State of California

AIR RESOURCES BOARD

STAFF REPORT

PROPOSED 2004 STATE IMPLEMENTATION PLAN 

FOR OZONE 

IN THE SAN JOAQUIN VALLEY 

Release Date: September 28, 2004

Meeting Date: October 28, 2004

The energy challenge facing California is real. Every Californian needs to take immediate action to

reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy

costs, see our Website: http://www.arb.ca.gov.
State of California

California Environmental Protection Agency

AIR RESOURCES BOARD

STAFF REPORT

PUBLIC MEETING TO CONSIDER APPROVAL OF THE PROPOSED 

2004 STATE IMPLEMENTATION PLAN FOR OZONE

IN THE SAN JOAQUIN VALLEY 

Air Resources Board Meeting

Begins October 28, 2004

9:00 a.m.

San Joaquin Valley Unified Air Pollution Control District

1990 E. Gettysburg Avenue

Fresno, California 

Meeting notice available at http://www.arb.ca.gov/planning/sip/sip.htm

Prior to the meeting, the public may submit written comments through regular mail,

e-mail or fax. To be considered by the Board, written comments not physically

submitted at the meeting must be received no later than 12:00 noon,

October 27, 2004 and sent to:

Clerk of the Board

Air Resources Board

1001 I Street, 23rd Floor

Sacramento, California 95814

or by e-mail to sjvsip04@listserve.arb.ca.gov

or by facsimile transmission to the Clerk of the Board at (916) 322-3928

This report has been reviewed by the staff of the Air Resources Board and approved for

publication. Approval does not signify that the contents necessarily reflect the views

and policies of the Air Resources Board, nor does mention of trade names or

commercial products constitute endorsement or recommendation for use.

This report is available for downloading from the Air Resources Board’s Internet site at

http://www.arb.ca.gov/planning/sip/sip.htm. In addition, written copies may be obtained

from the Board’s Public Information Office, 1001 I Street, 1st Floor, Environmental

Services Center, Sacramento, California 95814, (916) 322-2990. 
If you are a person with a disability and desire to obtain this document in an alternative

format, please contact the Americans with Disabilities Act Coordinator at

(916) 323-4916, or TDD (916) 324-9531, or (800) 700-8326 for TDD calls from outside

the Sacramento area.

PRINCIPAL AUTHOR

Ravi Ramalingam, P.E., Staff Liaison to the San Joaquin Valley District

Phone: (916) 322-2085

Email: rramalin@arb.ca.gov

PROJECT MANAGER

Kurt Karperos, P.E., Manager, Transportation Strategies Group

CONTRIBUTORS

Air Quality Modeling

John DaMassa, Chief, Modeling and Meteorology Branch

Ajith Kaduwela, Ph.D., Manager, Regional Air Quality Modeling Section

Vernon Hughes, Manager, Atmospheric Modeling and Support Section

Bruce Jackson, Staff Air Pollution Specialist

Cheryl Taylor, Air Resources Engineer

Emissions Inventory 

Michael Benjamin, Ph.D., Manager, Emission Inventory Systems Section

Michael FitzGibbon, P.E., Manager, Emission Inventory Analysis Section

Douglas Thompson, Manager, Motor Vehicle Assessments Section

Martin Johnson, P.E., Staff Air Pollution Specialist

Larry Hunsaker, Air Pollution Specialist

Thomas Scheffelin, P.E., Air Resources Engineer

Jonathan Taylor, P.E., Air Resources Engineer

Dennis Wade, Air Pollution Specialist

Air Quality Data

Gayle Sweigert, Manager, Air Quality Analysis Section

ACKNOWLEDGEMENTS

ARB staff thanks the San Joaquin Valley District staff for the high level of coordination

between the agencies in developing the technical elements of this plan. We would like

to recognize Mr. Dave Jones, Mr. Dave Mitchell, Mr. Scott Nester, Dr. Don Hunsaker,

Mr. George Heinen, Mr. Evan Shipp, Ms. Jennifer Barba, Ms. Cynthia Echavarria,

Mr. David Nunes, Ms. Elena Nuño, Mr. Steve Shaw, Mr. Jim Sweet, and

Mr. Tom Jordan, who each dedicated many hours to this interagency cooperation.
TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY...............................................................................................1

I. BACKGROUND..................................................................................................5

A. Profile of the San Joaquin Valley ...............................................................5

B. Historical Air Quality ...................................................................................6

C. Central California Ozone Study ..................................................................8

II. AIR QUALITY PLANNING..................................................................................9

A. Ozone Planning Background......................................................................9

B. 2003 PM10 Plan.......................................................................................10

C. 8-Hour Ozone Planning Requirements.....................................................10

D. PM2.5 Planning Requirements ................................................................11

E. California Clean Air Act Plans ..................................................................11

III. PLAN EVALUATION ........................................................................................12

A. Emission Inventory ...................................................................................12

B. Emission Reduction Credits .....................................................................13

C. Air Quality Modeling .................................................................................14

1. Ozone Episode.................................................................................14

2. Air Quality Model ..............................................................................14

3. Modeling Performance .....................................................................15

4. Attainment Emissions Target............................................................16

5. Peer Review .....................................................................................17

D. Control Strategy........................................................................................17

1. Local Measures ................................................................................19

2. State Measures ................................................................................26

3. Federal Measures.............................................................................31

4. Long-Term Measures .......................................................................31

5. Contingency Measures.....................................................................34

E. Attainment Demonstration ........................................................................34

F. Rate-of-Progress Demonstration..............................................................35

G. Transportation Conformity Budgets..........................................................37

IV. FUTURE FEDERAL OZONE PLANS ...............................................................38

A. 2007 1-Hour Ozone Plan Update .............................................................38

B. 8-Hour Ozone Plans.................................................................................38

V. ENVIRONMENTAL IMPACTS..........................................................................39

VI. LEGAL AUTHORITY ........................................................................................41

VII. STAFF RECOMMENDATIONS........................................................................42
-1-

EXECUTIVE SUMMARY

The San Joaquin Valley Unified Air Pollution Control District (District) released the

2004 State Implementation Plan (SIP) for Ozone in the San Joaquin Valley on

September 10, 2004 and will consider local adoption at a hearing scheduled for

October 8, 2004. Contingent on prior adoption by the District, the Air Resources Board

(ARB or Board) will consider approval of the 2004 Ozone SIP at a public meeting on

October 28, 2004. If the Board adopts the plan, it will be submitted to the

U.S. Environmental Protection Agency (U.S. EPA) for federal approval. 

This new plan identifies the clean air strategies needed to bring the Valley into

attainment with the federal 1-hour ozone standard by 2010. It builds on already

adopted controls and the strategies in the Valley’s 2003 SIP for inhalable particulate

matter (PM10), then adds new Ozone SIP commitments that provide the last increment

of reductions to meet the 1-hour standard. 

Air Quality, Emissions, and Growth. The San Joaquin Valley experiences some of

the worst ozone and particulate air pollution in the U.S., with both high levels and

frequent episodes. Since 1980, pollution controls have cut ozone-forming emissions by

nearly 60 percent, even with growth in population, vehicle travel, and the economy. The

emission controls have improved the long-term air quality trends, decreasing the

number of days over the federal 1-hour ozone standard and the geographic scope of

the problem. Based on U.S. EPA’s more protective 8-hour ozone standard, Valley

residents still breathe unhealthy levels of ozone about a third of the year.

