San Joaquin Valley Unified Air Pollution Control District December 20, 2012

Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

Chapter 9

Attainment 

Demonstration, 

RACM, RFP, and 

Contingency 

Measures

2012 PM2.5 Plan

SJVUAPCD
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

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San Joaquin Valley Unified Air Pollution Control District December 20, 2012

9-1 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency 

Measures

The District’s multi-faceted control strategy will achieve expeditious attainment Valleywide. Kern County is expected to be the last portion of the San Joaquin Valley air basin 

(Valley) to attain the 24-hour PM2.5 standard, with attainment in 2019. This chapter 

shows that this plan satisfies federal PM2.5 plan requirements for attainment,

reasonably available control measures (RACM), reasonable further progress (RFP), and 

contingency measures. 

9.1 ATTAINMENT OUTLOOK

Initial attainment deadlines for PM2.5 are five years from the effective date of the 

nonattainment designation, though up to a five year extension is available. This sets

the initial attainment date for the federal 24-hour PM2.5 standard (National Ambient Air 

Quality Standard, or NAAQS) at December 14, 2014, with an extension up to December 

14, 2019, if needed. EPA has clarified that for an attainment date of December 14, 

2014, air monitoring data collected in calendar years 2012 through 2014 would be used 

to determine whether the area has reached attainment.1 December 14, 2019 

attainment would then be based on air monitoring data collected in calendar years 2017 

through 2019. To be granted an extension, an area must show that it cannot attain by 

2014, but will attain as expeditiously as possible, no later than 2019.

Photochemical modeling and other technical analyses for this plan establish an 

emissions level at which the Valley would attain the federal 24-hour PM2.5 standard. 

Attaining the federal PM2.5 standard is extremely challenging, particularly in the 

southern Valley, and will require tremendous reductions in emissions. Given the 

significant contribution of ammonium nitrate to the Valley’s PM2.5 concentrations, 

reductions in NOx emissions are particularly important. To achieve the NOx reductions 

critical for reaching attainment in the Valley, ARB has adopted regulations that will 

significantly reduce NOx emissions from various mobile sources. Achieving this level of 

emissions reductions requires adequate time and carries a tremendous cost. These 

reductions are ultimately achieved in time to bring most of the Valley into attainment 

well before 2019, with the exception of Bakersfield.

All areas of the Valley will attain the standard in 2019 with the regulatory controls in this 

plan (see Chapter 5). In particular, Kern County is projected to be the last portion of the 

Valley to attain, and is thus the area with the most need for additional emissions 

reductions through this plan. Table 9-1 shows that the 2019 emissions target would not 

be achieved in Kern County prior to 2019. In order for Bakersfield to attain a year 

earlier by 2018, an additional 2.1 tons per day of NOx reductions would be needed in 

 

1 U.S. Environmental Protection Agency (2012, March 2). Memorandum from the Office of Air Quality Planning and 

Standards: Implementation Guidance for the 2006 24-Hour Fine Particle (PM2.5) National Ambient Air Quality 

Standards (NAAQS). Pages 14-15. Retrieved from 

http://www.epa.gov/ttn/naaqs/pm/pdfs/20120302_implement_guidance_24-hr_pm2.5_naaqs.pdf
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9-2 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

Kern County. To put this in perspective, achieving this level of emissions reductions is 

equivalent to virtually eliminating all passenger vehicles in Kern County in 2018. 

The District’s “no stone unturned” evaluation of emissions sources and emissions 

controls did not reveal any additional reasonably available emissions reductions 

opportunities that could expedite attainment, with all new control strategies scheduled 

for implementation by 2017. There are no unused control strategies available that could 

achieve the reductions necessary to accelerate attainment, because every reasonable 

control measure is already included in the plan (discussed further in Section 9.5). Thus, 

the modeled emissions targets cannot be achieved before 2019, and 2019 is the most 

expeditious attainment year available.

This 2012 PM2.5 Plan demonstrates that the Valley will attain the federal 24-hour 

PM2.5 standard as expeditiously as possible, with all feasible measures and strategies 

being implemented to accomplish this goal. The non-regulatory control measures not 

credited in the attainment demonstration are achieving actual emissions reductions in 

the Valley. The District will continue to reduce emissions wherever possible to expedite 

air quality improvements Valley-wide. 

