85 26.13 26.41 26.73 27.07 27.4 27.75 2
Resolution 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 require states to submit SIPs that 

implement, maintain, and enforce a new or revised national ambient air quality 

standard within 3 years following promulgation of the standard. Among the SIP 

elements identified in Section 110(a)(2) is the requirement to address the 

transport of pollutants between states. This section also requires states to 

ensure that their SIP does not interfere with another state’s program to prevent 

significant deterioration of its air quality or interfere with visibility in another state. 

In April 2005, the U.S. EPA notified states of their failure to make the required 

SIP submission addressing interstate transport of pollutants related to ozone and 

PM2.5. This “failure to submit” finding for the required interstate transport SIPs 

started a 24-month clock for U.S. EPA to issue a final Federal Implementation 

Plan (FIP) for any state that does not submit a plan and receive U.S. EPA 

approval within that time period. 

On August 15, 2006, U.S. EPA issued guidance for submitting interstate 

transport or “Good Neighbor” SIPs. In accordance with that guidance, this 

document contains documents 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, Montana. Libby is more 

than 900 miles away from the San Joaquin Valley, the nearest PM2.5 

nonattainment area in California. 

Evaluation of significant contribution to nonattainment or interference with 

maintenance of attainment standards in another state 

U.S. EPA did an analysis for its Clean Air Interstate Rule or CAIR to identify 

states that were contributing significantly to nonattainment of PM2.5 and ozone in 

adjacent states. In the preamble to that rule, U.S. EPA stated that: 

“In analyzing significant contribution to nonattainment, 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 factors, we 

concluded that the PM2.5 and 8-hour ozone nonattainment 

problems are not likely to be affected significantly by pollution 

transported across these States’ boundaries. Therefore, for the 
Resolution 07-28, Attachment A 20 

purpose of assessing State’s contributions to nonattainment in 

other States, we have only analyzed the nonattainment counties 

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

The meteorological discussions below provide more detail. 

Ozone: Ozone episodes over the Southwestern United States are normally 

associated with strong high pressure systems centered over the Southwest 

Desert. These meteorological patterns are characterized by clear skies, warm 

temperatures, and light winds and result in very stagnant conditions over the 

region. Ozone is not transported over long distances under these conditions. On 

occasion, the strong high pressure is weakly impacted 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 weak 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 designation of Lincoln 

County, Montana (containing Libby, Montana) found that 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 Libby area. 

U.S. EPA’s conclusion in CAIR preamble plus the above meteorological 

summary support the finding that California does not significantly affect 

nonattainment areas in other states. 

California’s existing stringent motor vehicle control program, consumer product 

regulations, stationary source permitting, new source 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 decreasing emissions. This greatly 

reduces the likelihood Even with the occasional possibility of ozone being

transported over long distances, California’s air quality programs greatly reduce 

the likelihood that emissions from California will contribute significantly to 

nonattainment in any downwind state. 

 

1 Rule to Reduce Interstate Transport of Fine Particulate 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 Significant Deterioration 

Measures of any other State 

U.S. EPA guidance2

 for interstate transport SIPs advises states to make a SIP 

submission to confirm that major sources in the State are currently subject to 

prevention of significant deterioration (PSD) and nonattainment new source 

review (NNSR) preconstruction permitting programs that 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 State 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 of preconstruction program for 

ozone and PM2.5. These rules are as stringent, or more stringent, than the 

federal preconstruction programs (PSD and NNSR). For 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 being 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 the 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 District 

• Northern Sonoma County Air Pollution Control District 

• North Coast Unified Air Quality Management District 

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

On a case-by-case basis, U.S. EPA has delegated partial PSD permitting 

authority to the following air districts that are in 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 federal standards, U.S. EPA retains 

federal PSD permitting authority. 

 

2 Guidance for State Implementation Plan (SIP) Submissions 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 Division Directors dated August 

15, 2006, Page 8. 
Resolution 07-28, Attachment A 22 

The following air districts are nonattainment of the 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. These rules are or will be 

equivalent to or more stringent than the federal requirements. 

• Antelope Valley Air Quality Management District (Antelope Valley and 

Western Mojave Desert Nonattainment Area) 

• Amador County Air Pollution Control District (Central Mountain 

Counties Nonattainment Area) 

• Bay Area Air Quality Management District 

• Butte County Air Quality Management District 

• Calaveras County Air Pollution Control District (Central Mountain 

Counties Nonattainment Area) 

• El Dorado County Air Pollution Control District (Sacramento Federal 

Nonattainment Area) 

• Feather River Air Quality Management District (Sacramento Federal 

Nonattainment Area)

• Imperial Air Pollution Control District 

• Kern County Air Pollution Control District (Eastern Kern Nonattainment 

Area) 

• Mariposa County Air Pollution Control District (Southern Mountain 

Counties Nonattainment Area) 

• Mojave Desert Air Pollution Control District (Antelope Valley and 

Western Mojave Desert Nonattainment Area) 

• Northern Sierra Air Quality Management District (Western Nevada 

County Nonattainment Area) 

• Placer County Air Pollution Control District (Sacramento Federal 

Nonattainment Area) 

• Sacramento Metropolitan Air Quality Management District 

(Sacramento Federal Nonattainment Area) 

• San Joaquin Valley Unified Air Pollution Control District 

• South Coast Air Quality Management District 

• Tuolumne County Air Pollution Control District (Southern Mountain 

Counties Nonattainment Area) 

• Ventura County Air Pollution Control District 

• Yolo Solano Air Quality Management District (Sacramento Federal 

Nonattainment Area) 

The following air districts are nonattainment of the federal PM2.5 standard and 

already have NSR rules in place for PM10. These rules are equivalent to or 

more stringent than the federal requirements. 

• South Coast Air Quality Management District 

• San Joaquin Valley Unified Air Pollution Control District 
Resolution 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 from 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 and/or NOx emissions until 

their attainment year. Serious areas are: San Joaquin Valley, Coachella Valley 

and Sacramento. Note that for the reasons given above, Coachella Valley is 

subject to a 15 percent ROG-only reduction requirement from 2002 to 2008. The 

South Coast Air Basin is classified as severe. 

For moderate and above 8-hour ozone nonattainment areas, a limited amount of 

NOx reductions may also be used, to a point, as a substitution for ROG 

reductions for RFP. NOx emission reductions creditable toward the RFP 

requirement cannot be greater than the cumulative NOx reductions that are 

necessary to demonstrate attainment. This attainment consistency requirement 

is meant to prevent the substitution of NOx reductions for progress purposes that 

would not lead toward attaining the ozone standard.

U.S. EPA has taken the position in guidance, and not in regulation, that for 

nonattainment areas classified under Subpart 2, reductions needed for progress 

in the attainment year should equate to those needed for attainment. ARB staff 

disagrees. We believe a plain reading of the Act indicates that a 3 percent 

reduction per year is needed between the next-to-last 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 for the next year (2018) is 

three percent more, or 48 percent – and not the reductions 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 locations. U.S. EPA 

acknowledges this relationship by allowing emission reductions from upwind 

locations outside the nonattainment area to be included 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 nonattainment areas: Antelope 

Valley and Western Mojave Desert, Central Mountain Counties, Coachella 

Valley, Eastern Kern, Southern Mountain Counties and Western Nevada. Their 

emission inventories for RFP purposes include ROG and NOx emissions from 

counties that are (1) entirely within the designated 100km and 200km distances, 

and (2) part of the area’s established federally Board-approved transport 

couples. 

Federal Motor Vehicle Control Program Adjustments