Attainment Deadline. This plan focuses on achieving the federal 1-hour ozone

standard by the 2010 deadline established by the federal Clean Air Act for

nonattainment areas with a classification of extreme. The 2010 date is the second

extension of the San Joaquin Valley’s deadline, with each change triggering a new

round of air quality planning and control strategy development. The Valley was

originally classified as a serious federal ozone nonattainment area with a 1999 deadline,

then as a severe area with a 2005 deadline. The District formally requested and was

granted a voluntary reclassification (or “bump up”) from severe to extreme, requiring

tighter emission controls and attainment by 2010. Although U.S. EPA intends to revoke

the 1-hour standard in 2005 (and replace it with the 8-hour standard), this plan is

necessary to satisfy a legal requirement in U.S. EPA’s transition policy for areas like the

Valley that don’t have an approved 1-hour ozone attainment plan. 

SIP Elements. The Proposed SIP includes: air quality data; an emission inventory for

1990 – 2010; air quality modeling to determine the attainment emissions target; a

control strategy reflecting the benefits of adopted local, State, and federal regulations,

together with local and State commitments for additional emission reductions from new

measures; a demonstration of attainment by 2010; a rate-of-progress demonstration

through 2010; new motor vehicle emission budgets for transportation conformity; and

contingency emission reductions.
-2-

Improved Scientific Tools. The tools and data used in the 2004 Ozone SIP represent

the state-of–the-science and a significant step forward in our collective ability to

understand the level of emission controls needed to the meet the ozone standards in

the Valley. This information and capability is a direct result of the work done under the

Central California Ozone Study, a public-private $18 million program of meteorological

and air quality monitoring, emission inventory development, data analysis, and air

quality simulation modeling.

Control Strategy. The plan shows that the Valley needs to reduce ozone-forming

emissions of volatile organic compounds (VOC) and nitrogen oxides (NOx) by a

combined 342 tons per day (tpd) between the 2000 starting point and the 2010

attainment date. Table ES-1 shows that 70 percent, or 238 tpd, of the needed 342 tpd

reductions come from control measures already adopted and on track for

implementation. The next 13 percent of the reductions are from new measures

identified in the adopted 2003 Valley PM10 SIP. This plan introduces additional

commitments to achieve the last 17 percent of the reductions needed. 

Table ES-1

Summary of Attainment Strategy for 2004 Ozone SIP

(San Joaquin Valley, Summer Planning, in tons per day)

VOC + NOx Percent of Total

Reductions

2000 Baseline Emissions

 Total Reductions Needed for Attainment 

2010 Attainment Emissions Target

1000

-342

658

Emission Reductions 

 Measures Adopted as of September 2002

 New Measures in 2003 Valley PM10 SIP

 New Defined Measures in Ozone SIP

 New Long-Term Measures in Ozone SIP 

-238

-46

-48

-10

70%

13%

14%

3%

Total Reductions Achieved by Ozone SIP -342

In this plan, the District introduces Ozone SIP commitments for 12 new defined

measures to achieve 23 tpd of reductions -- the most significant new measure would

reduce VOC emissions from large concentrated animal feeding operations by over

15 tpd. This plan takes full credit for the VOC and NOx reductions in the 2003 State

and Federal Strategy for the California SIP approved by the Board last year. The PM10

SIP included 10 tpd of NOx reductions from new State measures. To provide the

additional reductions needed for ozone attainment, this plan increases the State’s

commitment to a total of 20 tpd NOx and 15 tpd VOC reductions in the San Joaquin

Valley by 2010.
-3-

Table ES-2 provides a detailed breakdown of the attainment strategy by local, State,

and federal jurisdiction.

Table ES-2

Summary of Attainment Strategy by Jurisdiction

(San Joaquin Valley, Summer Planning, in tons per day)

VOC NOx

Percent of

VOC+NOx by

Jurisdiction

2000 Baseline Emissions

 State

 Local 

 Federal

 Total 

209.7

203.9

29.9

443.5

249.4

161.4

146.0

556.8

46%

36%

18%

2000-2010 Reductions from Measures Adopted 

(as of September 2002)

 State

 Local1

 Federal

 Total 

-79.3

+8.5

-7.6

-78.4

-97.2

-18.9

-43.9

-160.0

74%

4%

22%

2010 Baseline Emissions with Adopted Measures 

 State

 Local

 Federal

 Total

130.4

212.4

22.3

365.1

152.2

142.5

102.1

396.8

37%

47%

16%

2010 Reductions from Defined New Measures

 State 

 Local

 Federal

 Total

-15.0

-30.7

0

-45.7

-20.0

-28.3

0

-48.3

37%

63%

0%

2010 Reductions from Long-Term Measures

 Local -5.0 -5.0 100%

2010 Total Reductions from All Measures

 State

 Local

 Federal

 Total

-94.3

-27.2

-7.6

-129.1

-117.2

-52.2

-43.9

-213.3

62%

23%

15%

2010 Attainment Emissions Target 314.4 343.5

1 Baseline District measures reduce NOx by nearly 19 tpd between 2000 and 2010, but allow a net

increase of just over 8 tpd in VOC emissions due to projected growth (mainly from livestock operations)

over the same timeframe. The District’s full rulemaking agenda over the next several years will ensure

net reductions in both pollutants in the future. 

Federal 8-Hour Ozone Standard. U.S. EPA has begun to implement a more stringent

8-hour ozone standard that will replace the current 1-hour standard. In addition to

providing the last increment of reductions for the 1-hour standard, the 2004 Ozone SIP

lays the groundwork for the 8-hour plan and attainment strategy due June 15, 2007. 
-4-

District Clarifications to Proposed Plan. District staff indicates it will make technical

corrections to the plan at or prior to the October 8, 2004 local hearing. These changes

include:

• Clarification of the District’s commitment to achieve the aggregate local emission

reductions from the defined new measures or from alternative measures in the same

timeframe.

• Clarification of the District’s intent to adopt the long-term measures.

• Clarification that the District will use the SIP update mechanism for changes to the

rule development schedule.

• An update to the rate-of-progress calculations demonstrating the required emission

reduction progress based on adopted measures.

• Corrections to the emission inventory and other minor revisions.

Staff Recommendation. The Proposed SIP, with the technical corrections

characterized above, satisfies applicable requirements and will reduce ozone levels

throughout the San Joaquin Valley to benefit public health. We recommend that the

Air Resources Board adopt the 2004 San Joaquin Valley Ozone SIP and direct the

Executive Officer to submit the plan to U.S. EPA as a revision to the California SIP. 
-5-

I. BACKGROUND

This chapter provides an overview of topography, meteorology, and ozone air quality in

the San Joaquin Valley. It also briefly describes some of the air quality research used

to develop the Valley’s 2004 Ozone SIP.

A. Profile of the San Joaquin Valley

The San Joaquin Valley Air Basin covers San Joaquin, Stanislaus, Merced, Madera,

Fresno, Kings, Tulare, and Western Kern Counties. The San Joaquin Valley comprises

nearly 25,000 square miles and covers approximately 16 percent of the geographic area

of California. It is a continuous valley approximately 250 miles long and averaging

80 miles wide. Mountains bound the area on the west (Coastal Mountain range), the

east (Sierra Nevada range), and the south (Tehachapi Mountains). The San Joaquin

Valley has over 3.4 million residents today, with 4 million expected by 2010. The major

urban centers are Bakersfield, Fresno, Modesto, and Stockton. The San Joaquin Valley

Unified Air Pollution Control District is the local air quality agency responsible for the air

basin. Figure I-1 shows the San Joaquin Valley Air Basin.