Table 9-1 Kern County Attainment Outlook

Ref#

2007 

base 

year

2014 2015 2016 2017 2018 2019

1

Winter PM2.5 emissions 

inventory, reflecting adopted 

control measures

15.4 11.8 11.5 11.4 11.4 11.4 11.4

2

New control measure 

commitments (Table 9-1) 0 0 0.1 0.3 0.3 0.3

3

Winter PM2.5 emissions 

inventory reflecting full 

plan control strategy (Line 

1 – Line 2)

11.8 11.5 11.3 11.1 11.1 11.1

4 Direct PM2.5 Attainment Target 11.1

5

Winter NOx emissions 

inventory, reflecting full plan 

control strategy 

115.4 63.8 58.6 54.5 51.5 48.9 46.8

6 NOx Attainment Target 46.8

7

Winter SOx emissions 

inventory, reflecting full plan 

control strategy 

3.6 1.8 1.8 1.8 1.8 1.8 1.8

8 SOx Attainment Target 1.8

Attainment? No No No No No Yes

Projected attainment year 2019
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9-3 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

9.2 REASONABLY AVAILABLE CONTROL MEASURES (RACM)

Table 9-1 shows that sufficient emissions reductions will be achieved for the Valley to 

reach attainment in 2019. A PM2.5 attainment plan must also demonstrate 

implementation of RACM (reasonably available control measures): the collection of 

reasonable emissions reductions that, taken as a group, advance attainment of an air 

quality standard by at least one year. Put another way, the total of all potential 

emissions reductions opportunities that are not included as plan commitments must not 

advance attainment by one year. Measures that are not necessary to satisfy 

Reasonable Further Progress (RFP) or expeditious attainment are also not required 

RACM for the area. 

To advance attainment by at least one year, the collective emissions reductions that 

could be achieved through unused but reasonably available controls would have to 

achieve the 2019 emissions levels by 2018 in Kern County. Per the District’s Riskbased Strategy, through which the District prioritizes public health benefits in its 

attainment control strategy, the District is adopting its new rule amendments to reduce 

directly-emitted PM2.5 to achieve the necessary PM2.5 reductions by 2017, in advance 

of the 2019 attainment year. Similarly, the SOx emissions level needed for attainment 

is being achieved by 2014. 

Advancing attainment by one year would thus depend on expediting NOx reductions. 

However, many NOx emissions are being reduced as adopted regulations are fully 

implemented through fleet turn-over and normal equipment replacement. In fact, as 

demonstrated in Appendix B, 92% of NOx reductions from the 2007 base emission 

inventory to attainment in 2019 come from mobile sources. These reductions cannot be 

expedited through additional stationary and area source regulations, for which the 

District has regulatory authority. Based on the difference between 2018 and 2019 NOx 

emissions levels shown in Table 9-2, unused control measures would have to achieve 

2.1 tons per day (tpd) of NOx reductions in Kern County to advance attainment by one 

year. However, as previously discussed, there are no unused control measures in this 

plan because every reasonable control measure is used in this plan. 

RACM are, by definition, reasonable. Although an air quality attainment plan must 

include a thorough analysis of reasonably available measures, it need not analyze every 

conceivable measure; reasonability must drive the analysis. Any measure that is 

absurd, unenforceable, impractical, or would cause severely disruptive socioeconomic 

impacts is unreasonable.

This analysis must consider all agencies’ opportunities together, but the starting point is 

the separate analyses of each agency:

 District: as discussed in Appendix D, and Chapter 5, all reasonable control 

measures under the District’s jurisdiction are being implemented. The District 

has adopted many of the toughest stationary and area sources rules in the 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

9-4 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

nation. There are no reasonable regulatory control measures excluded from use 

in this plan; therefore, there are no emissions reductions associated with unused 

regulatory control measures. 

 ARB: as discussed in Appendix C, all reasonable control measures under ARB’s 

jurisdiction for mobile sources are being implemented. Given the significant 

emission reductions needed for attainment in California, ARB has adopted some 

of the most stringent control measures nationwide for on-road and off-road 

mobile sources and the fuels that power them. There are no reasonable 

regulatory control measures excluded from use in this plan; therefore, there are 

no emissions reductions associated with unused regulatory control measures.

 Metropolitan Planning Organizations (MPOs): as discussed in Appendix C, all 

reasonable control measures under MPO jurisdiction are being implemented. 

There are no reasonable regulatory control measures excluded from use in this 

plan; therefore, there are no emissions reductions associated with unused 

regulatory control measures.

