San Joaquin Valley Unified Air Pollution Control District Dece mber 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

SJVUAPCDSan Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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

2012 PM2.5 Plan This page intentionally blank

.San Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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

2012 PM2.5 Plan 

### Chapter 9 : Attainment Demons tratio n, RACM, RFP, and Contingency

Measures

The District’s multi

- faceted control strategy will achieve expeditious attainment Valley

wide. 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 ch apter 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 D ecember 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 r eached 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 po ssible, 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,

reduction s 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

emi ssions 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.

A ll 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 th is plan. Table 9

- 1 shows that the 2019 emissions target would not

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

ea rlier 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. Retrie ved from http://www.epa.gov/ttn/naaqs/pm/pdfs/20120302_implement_guidance_24

- hr_pm2.5_naaqs.pdfSan Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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

2012 PM2.5 Plan Kern County. To pu t 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 im p lementation 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, wit h all feasible measures and strategies being implemented to accomplish this goal. T he non

- regulatory contr ol measures not

credited in the attainment demonstration are achieving actual emissions reductions in the Valley. T he District will continue to redu ce 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 W inter 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 e missions 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 W inter 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 W inter 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 2019San Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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- 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 reduction s that, taken as a group, advance attainment of an air quality standard by at least one year. Put another way, t he 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 exped itious 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 contro ls would have to

achieve the 2019 emissions levels by 2018 in Kern County

. Per the District’s Risk

based 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 a chieve 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 depe nd 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 a ttainment in 2019 come from mobile sources. These reductions cannot be expedited through additional stationary and area source regulation s, for which the District has regulatory authority

. Based on the difference between 2018 and 2019 NOx

emissions level s shown in Table 9

- 2, unused control m easures would have to achieve

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

year. However, a s 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 a nalysis 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 im plemented. The District has adopted many of the toughest stationary and area sources rules in theSan Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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- 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 unu sed 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 red uctions 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 measure s. T he District also considered

whether ammonia emissions reductions could expedite attainment. Based on 2018 emissions and analysis conducted for t his 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 practi cable in the San Joaquin Valley, wi th 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_p m2.5_naaqs.pdfSan Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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

2012 PM2.5 Plan nonattainment area as a whole. R FP requirement targets and attainment

demonstrations are as follows:

1. Determine the Emissions Inventory of the Valley with the Plan control s trategy 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 E missions I nventory , 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 R eductions N ecessary 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. Determin e 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

emissio ns reductions must occur by 2017

.San Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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- 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 E missions L evels for RFP M ilestone Y ears (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 (T able 9

- 4 ) to the project ed emissions inventory (Table 9

- 2 ) to determine compliance with RFP target s.

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 YesSan Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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- 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 StrategySan Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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- 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.

C ontingency reductions must start occurring automatically, withou t any further regulatory action

, in the following scenarios :

 RFP c ontingencies: Used i f planned emissions controls fail to reach the emissions targets specified in the attainment plan for RFP. Th e need to implement RFP contingencies is based on the emissions inventory in the RFP milestone years

.

 Attainment contingencies: Used i f 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

.

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

the attainment year ( 2019 )

. T he total emissions reductions available from contingency measures should be equivalent to about one year of reductions needed for RFP 4

. 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

.

Tabl e 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

SO x 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

emissio n reductions from the different PM2.5 precursors based on photochemical modeling sensitivity runs. The current modeling using V alley

- 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=1San Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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- 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 t he 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 Q ualifies as a Contingency Measure?

C ontingency 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 EPA 5 . The plan should contain trigger mechanisms and a schedule for

the c ontingency 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 Implement ation 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

reg ulations 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

demonstrat e RFP in those years. As such, the difference between the RF P 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.San Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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

2012 PM2.5 Plan Table 9

- 7 Redu ctions Surplus to RFP for Contingency (tpd)

Year 2014 2017

RFP target

emissions

level Projected

e missions inventory Contingency RFP target

emissions

level Projected

emissions inventory Contingency

PM2.5 7 3.5 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 a s 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 re ducing 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 conti ngency: 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 curtailmentSan Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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

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 r eductions 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 r eductions 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 E ngines)

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/m 3, 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 faile d to

attai n 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.San Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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- 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 trigge r could occur

. As such, t he 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 20 19. 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 2 0 μg/m3 down to 15 μg/m3: 1.5 tpd of PM2.5, as an average day dur ing 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 i s 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, v oluntary 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 r egulations. 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 f rom 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 Valley

wide to achieve emissions reductions for contingency and expedite public health benefits Valley

- wide. However, as this plan's modeling and analysis shows the parti cular 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 considerSan Joaquin Valley Unified Air Pollution Control District Dece mber 20 , 2012

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

2012 PM2.5 Plan oppo rtunities 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 pro grams 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 o ther 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 agricultu ral 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 propose s 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 leg ally 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” poli cy 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

dem onstrations 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 Dece mber 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 * A bove , 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* A bove , 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)