Figure I-1

San Joaquin Valley
-6-

B. Historical Air Quality

Due to a combination of meteorology and air pollutant emissions, the San Joaquin

Valley experiences many days where ozone levels are greater than the federal 1-hour

ozone standard. The areas experiencing the greatest number of violations of that

standard are southeast and downwind of Fresno and Bakersfield. Ozone peaks

generally occur during July through October, with daily maximum concentrations

between noon and 6:00 p.m.

The long-term trend in San Joaquin Valley ozone air quality, as measured by the

maximum 1-hour ozone concentration in parts per billion (ppb) and the number of days

over the federal 1-hour ozone standard, is shown in Figure I-2. As the figure shows,

ozone air quality is improving in the Valley over the long-term. Despite fluctuations due

to differences in weather each year, the Valley has experienced a gradual decline in

both the highest recorded concentrations of ozone, and the number of days on which

the federal 1-hour standard is exceeded. 

Figure I-2

Maximum 1-Hour Ozone Concentration and 

Days Over Federal 1-Hour Ozone Standard in the San Joaquin Valley

Although the emission reduction progress has been steady, the annual variation in

ozone air quality is strongly influenced by differences in weather conditions. Years

having more days with severe weather conditions that are conducive to ozone formation

(such as 1988, 1996 and 1998) have more days that exceed the standards and higher

peak concentrations. These severe weather conditions include hot temperatures,

strong inversion layers, and calm conditions. Summers with milder weather conditions

(1997, 2004) have better air quality. Preliminary data indicates fewer than 10 federal

1-hour exceedances for the Valley to date in Summer 2004.

0

50

100

150

200

250

1980

1982

1984

1986

1988

1990

1992

1994

1996

1998

2000

2002

Days Over Federal 1-Hour Ozone Standard

Maximum 1-Hour Ozone Concentration (ppb)
-7-

The northern region of the Valley – San Joaquin, Stanislaus and Merced Counties–has

the cleanest air. The Valley’s peak concentrations have occurred (and continue to

occur) at sites in either Fresno or Kern Counties. On average, Fresno and Kern

Counties each have historically recorded at least twice as many days above the national

1-hour standard as any of the remaining counties in the Valley.

Figure I-3 shows the Valley’s federal 1-hour design value (the required statistical

indicator used to compare to the federal standard). It has improved only slightly over

the last 15 years. The San Joaquin Valley also exceeds U.S. EPA’s new 8-hour ozone

standard. The Valley trends for 8-hour and 1-hour ozone are similar.

Figure I-3

1-Hour and 8-Hour Design Value Trends

San Joaquin Valley

1988-2003

Other indicators of how severe and widespread the ozone problem is in the Valley show

appreciable progress over time. 

• The number of days over the federal 1-hour standard is dropping for nearly all sites. 

• In Kern County, the number of the very worst days (days with ozone over 0.15 ppm)

has dropped by about 75 percent, and the number of days with federal 1-hour

exceedances by more than 50 percent, over the last 15 years. 

• The geographic extent of ozone levels above the federal 1-hour standard is also

shrinking over time, meaning that fewer communities are exposed to these

unhealthful levels. The Valley’s northern region has not registered any exceedances

since Summer 2002. Air quality modeling for 1-hour and 8-hour ozone shows both

reduced ozone levels and fewer areas exposed to high ozone over time.

0

50

100

150

200

19881990199219941996

1998

2000

2002

ppb

1-Hour (compared to standard of 124 ppb)

8-Hour (compared to standard of 84 ppb)
-8-

C. Central California Ozone Study

The San Joaquin Valley’s last attainment demonstration for the federal 1-hour ozone

standard as part of the 1994 Ozone SIP was based on modeling from an ozone episode

that occurred during the 1990 San Joaquin Valley Air Quality Study. 

A decade later, air quality experts conducted the next generation study, called the

Central California Ozone Study (CCOS). CCOS is a public-private $18 million,

multi-year program of meteorological and air quality monitoring, emission inventory

development, data analysis, and air quality simulation modeling. CCOS was designed

to advance the state-of-the-science and provide modeling capability for all of California

north of the Tehachapi Mountains. The CCOS study domain is large, extending from

out over the Pacific Ocean to Nevada and from south of the Tehachapies to north of the

Oregon border.

Data collected in CCOS, especially for the July-August 2000 intensive ozone episode,

provides the basis for the air quality modeling and attainment demonstration in the

Valley’s 2004 Ozone SIP.
-9-

II. AIR QUALITY PLANNING

This chapter describes recent and future San Joaquin Valley plans and reviews the

relevant planning provisions in the federal Clean Air Act (Act).

A. Ozone Planning Background

The federal Clean Air Act classifies nonattainment areas and sets out specific planning

and control requirements based on the severity of each area’s air quality. Each of the

nonattainment classifications—marginal, moderate, serious, severe, or extreme—is

linked to a fixed deadline to attain the federal air quality standard. In 1990, the

San Joaquin Valley was designated as nonattainment with a serious classification,

which carried an automatic attainment date of 1999.

The San Joaquin Valley did not attain the 1-hour ozone standard in 1999. U.S. EPA

found that the area failed to attain by the deadline and reclassified the Valley as a

severe ozone nonattainment area on November 8, 2001. (At the same time, U.S. EPA

established eastern Kern County, which had been part of the San Joaquin Valley

nonattainment area, as its own nonattainment area.) With the reclassification, U.S. EPA

set a deadline of May 15, 2002 for the District to submit a severe area plan.

In response to the reclassification, the District adopted a 2002 and 2005 Rate of

Progress (ROP) Plan in May 2002. The District later amended this plan in December of

the same year to reflect the latest motor vehicle emission estimates projected by

EMFAC2002. These plans satisfied all planning requirements for a severe

nonattainment area, except for a demonstration of attainment by the 2005 deadline.

Preliminary analysis at that time indicated that to attain the federal standard, the Valley

needed to reduce ozone precursor emissions by approximately 30 percent (roughly

300 tons per day) from expected 2005 emission levels. Recognizing the inability to

identify sufficient emission reductions from control measures to bring the Valley into

attainment by 2005, the District Board voted on December 18, 2003 to request voluntary

reclassification to extreme with an associated 2010 attainment deadline. ARB

forwarded this request to U.S. EPA. On April 16, 2004, U.S. EPA published a final

notice in the Federal Register reclassifying the Valley to extreme effective May 17, 2004

and established the following requirements:

Due November 15, 2004

• Demonstrate attainment* of the 1-hour ozone standard attainment by 2010;

• Demonstrate reasonable progress* in reducing emissions for years 2008 and 2010;

• Use clean fuels (like natural gas) for boilers as required under section 182(e)(3); and

• Identify contingency measures for progress and attainment.

* These plans also need to establish motor vehicle emission budgets for

transportation conformity in 2008 and 2010.
-10-

Due May 16, 2005

• Decrease the emission level that defines a major stationary source from 25 down to

10 tons per year;

• Apply reasonably available control technology (RACT) rules to facilities subject to

the new lower major source cutoff; and

• Establish a more stringent New Source Review (NSR) requirement to offset

emissions from new or modified major stationary sources – increase the current

offset ratio of 1.3 tons of reductions for every ton of increased emissions up to a ratio

of 1.5 to 1. 