There are no reasonable regulatory control measures from any agency’s jurisdiction that 

have been excluded from use in this plan; therefore, there are no emissions reductions 

associated with unused regulatory control measures. The District also considered 

whether ammonia emissions reductions could expedite attainment. Based on 2018 

emissions and analysis conducted for this plan, the District estimates the 2018 design 

value for Bakersfield-California is at least 1 μg/m3 higher than the attainment level. It 

would therefore take at least 125 tons of additional ammonia emissions reductions to 

advance attainment by one year. As discussed in Chapter 5, this is an infeasible 

amount of emissions reductions for ammonia, since there are no control strategies that 

exist or have been identified which could achieve such large reductions.

9.3 REASONABLE FURTHER PROGRESS (RFP)

Clean Air Act (Act) Section 171(1) defines reasonable further progress (RFP) as 

incremental emission reductions leading to the attainment date. EPA’s interpretation of 

the RFP requirement for federal PM2.5 standards is “generally linear progress” from the

base year to the attainment year, demonstrated at RFP milestone years.2 “Generally 

linear progress” is calculated in an exactly linear fashion. 

This plan identifies 2019 as the most expeditious attainment date practicable in the San 

Joaquin Valley, with a baseline year of 2007. For the federal 24-hour PM2.5 standard, 

the RFP milestone years are 2014 and 2017. 3 RFP is demonstrated for the 

 

2

72 FR 20633, codified at 40 CFR 51 Subpart Z Section 51.1000 (Definitions)

3 U.S. Environmental Protection Agency (2012, March 2). Memorandum from the Office of Air Quality Planning and 

Standards: Implementation Guidance for the 2006 24-Hour Fine Particle (PM2.5) National Ambient Air Quality 

Standards (NAAQS). Page 16. Retrieved from 

http://www.epa.gov/ttn/naaqs/pm/pdfs/20120302_implement_guidance_24-hr_pm2.5_naaqs.pdf
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9-5 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

nonattainment area as a whole. RFP requirement targets and attainment 

demonstrations are as follows: 

1. Determine the Emissions Inventory of the Valley with the Plan control strategy for 

the baseline year, the RFP years, and the attainment year. 

Table 9-2 Emissions Inventory with Plan Control Strategy (tpd)

Description 2007 2014 2017 2019

Direct PM2.5

Emission Inventory (Table B-1) 87.1 64.4 63.5 64.0

Subtract Additional CM Reductions (Table 10-1) 0.0 0.0 0.3 0.3

Projected Direct Emissions Inventory, reflecting full plan 

control strategy 87.1 64.4 63.2 63.7

NOx

Projected Emissions Inventory, reflecting full plan 

control strategy 

(Table B-2) 465.1 275.7 226.9 208.5

SOx

Projected Emissions Inventory, reflecting full plan 

control strategy 

(Table B-3) 12.8 8.6 8.8 9.0

2. Determine the total reductions from the 2007 baseline emission inventory that 

must be achieved to reach attainment. 

Table 9-3 Total Reductions Necessary to Reach Attainment (tpd) 

Pollutant 2007 Baseline

Emissions Inventory

Attainment 

Emissions Level 

Reductions 

Needed

Direct PM2.5 87.1 63.7 23.4

NOx 465.1 208.5 256.6

SOx 12.8 9 3.8

3. Determine the fraction of reductions that are achieved in each RFP milestone 

year. The base year of 2007 and attainment year of 2019 span a 12-year period. 

 2014 occurs at year seven of twelve (7/12), so 58.3% of the needed 

emissions reductions must occur by 2014. 

 2017 occurs at year ten of twelve (10/12), so 83.3% of the needed 

emissions reductions must occur by 2017. 
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9-6 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

4. Determine the RFP target emissions levels using reduction fractions. 

Table 9-4 Target Emissions Levels for RFP Milestone Years (tpd) Pollutant 2007 Emissions Inventory Reductions Needed

2014 2017

Tons to be 

reduced 

(B x 58.3%)

RFP target 

emissions level 

(A-C)

Tons to be 

reduced 

(B x 83.3%)

RFP target 

emissions level 

(A-E)

A B C D E F

Direct 

PM2.5 87.1 23.4 13.6 73.5 19.5 67.6

NOx 465.1 256.6 149.6 315.5 213.7 251.4

SOx 12.8 3.8 2.2 10.6 3.2 9.6

5. Compare RFP target emissions level (Table 9-4) to the projected emissions 

inventory (Table 9-2) to determine compliance with RFP targets. 

Table 9-5 RFP Target Demonstration (2014 and 2017)

2014 2017

RFP target 

emissions 

level

Projected 

emissions 

inventory

RFP 

target 

met?

RFP target 

emissions level

Projected 

emissions 

inventory

RFP 

target 

met?

Direct 

PM2.5 73.5 64.4 Yes 67.6 63.2 Yes

NOx 315.5 275.7 Yes 251.4 226.9 Yes

SOx 10.6 8.6 Yes 9.6 8.8 Yes
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9-7 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

Figure 9-1 NOx RFP Demonstration 

0

50

100

150

200

250

300

350

400

450

500

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Nox Tons per Day

NOx Emissions Required to Demonstrate 

Reasonable Further Progress

NOx Emission Inventory with

Plan Control Strategy
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9-8 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

9.4 CONTINGENCY MEASURES

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

regulatory action. In an attainment plan, the measures must be “extra” in the sense that 

the reductions are not accounted for in RFP or in the attainment demonstration. 

Contingency reductions must start occurring automatically, without any further 

regulatory action, in the following scenarios:

 RFP contingencies: Used if planned emissions controls fail to reach the 

emissions targets specified in the attainment plan for RFP. The need to 

implement RFP contingencies is based on the emissions inventory in the RFP 

milestone years.

 Attainment contingencies: Used if a region fails to attain a federal standard by 

the final attainment date. The need to implement attainment contingencies is 

based on ambient air quality data as of the end of the attainment year. If EPA 

finds that an area fails to attain a standard on time, contingency reductions must 

be implemented automatically. An area often must adopt a new attainment plan, 

and sometimes other penalties apply as well, depending on the requirements 

associated with the standard in question. 

The contingency years for this plan are the RFP milestone years (2014 and 2017) and 

the attainment year (2019). The total emissions reductions available from contingency 

measures should be equivalent to about one year of reductions needed for RFP4. This 

is based on the overall level of reductions needed to demonstrate attainment (see Table 

9-3) divided by the number of years between the base year and the attainment year (12 

years). Table 9-6 shows the resulting contingency need for each pollutant. 

Table 9-6 Contingency Emissions Reductions Target (in tons per day, or tpd)

Contingency Need =

“One year’s worth of RFP”

PM2.5 2.0

NOx 21.4

SOx 0.3

Interpollutant trading can be used to demonstrate equivalent emissions reductions 

levels between PM2.5, NOx, and SOx reductions strategies. Appendix G (Weight of 

Evidence Analysis) documents the methodology used to develop the relative efficacy of 

emission reductions from the different PM2.5 precursors based on photochemical 

modeling sensitivity runs. The current modeling using Valley-wide emissions reductions 

demonstrates that the greatest benefits are achieved from reductions in directly emitted 

PM2.5, followed by NOx (based on EPA’s relative response factor procedures). Kern 

County specific model sensitivity runs were also conducted to evaluate the benefits of 

 

4 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/E7-6347.pdf#page=1
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9-9 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

emission reductions focused on the Bakersfield area. These runs show that directly 

emitted PM2.5 emission reductions are approximately eight times more effective than 

NOx reductions. Refer to Appendix G Section 10.c. (Evaluation of precursor sensitivity) 

and Section 11 (Summary) for the complete analysis and discussion). Additionally, due 

to the photochemistry of ammonium sulfate formation, one ton of SOx reductions is 

equivalent to one ton of PM2.5 reductions; therefore, for contingency purposes, SOx is 

equivalent to directly emitted PM2.5. 

9.4.1 What Qualifies as a Contingency Measure?

Contingency measures must be fully adopted rules or control measures that are ready 

to be implemented quickly without significant additional action by the state or local 

agency or by EPA5. The plan should contain trigger mechanisms and a schedule for 

the contingency measure implementation. Contingency measures can include 

measures already adopted and scheduled for implementation, as long as these 

measures are not relied on to provide emissions reductions needed to provide for RFP 

or expeditious attainment. 