B. 2003 PM10 Plan

To fulfill its obligations as a serious PM10 nonattainment area, the San Joaquin Valley

adopted a new PM10 Plan on June 19, 2003. This plan includes 245 tons per day of

reductions in direct PM10 and PM10 precursor emissions (notably NOx) between 1999

and 2010 from a combination of the existing control programs and new commitments,

and demonstrates attainment by 2010. U.S. EPA published its final approval of the

Valley’s 2003 PM10 Plan in the Federal Register on May 26, 2004.

The 2003 PM10 Plan included new State commitments for measures and emission

reductions based on a subset of the Proposed 2003 State and Federal Strategy for the

California State Implementation Plan, as revised by ARB Resolution 03-14. 

In adopting the 2003 PM10 Plan, the District committed to reassess the attainment

demonstration and update the Plan by March 31, 2006, based on final results from the

California Regional Particulate Matter Air Quality Study. This review will include an

evaluation of the modeling and the latest technical information to determine whether the

level of emission reductions in the 2003 PM10 Plan is sufficient to attain the PM10

standards. If this mid-course review shows a need for control strategy changes, the

Plan revision will include the appropriate measures. 

C. 8-Hour Ozone Planning Requirements

On April 15, 2004, U.S. EPA finalized both designations and the first phase of its rule

defining requirements for the 8-hour ozone standard. The San Joaquin Valley, as

anticipated, is nonattainment for the federal 8-hour standard. Classified serious, the

Valley has until 2013 to attain the 8-hour standard.

The Valley will need significant further emission reductions to achieve this more healthprotective federal standard. The strategies contained in this 1-hour ozone plan will

serve as a down payment on the reductions needed to attain the 8-hour standard.
-11-

D. PM2.5 Planning Requirements

U.S. EPA plans to finalize designations for PM2.5 (particulate matter of diameter

2.5 microns and less) in December 2004. Based on its air quality data, we expect the

Valley to be designated nonattainment for both the 24-hour and the annual PM2.5

standards. The Valley’s PM2.5 attainment demonstration plan is due to U.S. EPA in

early 2008.

The Valley will need significant additional NOx (a precursor to PM2.5) reductions for

PM2.5 attainment. Therefore, the strategies for 1-hour ozone, 8-hour ozone, and PM10

are complementary.

E. California Clean Air Act Plans

The California Clean Air Act (CCAA) requires districts that violate the State 1-hour

ozone standard to demonstrate every three years that they are making steady progress

towards attainment through a five percent annual reduction in ozone precursors, or

implementation of all feasible measures. Thus far, all districts, including the

San Joaquin Valley, have relied on the all feasible measures option to show progress.

Districts like the San Joaquin Valley that send “overwhelming” pollutant transport to

other regions are also required to mitigate their transport contribution.

The District’s 2004 Ozone SIP includes elements to address both federal and State

ozone planning requirements. This evaluation covers only the federal element; we will

assess the CCAA element in a separate, subsequent analysis of all districts’ triennial

plans. 
-12-

III. PLAN EVALUATION

This chapter reviews the contents of the Proposed San Joaquin Valley 1-Hour Ozone

SIP and provides ARB staff’s evaluation of each significant element.

A. Emission Inventory

California’s emission inventory is an estimate of the amounts and types of pollutants

emitted from thousands of industrial and commercial facilities, millions of mobile

sources, and hundreds of millions of applications of other products such as paint and

consumer products. The development and maintenance of the inventory is a multiagency effort involving ARB, 35 local air pollution control and air quality management

districts (districts), metropolitan planning organizations (MPOs), councils of

governments (COGs), and the California Department of Transportation (Caltrans). ARB

staff compiles the final, statewide emission inventory and maintains this information in a

complex electronic database. An inventory reflects the best information available about

the emission rate and activity (including projected growth) for each category of sources.

The San Joaquin Valley 1-Hour Ozone SIP utilizes the latest estimates of VOC and

NOx for stationary, area-wide, and on-road and off-road mobile sources. These are

consistent with emission estimates reflected in the Valley’s 2003 PM10 SIP.

The emission analyses in the SIP focus on the years 2000 (the starting point for the air

quality modeling analysis) and 2010 (the attainment date). For purposes of assessing

emission reduction progress according to the milestones identified in the Act, the SIP

also includes inventories for 1990 and 2008. VOC and NOx emissions are projected to

decline by 24 percent between 2000 and 2010, on the strength of controls adopted as of

2002. This reflects a net 3 percent decline in emissions from stationary and area-wide

sources, a 44 percent decline in emissions from on-road motor vehicles, and a

32 percent decline in emissions from off-road vehicles and equipment. Table III-1

shows the breakdown of VOC and NOx emissions by broad source category in 2000

and 2010, with the benefit of adopted controls. Throughout this report, emissions and

reductions are shown in tons per day (tpd), during the summer ozone season planning

inventory, for the San Joaquin Valley Air Basin, unless otherwise noted.

We note that the ozone season planning inventory currently includes estimates for

VOC, carbon monoxide, and PM10 emissions from range land and forest management

prescribed fires. ARB and District staff are working to identify the seasonal NOx

emissions for these activities. Since that work was not complete at the time the

planning inventory was developed, this inventory does not include estimates of the NOx

emissions from prescribed burning. Until the seasonal NOx estimates from prescribed

burning are finalized and reflected in a subsequent SIP, evaluation of prescribed

burning emissions against the SIP planning inventory should focus on VOC, carbon

monoxide, and PM10. This approach does not impact the attainment demonstration

because the day-specific emission inventory used for air quality modeling in this plan

does include information on fire activity and the associated emissions.
-13-

Table III-1

Baseline Emission Trends with Measures Adopted as of September 2002

(San Joaquin Valley, Summer Planning, in tons per day)

VOC NOx VOC + NOx

Source Category 2000 2010 %

Change 2000 2010 %Change 2000 2010 %Change

Stationary & 

Area-wide 258.9 265.7 +3%1 161.5 142.5 -12% 420.4 408.2 -3%

On-Road Motor

Vehicles 115.3 57.02 -51% 223.8 134.22 -40% 339.1 191.2 -44%

Off-Road

Vehicles and

Equipment

69.2 42.43 -39% 171.5 120.13 -30% 240.7 162.53 -32%

TOTAL 443.5 365.1 -18% 556.8 396.8 -29% 1,000.3 761.9 -24%

1

 This projected increase comes primarily from expected growth in livestock emissions before the

benefits of the proposed control measure are applied. 2

 Reflects ARB staff’s external adjustment for geographic expansion of the Smog Check II program

(requested by the District in 2001 and implemented by BAR in 2002), which reduces VOC by 2.5 tpd

and NOx by 4.9 tpd in 2010. The District Plan refers to these reductions as new State commitments in

2010 associated with the 2003 PM10 Plan. 

3 Includes 1.0 tpd of VOC and 0.1 tpd NOx added to the baseline emission inventory to eliminate double

counting for emission reductions from ARB’s 2003 lawn and garden regulations, which are reflected in

the State’s new measures commitment. 

B. Emission Reduction Credits

According to U.S. EPA and ARB policy, emission reduction credits (ERC) banked

before a plan’s emission inventory baseyear must be explicitly treated as emissions in

the air. In other words, the plan must account for ERC use. The District does this by

including projected ERC use in the emission inventory growth factor. This plan’s

projections for ERC use and total growth in stationary source emissions between 2000

and 2010 are shown in Table III-2. 

Table III-2

Projected ERC Use and Stationary Emissions Growth 2000-2010

(San Joaquin Valley, Annual Average, in tons per day)

Pollutant ERC Use (tpd) Total Growth (tpd)

NOx 12.1 15.8

VOC 8.1 9.7

Projected ERC use is less than total growth for each pollutant. That is the minimum

criteria for the District’s approach to work. However, projected ERC use is large and

accounts for nearly all growth. Consequently, there is very little margin for nonpermitted

stationary sources to grow. As we have commented in the past, the District will need to

monitor both ERC use and growth in nonpermitted sources to ensure the sum of the two

does not exceed total growth.
-14-

C. Air Quality Modeling

The Act requires the use of air quality modeling to relate ozone levels to emissions in a

region and simulate future air quality based on changes in emissions. Modeling uses

day-specific emission inventories, with measurements of meteorology and air quality, to

establish this relationship. The performance of the model is determined by comparing

the modeled or predicted ozone value to the monitored or observed ozone level. 

As applied in this SIP, the end result of the modeling is to project the quantity of VOC

and NOx emissions that the Valley can accommodate while attaining the standard

(known as the attainment emissions target or carrying capacity). 

The modeling process involves a number of decisions along the way. These choices

include an ozone episode representative of days that exceed the standard and

appropriate scientific tools (like the air quality model, the meteorological model, and the

atmospheric chemistry mechanism for ozone formation) that can best predict ozone

levels. ARB and District staff made these decisions together, aided by input from

agency, industry, and scientific peer reviewers. 

The tools and data used in the modeling analysis for the 2004 Ozone SIP represent the

state-of–the-science and a significant step forward in our collective ability to understand

the level of emission controls needed to meet the ozone standards. The modeling

results meet the performance criteria established by both U.S. EPA and ARB. 

1. Ozone Episode

During Summer 2000, intensive measurements were made during two ozone episodes,

which occurred from July 30-August 2, and from September 17-21. In addition, a

“training episode” was captured on June 14-15. During the June episode, intensive

meteorological measurements were made, although the extensive CCOS air quality

monitoring system was not engaged.

The July/August 2000 episode was the only episode with exceedances in all three

regions of the San Joaquin Valley. This episode was characterized by localized high

ozone concentrations in the San Joaquin Valley, Bay Area, and Sacramento Region.

Westerly breezes in the Sacramento River delta occurred on most afternoons along with

mid-morning northwest flows in Sacramento.

2. Air Quality Model

ARB staff and modelers with the University of California at Riverside, together with

District staff, conducted extensive model performance evaluations with two

meteorological models, two air quality models, and two chemical mechanisms within the

air quality models. Each of the air quality models -- the Comprehensive Air Quality

Model with Extensions (CAMx), and U.S. EPA’s Models 3 – Community Multiscale Air

Quality (CMAQ) modeling -- met U.S. EPA model performance guidelines to varying
-15-

degrees on different episode days. Of the two air quality models, CAMx was best able

to simulate the unpaired peak concentrations during the July/August 2000 episode.

The period July 30 - August 2, 2000 was simulated using the CAMx air quality model,

alternatively with Carbon Bond IV and SAPRC99f chemical mechanisms. The

meteorological models MM5 and the CALMET/MM5 hybrid were also used to provide

inputs to CAMx. Overall model performance of CAMx using the CALMET/MM5 hybrid

and SAPRC99f was superior to that resulting from MM5 alone.

The attainment demonstration in this SIP uses the CAMx model, with the CALMET/MM5

hybrid meteorological model, and the SAPRC99f chemical mechanism.

3. Modeling Performance

Four of the Valley’s ozone monitors recorded 1-hour exceedances during the

July/August 2000 episode. Recorded values during the episode are shown in

Table III-3 below, with exceedances in bold.

Table III-3

Peak Ozone Values at Exceeding Monitors

July/August 2000 Episode

1-Hour Ozone Maximum Value, ppb Monitor July 30 July 31 August 1 August 2

Modesto 84 94 99 131

Turlock 80 105 104 131

Parlier 129 103 105 97

Edison 128 115 113 151

In selecting a day and location within the episode for the attainment demonstration,

ARB and District staff focused on the central and southern regions of the Valley, as the

District’s site with the highest design value (the design site) has historically fluctuated

between monitors in Fresno and Kern Counties.

ARB and District staff chose July 30 to determine the reductions needed for attainment

because that day had model performance that met acceptance criteria, had minimal fire

impacts, had the best match with design values, and provided the most conservative

estimates of further reductions needed for attainment. Table III-4 shows the relationship

between monitored and modeled values at the two Valley sites with the highest

measured ozone on July 30, the modeled 2010 ozone level using baseline inventories

that reflect adopted controls, and the maximum ozone level expected in each

surrounding county. The model may predict a peak ozone value at a location where

there is no monitoring site for comparison.
-16-

Table III-4

Monitored and Modeled Peaks

July/August 2000 Episode

Ozone Peak Values on Episode Days, ppb

July 30 August 2

Location 2000

Monitor

Value

2000

Modeled

Value

2010

Modeled

Value

2000

Monitor

Value

2000

Modeled

Value

2010

Modeled

Value

Parlier, Fresno County

Parlier Monitor 129 131 114 97 122 100

Fresno County

Modeled Peak - 144 128 - 137 119

Edison, Kern County

Edison Monitor 128 128 115 151 136 119

Kern County

Modeled Peak - 149 136 - 140 121

4. Attainment Emission Target

The Valley’s predicted 2010 peak ozone level based on already adopted controls is

136 ppb. To determine the level of emissions needed to bring this ozone value down to

the standard of 124 ppb, the SIP relies on graphical diagrams (called isopleths). ARB

staff produced these diagrams based on hundreds of model runs to assess the impact

of small incremental changes to VOC emissions, NOx emissions, and VOC plus NOx

emissions. The resulting chart shows how each of these incremental changes in VOC

and/or NOx emissions is predicted to change ozone levels. 

Starting with the 2010 baseline emissions, and using an equal percent reduction in VOC

and NOx emissions, District staff determined that a 14.5 percent reduction in each

pollutant would reduce the predicted peak ozone level to the federal standard. This

corresponds to a 2010 attainment emissions target of 314.4 tpd VOC and 343.5 tpd

NOx. Table III-5 summarizes the modeling results. 

Based on the modeling, other combinations of VOC and NOx emission reductions could

also reduce ozone levels to the federal standard. ARB staff believes that the equal

percent reduction option chosen by the District is a scientifically valid and effective

approach.

 

The control strategy identifies the measures that will be used to reach these emission

targets and demonstrate attainment of the federal 1-hour ozone standard. 
-17-

Table III-5

Modeling Summary for 2004 San Joaquin Valley Ozone SIP

Attainment

Emissions

Episode Target (tpd)

3-Year

Design

Value1

(ppb)

Peak

Concentration

Observed in

Episode

(ppb)

Peak

Concentration

Simulated by

Model in 20002

(ppb)

Peak

Concentration

Simulated by

Model from

2010 Baseline

Emissions2

(ppb) VOC NOx

July 30-August 2

2000 161 151 149 136 314.4 343.5

1

 The design value reflects the fourth highest observed ozone level in an area over the three year

period up to and including the year of the primary episode day. A design value of 124 ppb or less

equals attainment.