Based on these general contingency requirements, the District is utilizing three types of 

contingency measures:

A. Surplus reductions from implementation of traditional regulations

B. Regulations with a contingency trigger

C. SIP-creditable incentive-based emissions reductions

9.4.1.1 Surplus Reductions from Implementation of Traditional Regulations

Although contingency measures must be surplus to RFP and attainment calculations, 

areas are not required to wait until there is an RFP or attainment failure to implement 

the measures. In fact, designing an effective adopted-but-not-implemented approach 

with an appropriate implementation trigger is only an option in very limited 

circumstances (see 9.4.1.2). Both already-adopted regulations and new or amended 

regulations to be pursued under this plan 

As shown in the RFP demonstration in this chapter, significant regulatory emissions 

reductions are being achieved by 2014 and 2017 – more than the minimum needed to 

demonstrate RFP in those years. As such, the difference between the RFP target 

emissions level and the actual projected emissions level can serve as contingency 

reductions in 2014 and 2017. Using the data in Table 9-5, Table 9-7 shows amount of 

reductions available in 2014 and 2017.

 

5 Clean Air Act Section 172(c)9, 40 CFR 51.1012. 
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9-10 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

Table 9-7 Reductions Surplus to RFP for Contingency (tpd)

Year

2014 2017

RFP target 

emissions 

level

Projected 

emissions

inventory

Contingency

RFP target 

emissions 

level

Projected 

emissions 

inventory

Contingency

PM2.5 73.5 64.4 9.1 67.6 63.2 4.4

NOx 315.5 275.7 39.8 251.4 226.9 24.5

SOx 10.6 8.6 2.0 9.6 8.8 0.8

As the 2019 attainment contingency need would not occur until 2020 (since attainment 

would be based on air quality data collected through the end of 2019), the additional 

PM2.5 and NOx reductions occurring between 2019 and 2020 can serve as attainment 

contingencies (Table 9-8). SOx will not be further reduced between 2019 and 2020 and 

is thus omitted from Table 9-8.

Table 9-8 Attainment Contingencies from Traditional Regulatory Reductions (tpd)

2019 

emissions

2020 

emissions

Attainment 

Contingency

PM2.5

Adopted measures 62.0 61.9 0.1

Rule 4692 reduction for contingency accounting (Appendix D) 0.3

Rule 4901 reduction for contingency accounting (Appendix D) 1.3

Total 1.7

NOx (adopted measures only) 208.5 196.2 12.3

The control measures achieving the contingency reductions in Tables 9-7 and 9-8 are 

as follows:

 Rule 4692 PM2.5 contingency: The modeling conducted for this plan shows 

that reducing emissions from under-fired charbroiling by 20% in Kern County is 

necessary for attainment; thus, only the reductions achieved in Kern County are 

accounted for in the attainment demonstration. By reducing emissions from 

under-fired charbroiling 20% Valley-wide, the District achieves significant health 

benefits Valley-wide per the District’s Risk-based Strategy, and the emissions 

reductions achieved in the Valley’s other seven counties can be counted as 

contingency reductions, as reflected in Table 9-9. This contingency reduction 

approach would be valid for 2017 as well, but is not needed to show sufficient 

contingency reductions as shown in Table 9-10 at the end of this chapter.

 Rule 4901 PM2.5 contingency: Similarly, the modeling conducted for this plan 

shows that lowering the Rule 4901 wood burning curtailment level from 30 μg/m3 

to 20 μg/m3 is necessary for attainment in both Kern County and Kings County; 

thus, only the reductions achieved in Kern and Kings Counties are accounted for 

in the attainment demonstration. By lowering the wood burning curtailment 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

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2012 PM2.5 Plan 

Valley-wide, the District achieves significant health benefits Valley-wide per the 

District’s Risk-based Strategy, and the Rule 4901 emissions reductions achieved 

in the Valley’s other six counties can be counted as contingency reductions, as 

reflected in Table 9-9. This contingency reduction approach would be valid for 

2017 as well, but is not needed to show sufficient contingency reductions as 

shown in Table 9-9 at the end of this chapter.