2

 The peak observed and predicted concentrations do not necessarily occur at the same location. 

5. Peer Review

Peer review of the modeling inputs, technical tools, and results occurred on several

levels. There were inventory work groups with representatives from multiple air

agencies, transportation agencies, and consultants. The experts on the CCOS

Technical Committee reviewed and provided feedback on all aspects of the modeling.

Overall, the Technical Committee concurred that the technical approach for the air

quality modeling used by ARB and District staff was reasonable. The modeling analysis

was circulated in both draft and proposed form for public review and comment.

D. Control Strategy

The Proposed 2004 Ozone SIP includes a control strategy to attain the federal 1-hour

ozone standard based on reductions from existing regulations as well as additional

reductions from enforceable commitments to adopt new control measures and clean

engine incentive programs. The District has lead responsibility for adopting and

implementing most stationary and area source controls; the transportation planning

agencies for vehicle activity-related strategies; ARB for most mobile sources, fuels, and

consumer products; the Bureau of Automotive Repair for vehicle inspection and

maintenance (Smog Check); the California Department of Pesticide Regulation for

pesticides; and U.S. EPA for national transportation sources and certain off-road farm

and construction equipment.

Table III-6 summarizes the control strategy to reach the attainment emissions target.

This section then describes the local, State, and federal measures contributing to

attainment. The combined control strategy provides enforceable measures or

commitments that meet the applicable requirements for approval. The District, local

transportation agencies, and ARB have previously demonstrated in the materials
-18-

supporting the 2002/2005 Ozone Rate-of-Progress Plan and the 2003 PM10 SIP that all

reasonably available control measures are being implemented or are committed for

implementation. The commitments in this plan for additional controls further strengthen

the SIP. 

Table III-6

Summary of Control Strategy for 2004 Ozone SIP

(San Joaquin Valley, Summer Planning, in tons per day)

VOC NOx

EMISSIONS

2000 baseline emissions 443.5 556.8

2010 baseline emissions 1 365.1 396.8

2010 attainment emissions target 314.4 343.5

REDUCTIONS BETWEEN 2000-2010

Total Emission Reductions Needed for Attainment 129.1 213.3

Measures adopted as of September 20021

 Local

 State

 Federal

Total

+8.52

-79.3

-7.6

-78.4

-18.9

-97.2

-43.9

-160.0

 Percent of needed reductions from adopted measures 61% 75%

Commitments for new defined measures

 District

 --- Adopted since September 2002

 --- Remaining PM10 SIP commitments

 --- New Ozone SIP commitments

 District Total

 State

 --- PM10 SIP commitments

 --- New Ozone SIP commitments

 State Total

 Total

-2.4

-7.0

-21.3

-30.7

--

-15.0

-15.0

-45.7

-12.2

-14.2

-1.9

-28.3

-10.0

-10.0

-20.0

-48.3

 Percent of needed reductions from new defined measures 35% 23%

Commitment for long-term measures

 District -5.0 -5.0

 Percent of needed reductions from long-term measures 4% 2%

1

 Reflects ARB staff’s external adjustment for geographic expansion of the Smog Check II program

(requested by the District in 2001 and implemented by BAR in 2002), which reduces VOC by 2.5 tpd

and NOx by 4.9 tpd in 2010. The District Plan refers to these reductions as new State commitments in

2010 associated with the 2003 PM10 Plan. 

2 Indicates a net increase in emissions because the effect of growth (primarily in livestock operations)

during this period is greater than the benefits of adopted controls. 
-19-

1. Local Measures

The 2004 Ozone SIP includes District control measures and incentive programs that

contribute to meeting progress and attainment targets. All of the emission reductions

from local control programs in the plan come from the District’s adopted rules, the

District’s commitments for new measures, or the District’s incentive program for cleaner

engines. The sources under District control account for 36 percent of the Valley’s

inventory of ozone-forming emissions (VOC plus NOx) in 2000, rising to 47 percent by

2010 before the benefits of new controls are applied. The Valley 2004 Ozone SIP relies

on the District’s existing control program and commitments for new measures to provide

nearly 80 tpd of VOC plus NOx reductions (net of growth), towards the total 340 tpd

required for attainment between 2000 and 2010. This local contribution amounts to

23 percent of the emission reduction target. Our evaluation focuses on the District’s

control strategy. 

The plan also contains local transportation-related strategies from Valley COGs and

MPOs that are not relied upon to demonstrate progress or attainment. These

transportation strategies help document the local approach to planning a transportation

system that seeks to lessen the impacts of travel growth on air quality, but the strategies

do not have quantified emission reductions associated with them. In the SIP, the

District and transportation planning agencies did not specifically identify any of these

strategies as transportation control measures or ask that they be considered as such for

purposes of transportation conformity. 

a. Adopted District Measures in Baseline 

The District has adopted prohibitory rules for a wide range of the stationary and

areawide sources under its jurisdiction. This plan includes the benefits of local, State,

and federal controls adopted through September 2002 as part of the 2010 baseline

emission inventory. Rules adopted after that date or with future adoption dates are

considered new measures. The September 2002 cutoff for defining what is in the

baseline versus what is considered a new measure allows the plan to be consistent with

the 2003 Valley PM10 SIP and ARB’s 2003 Statewide Strategy. Baseline District

measures reduce NOx by about 19 tpd between 2000 and 2010, but allow a net 8 tpd

increase in VOC emissions due to projected growth over the same timeframe. The

District’s full rulemaking agenda over the next several years will ensure net reductions

in both pollutants in the future. 
-20-

b. New Defined District Measures 

The category of new defined District measures includes those adopted subsequent to

the September 2002, remaining 2003 PM10 SIP commitments, and new Ozone SIP

commitments the District is proposing as part of this plan. 

The District has now adopted some of the PM10 SIP measures and an additional one

for lime kilns. The District is also taking credit for NOx emission reductions from its

clean engine incentive programs, based on the local portion of the total funding.

Table III-7 summarizes the District’s actions on these measures and the resulting

benefits. 

Table III-7

List of District Measures Adopted After September 2002

(San Joaquin Valley, Summer Planning, in tons per day)

2010

Reductions1

Rule Source Category Adoption

Date

Implementation

Date

VOC NOx

4408 Glycol Dehydration

Systems 12/19/02 12/31/03 1.8 --

4313 Lime Kilns 3/27/03 9/27/03 -- 0.1

4610 Glass Coating Operations 4/17/03 12/1/02 0.2 --

4306 Boilers, Steam Generators,

and Process Heaters 9/18/03 6/1/07 -- 7.1

4604 Can and Coil Coatings 1/15/04 2/1/06 0.4 --

Clean Engine Incentive

Programs2 - - -- 5.0

Totals 2.4 12.2

1 Emission reductions creditable against PM10 SIP commitments are different for some

measures because of the shift from annual average or winter season inventory used for

PM10 to the summer ozone season planning inventory shown here. 2

 Portion funded by local monies.

As shown in Table III-8, the District’s strategy relies on nine measures that are

remaining commitments from the PM10 SIP and that reduce VOC or NOx emissions.

The District also proposes to add commitments in this Ozone SIP for 12 new measures

(encompassing 21 rules).

Together, the District is committing to reduce emissions by an aggregate 28.3 tpd VOC

and 16.1 tpd NOx in 2010, through adoption of all new defined measures between 2004

and 2007, and with implementation beginning between 2005 and 2010. If the District

Board later finds one of the defined measures to be infeasible at a noticed public

hearing, the District’s SIP commitment requires the District Board to adopt alternative

measures sufficient to achieve equivalent aggregate emission reductions in the same

timeframe. 
-21-

Table III-8

New Defined District Measures for Attainment

(San Joaquin Valley, Summer Planning, 2010, in tons per day)

VOC NOx

SIP

# Source Category AdoptionDate

Full

Implementation

Date

Baseline

Emissions Reductions BaselineEmissions Reductions

Remaining PM10 SIP Commitments

A Oil and Gas Fugitives 3Q/04 1Q/05 10.2 -4.7 -- --

B Refinery and Chemical Fugitives 3Q/04 1Q/05 0.5 -0.2 -- --

D Indirect Source Mitigation 2Q/05 4Q/05 1 -- -- N/A -4.0

E Small Boilers, Process Heaters,

Steam Generators 2–5 MMBtu/hr 4Q/04 4Q/08 -- -- 9.0 -1.0

F Wineries – Fermentation&Storage 4Q/04 4Q/07 2.1 -0.7 -- --

H Stationary IC Engines 2Q/05 1Q/06 1 -- -- 20.1 -8.0

I Commercial Dryers 2Q/05 4Q/09 -- -- 9.0 -1.0

N Water Heaters, 0.075–2.0 Mbtu/hr 3Q/06 2025-

2035 -- -- 1.4 -0.2

O Steam-Enhanced Oil Well Vents 3Q/06 4Q/08 12.8 -1.4 -- --

Subtotal -7.0 -14.2

New Ozone SIP Commitments

C Fleet Rule – School Buses 4Q/04 2010-

2015 -- -- 2.6 -0.1

G Solid Fuel Boilers, Steam

Generators & Process Heaters 4Q/04 1Q/06 -- -- 4.4 <-0.05

J Composting/Biosolids Operations 2Q/05 2010 0.7 -0.1 -- --

K Automotive Coating 3Q/05 2Q/07 1.6 -0.1 -- --

L Concentrated Animal Feeding

Operations 2Q/06 1Q/07 1 63.1 -15.8 -- --

M

− Organic Solvent Degreasing

− Organic Solvent Cleaning

− Motor Vehicle and Mobile

Equipment Coating

− Surface Coating of Metal Parts

and Products

− Can and Coil Operations

− Aerospace Assemblies and

Component Coating

− Wood Products Coating

− Graphic Arts

− Adhesives

− Polyester Resin Operations

2Q/06 4Q/08 5.1 -1.3 -- --

P Soil Decontamination 4Q/06 2008 <0.05 <-0.05 -- --

Q Open Burning 1Q/07 2010 5.8 -2.9 2.3 -1.1

R Polymeric Foam Manufacturing 2Q/07 4Q/09 0.3 -0.1 -- --

S Stationary Gas Turbines (<10MW,

distributed generation)

2Q/07 2010 2.5 -0.6

T Gasoline Storage & Transfer 3Q/07 2010 3.4 -0.9 -- --

U Aviation Fuel Transfer, Phase I 3Q/07 2010 0.2 <-0.05 -- --

Subtotal -21.3 -1.9

TOTAL -28.3 -16.1

1

 Implementation begins
-22-

A summary of each proposed measure is presented below.

A. Oil and Gas Fugitives. This measure is committed to in the Valley’s 2003 PM10

Plan. It applies to sources involved in the production of crude oil, natural gas, and

natural gas liquids. These sources house pipes, valves, flanges, hatches, pumps,

compressors, and many other components with the potential to leak fluids or gases,

releasing fugitive VOC emissions. Controls could include lowering the permissible

gaseous leak threshold of 10,000 ppmv, eliminating some existing exemptions,

increasing the frequency of inspection, shortening the repair period for leaking

components, and replacing frequently leaking components.

B. Refinery and Chemical Fugitives. This measure applies to petroleum refineries

and gas-liquids processing facilities, and is a commitment in the Valley’s PM10 Plan.

These facilities house large numbers of components with the potential to leak fluids or

gases, causing fugitive VOC emissions. The measure would set lower leak thresholds,

require operators to conduct more frequent inspections of components, implement a

rigorous leak detection and repair program, and require Best Available Control

Technology (BACT) equipment to replace frequently leaking devices. 

C. Fleet Rule – School Buses. This measure would reduce NOx and PM10

emissions from bus fleets used for elementary and secondary schools. Reductions

would occur by replacing buses with newer, cleaner vehicles, by retrofitting existing

buses with cleaner burning engines or emission controls, or by modifying buses to use

cleaner-burning fuels. District staff indicates that the intent of this measure is to ensure

that bus purchases result in a cleaner fleet, aided by incentives to help school districts

finance the cost. 

D. Indirect Source Mitigation Fee. This proposal, committed to in the Valley’s 2003

PM10 Plan, would create a program to mitigate emissions from new development

projects that generate vehicle trips and area source emissions from other on-site

activities not subject to District permitting. These types of projects are referred to as

indirect sources. New development projects could be required to pay a mitigation fee to

mitigate a portion of their indirect emissions, or they could provide on-site mitigation.

Mitigation funds would be used to purchase cost-effective emission reductions. The

District is proposing to adopt this program in three phases. The first phase would apply

to residential development projects; the second phase to commercial and institutional

development projects; and the third phase to industrial development projects.

E. Small Boilers, Steam Generators and Process Heaters, from 2-5 MMBtu/hr.

This is a new measure, committed to in the Valley’s PM10 Plan, and applicable to small

boilers, steam generators, and process heaters, from 2-5 MMBtu/hr. Affected facilities

include hotels, hospitals, office buildings, schools, prisons and military facilities.

Combustion modifications appropriate for these units include low excess air, low NOx

burners, water/steam injection, and flue gas recirculation. Post-combustion treatment of

the exhaust stream may include selective catalytic reduction or selective non-catalytic

reduction. 
-23-

F. Wineries. This is a new measure, committed to in the Valley’s 2003 PM10 Plan,

and applicable to winery processes that produce significant VOC emissions via wine

fermentation and aging. The District determined that the emissions exceed the de

minimus threshold and are subject to Reasonably Available Control Technology (RACT)

requirements. The District does not currently regulate wine fermentation and aging.

VOC reduction could be achieved with vapor collection and control systems, carbon

adsorption, water scrubbers, catalytic incineration, condensation, and additional

temperature control. The District has refined the inventory for this category over the last

year. The measure anticipates the same control efficiency as in the PM10 Plan, with

the lower baseline inventory translating to lower expected reductions.

G. Solid Fuel Boilers, Steam Generators and Process Heaters. This measure,

committed to in the Valley’s 2003 PM10 Plan, would amend an existing rule. This rule

applies to facilities combusting biomass, municipal solid waste, tires, or petroleum coke.

The rule would be amended to apply to facilities with the potential to emit lower levels of

NOx. The District may also set more stringent emission limits.