 Adopted mobile source measures for NOx contingency: Most of the total 

NOx contingency reductions (12.2 tpd of the total 12.3 tpd NOx reduction need in 

2019, for example) are from adopted mobile source control measures for the 

following sources:

o Passenger cars, light-duty vehicles, and medium-duty vehicles 

o Heavy-duty trucks 

o Buses

o Aircraft

o Trains

o Commercial harbor craft

o Motor homes

o Off-road equipment

o Farm equipment

 Adopted stationary and area source measures for NOx contingency: Some 

of the total NOx contingency reductions (0.1 tpd of the total NOx reduction need 

in 2019, for example) are from adopted District rules: 

o Rule 4307 (Boilers, Steam Generators, and Process Heaters- 2.0 

MMBtu/hr to 5.0 MMBtu/hr)

o Rule 4308 (Boilers, Steam Generators, and Process Heaters- 0.075 

MMBtu/hr to less than 2.0 MMBtu/hr) 

o Rule 4320 (Advanced Emission Reduction Options for Boilers, Steam 

Generators, and Process Heaters Greater than 5.0 MMBtu/hr)

o Rule 4702 (Internal Combustion Engines)

o Rule 4103 (Open Burning)

9.4.1.2 Regulations with Contingency Trigger

The District’s 2008 Amendment to Rule 4901 (Wood Burning Fireplaces and Wood 

Burning Heaters) included a contingency provision (Section 5.6.5 of Rule 4901) that 

would lower the mandatory wood burning curtailment threshold if the Valley fails to 

attain the 1997 PM2.5 standard by April 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, which would result in more “No Burn” days and more emissions reductions from 

residential wood combustion. The trigger for this measure is that the 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 1997 by the applicable attainment 

deadline (April 2015). Since the wood burning curtailments are effective from 

November through February, the earliest the contingency level would take effect would 

be November 1, 2015, pending EPA finding that the Valley failed to attain. 
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9-12 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

If, as projected in the 2008 PM2.5 Plan, the Valley reaches the PM2.5 standard by the 

deadline, then this contingency measure would not be used. The Governing Board 

directed District staff to report on the likely necessity of this existing contingency 

measure or the potential for substitute measures. However, this 2012 PM2.5 Plan

contains a commitment to lower the curtailment level 20 μg/m3 officially before for the 

current contingency trigger could occur. As such, the need to evaluate the likely 

necessity of this existing contingency measure is now moot, with the contingency level 

being implemented regardless of a failure to attain the 1997 PM2.5 standard. The 

contingency reductions still apply to the 2008 PM2.5 Plan, since that plan did not rely on 

those reductions. 

Given EPA’s acceptance of the previous Rule 4901 contingency measure, though, the 

District commits to include a contingency threshold in the next Rule 4901 amendment. 

Since the curtailment level in rule would be 20 μg/m3, the District proposes a new 

contingency level of 15 μg/m3, to be implemented if EPA finds that the Valley fails to 

attain the federal 24-hour PM2.5 standard set in 2006 by 2019. The emissions 

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

increased number of “No Burn” days resulting from the curtailment threshold decreasing 

from 20 μg/m3 down to 15 μg/m3: 1.5 tpd of PM2.5, as an average day during the wood 

burning season (November - February). However, average winter reductions greatly 

understate the full impact of Rule 4901 “No burn” days, which reduce some of the most 

harmful species of particulates in the times and places where air quality is forecast to 

reach unhealthy levels. A Valley-wide no-burn day achieves a direct PM2.5 emission 

reduction of 16.7 tons. No other single regulation achieves this level of effectiveness. 

This Rule 4901 Contingency-Trigger reduction is in addition to the contingency 

reductions quantified in section 9.4.1.1 above.

9.4.1.3 SIP-Creditable Incentive-Based Emissions Reductions

As discussed in Chapter 6 of this plan, voluntary incentive programs achieve emissions 

reductions beyond those achieved by regulations alone. Incentive programs accelerate 

the adoption of cleaner technologies and encourage the use of cleaner technologies by 

those not yet subject to air quality regulations. Incentives allow the District to reduce 

emissions from source categories outside of the District’s traditional regulatory authority, 

as well as source categories where financial hardship would otherwise prevent 

traditional control strategies from being implemented. As discussed in Chapter 6, and 

reflected in Table 10-1, the District will be developing a new rule (Rule 9610) allowing 

for SIP-credit of incentive based emissions reductions. 

The District will continue to seek opportunities for additional incentive reductions Valleywide to achieve emissions reductions for contingency and expedite public health 

benefits Valley-wide. However, as this plan's modeling and analysis shows the 

particular effectiveness of localized controls, replacing of on- and off-road engines that 

are likely to operate in Kern County would be especially effective in accelerating 

Bakersfield's attainment of the 24-hour PM2.5 standard. The District will consider 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

9-13 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

opportunities to target mobile source incentive reductions, per this PM2.5 standard as 

well as the Valley's other attainment and public health considerations. 

Both ARB and the District are committed to pursuing the needed funding and to target 

incentive programs to provide for expeditious attainment. Some source categories that 

are good candidates for such targeted incentive reductions, due to their associated 

post-2019 regulatory deadlines, include, but are not limited to:

 Further emissions reductions from construction equipment to accelerate 

conversion of older construction equipment to Tier 4. Upon targeting 

construction fleet turnover in the Kern County area, the District could work to 

encourage use of the cleanest equipment (and discourage the use of other 

equipment) during episodes generating poor air quality. 

 Accelerated retirement of older light- and medium-duty vehicles

 Accelerated retirement of older on- and off-road diesel vehicles and equipment, 

including on-road diesel, off-road, and agricultural equipment

 Further emission reductions from freight locomotives, including the introduction of 

Tier 4 locomotives in the South Coast air basin that then travel through the Valley

At this time, the District proposes to achieve 1.9 tpd of NOx reductions through Rule 

9610 and related incentive programs to use as contingency for 2019. Beginning in 

2017, the District will evaluate the Valley’s progress towards attainment of the 2006

federal PM2.5 standard. If needed, the District will explore any other legally feasible 

corrective actions that may be suitable, such as additional reductions from ARB, and 

amend the SIP if appropriate before the Rule 9610 contingency reductions are needed.

9.4.2 Sufficient Contingency Reductions

Areas like the Valley that have significant nonattainment challenges have developed 

several generations of aggressive and far-reaching emission reduction measures to 

meet various Clean Air Act requirements. The result of this “no stone left unturned” 

policy is that when viable emission reductions are identified, they are implemented to 

contribute to expeditious attainment. Reductions are not usually held in reserve to be 

used only if an area fails to meet a milestone. As a result, contingency measure 

demonstrations in the Valley have been a challenge, historically.

However, this chapter has outlined three types of contingency measures being used to 

meet the contingency reductions required for this plan:

 Surplus from traditional regulations (see Section 9.4.1.1)

 Regulations with contingency trigger (see Section 9.4.1.2)

 SIP-creditable incentives (see Section 9.4.1.3)

Table 9-9 shows how these approaches together generate enough emissions 

reductions to meet the contingency reductions required for this plan.
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

9-14 Chapter 9: Attainment Demonstration, RACM, RFP, and Contingency Measures

2012 PM2.5 Plan 

Table 9-9 Demonstration of Sufficient Contingency Reductions

2014 2017 2019 Data reference

PM2.5

Surplus from traditional regulations 9.1 4.4 1.7 Tables 9-7 and 9-8

Regulations with contingency trigger 0 0 1.5 Section 9.4.1.2

SIP-creditable incentives 0 0 0 Section 9.4.1.3

Subtract PM2.5 reductions, trade for SOx 0 0 -0.3* 1:1 trading ratio*

Subtract PM2.5 reductions, trade for NOx -0.9* 1:8 trading ratio*

Total contingency reductions achieved 9.1 4.4 2.0

Contingency reductions required 2.0 Table 9-6

Contingency need met? Yes Yes Yes

NOx

Surplus from traditional regulations 39.7 24.4 12.3 Tables 9-7 and 9-8

Regulations with contingency trigger 0 0 0 Section 9.4.1.2

SIP-creditable incentives 0 0 1.9 Section 9.4.1.3

Substitute PM2.5 reductions 7.2* Above, with 1:8 

trading ratio*

Total contingency reductions achieved 39.7 24.4 21.4

Contingency reductions required 21.4 Table 9-6

Contingency need met? Yes Yes Yes

SOx

Surplus from traditional regulations 2.0 0.8 0 Tables 9-7 and 9-8

Regulations with contingency trigger 0 0 0 Section 9.4.1.2

SIP-creditable incentives 0 0 0 Section 9.4.1.3

Substitute PM2.5 reductions 0.3* Above, with 1:1 

trading ratio*

Total contingency reductions achieved 2.0 0.8 0.3

Contingency reductions required 0.3 Table 9-6

Contingency need met? Yes Yes Yes

* 1 ton of direct PM2.5 emissions reductions is equivalent to 1 ton of SOx reductions or 8 tons of NOx reductions as 

demonstrated in the Weight of Evidence (Appendix G). These ratios are conservative estimates summarizing the plan 

as a whole, not reflecting ratios appropriate for New Source Review (NSR)