H. Stationary IC Engines. This measure, committed to in the Valley’s 2003 PM10

Plan, would upgrade an existing rule that establishes opacity standards. Agriculture

irrigation engines are currently exempt from the opacity standards; the District plans to

remove the exemption.

I. Commercial Dryers. This is a new measure, committed to in the Valley’s PM10

Plan that will affect dryers used to remove water from process material by heating. The

District determined that these dryers exceed the de minimus threshold and are subject

to Best Available Control Measures (BACM) requirements for PM10. These units are

currently subject to District permitting requirements, but there is no specific rule.

Emission controls appropriate for dryers include Public Utilities Commission-quality

natural gas, low excess air, low NOx burners, and flue gas recirculation.

J. Composting/Biosolid Operations. This new measure would reduce VOC

emissions from the composting of biosolids, including sewage sludge, agricultural

waste, and other green waste (such as from residential landscaping). Controls could

include vapor collection and control systems, forced aeration, and windrow of materials.

K. Automotive Coating. This new measure would reduce VOC emissions from any

new or existing operations that apply coatings to automobile parts or accessories. This

measure would be amended to align with California Air Pollution Control Officers’

Association (CAPCOA) recommendations.

L. Concentrated Animal Feeding Operations. The District is proposing to reduce

VOC emissions from dairies, cattle feedlots, poultry ranches, and other agricultural

operations involving animal husbandry. VOC emissions may be reduced by controlling

emissions from feedlots and from supporting operations such as waste treatment

lagoons. The measure is intended to comply with California Health and Safety Code

Section 40724.6.
-24-

M. Organic Solvents Omnibus Measure. Ten District solvent rules would be

amended to satisfy “all feasible measure” requirements under the California Clean Air

Act. The commitment to amend these rules is being included in this SIP because the

resulting emission reductions are needed to attain the federal 1-hour ozone standard.

Since these rules were last amended, other districts have started requiring lower-VOC

solvents at a level of 25 grams of VOC per liter. This new standard would be

incorporated into the rules.

N. Water Heaters 75,000 Btu/hr to 2 MMBtu/hr. This is a new measure, committed to

in the Valley’s PM10 Plan, and applicable to industrial, commercial, and institutional

water heaters. These sources are currently not regulated by the District. NOx

prohibitory rules may be coupled with a financial incentive program to accelerate the

replacement or retrofit of higher-polluting units. While the PM10 Plan committed to an

adoption date for this measure in 4Q/04, the Ozone SIP commits to adoption in 3Q/06.

The District projects that full implementation of this rule will extend out 20 to 30 years

based on the current pace of replacement for existing water heaters.

O. Steam-Enhanced Crude Oil Production Well Vents. This is an upgrade to an

existing rule, and is a commitment in the Valley’s PM10 Plan. This measure would

reduce VOC emissions from steam-enhanced crude oil production wells, and any

associated vapor collection and control systems. Emission reductions can be achieved

by lowering the rule exemption thresholds.

P. Soil Decontamination. This measure is an upgrade to an existing rule designed to

reduce VOC emissions created during activities in the remediation of contaminated

soils.

Q. Open Burning. The District’s open burning rule will be amended pursuant to

California Health and Safety Code Section 41855.5(a), which phases out open burning

between 2005 and 2010, and exemptions allowed for disease control. The exact

reductions achievable by this rule will depend on the extent to which open burning

practices can be replaced by cost-effective technologically feasible alternatives.

R. Polymeric Foam Manufacturing. This rule amendment would reduce VOC

emissions from manufacturing polymeric foam and foam products by specifying material

VOC content limits and emission control devices. This rule would be expanded to

include VOC emission reduction or control from product curing areas and general

product storage, similar to those employed by several of the existing sources. Possible

controls for this category include switching to an alternative, non-VOC blowing agent or

employing capture and control systems for the VOC emissions.

S. Stationary Gas Turbines. This measure would amend the District’s stationary gas

turbine rule, which was last amended in 2002. Since then, ARB published emission

standards for turbines used in electrical power generation. Turbines rated greater than

10 MW are subject to District requirements similar to the ARB limits. The control
-25-

measure would examine the feasibility of ARB NOx and carbon monoxide limits for

stationary gas turbines, rated <10.0 MW. 

T. Gasoline Storage and Transfer. This measure would reduce fugitive VOC

emissions occurring at gasoline terminals and bulk plants. More stringent rules

standards would be set, together with possible control enhancements such as increased

inspection and maintenance frequencies, tank seal repair or replacement, and

retrofitting old systems with newer technologies.

U. Aviation Fuel Transfer, Phase I. The new measure would reduce fugitive VOC

emissions created during Phase 1 refueling operations, including filling aviation fuel bulk

storage tanks using primary fuel delivery trucks, and filling an airport’s fuel delivery

trucks from the bulk storage tanks. The measure does not propose to cover the

process of filling the aircraft’s onboard fuel tanks. Fugitive emissions from storage and

delivery can be controlled with pressure-vacuum relief valves on storage tanks,

submerged fill tubes to reduce splashing, and vapor recovery or destruction systems

similar to those used for Phase I motor vehicle fueling operations.

c. Compliance With Other Extreme Area Requirements

As an extreme nonattainment area, the District must adopt RACT control measures

applicable to sources with emissions greater than 10 tons per year of an ozone

precursor, rather than the current 25 tons per year cutoff applicable to severe areas.

The District must also upgrade its rules for the Title V federal operating permits program

and New Source Review to comply with extreme area requirements. All three elements

are due for submittal to U.S. EPA by May 16, 2005. The plan includes the District’s

commitment to meet this deadline.

The District evaluated sources with VOC or NOx emissions ranging from 10-25 tons per

year, and identified three RACT measures: Dryers and Dehydrators; Flares; and Jet

Engines and Test Cells. The District is proposing to address the Dryer and Dehydrator

category as a near-term measure. Similarly, sources with emissions from 10-25 tons

per year will become subject to the District’s existing Flares rule once the District

amends its definition of major sources in the District’s New Source Review (NSR) rule to

reflect its extreme classification. With respect to Jet Engines and Test Cells, the District

was unable to identify viable control measures. The District is listing this as a further

study measure and will investigate potential controls. Meanwhile, these sources will be

brought into the Title V program when the District modifies its NSR rule.

The District states that rules and practices already satisfy the extreme area requirement

that clean fuels (like natural gas) be used in boilers (per Act section 182(e)(3)).
-26-

2. State Measures

The emission sources under State regulatory jurisdiction (e.g., vehicles, fuels, some offroad equipment, and consumer products) are a significant contributor to the Valley’s

pollution problems. These sources under State control account for 46 percent of the

Valley’s inventory of ozone-forming emissions (VOC plus NOx) in 2000, becoming a

smaller share (37 percent) of the total by 2010 in response to cleaner vehicles and

fuels. The Valley 2004 Ozone SIP relies on the State’s existing control program and

prior commitments for new State measures to provide over 210 tpd of the total 342 tpd

emission reductions required for attainment between 2000 and 2010. This State

contribution amounts to 62 percent of the emission reduction target. 

a. Adopted State Measures in Baseline 

ARB regulations on the books as of 2002 are providing 176 tpd of emission reductions –

these include the Low-Emission Vehicle Program and California Reformulated Gasoline,

together with a series of progressively tighter emission standards for new engines used

in big diesel trucks and heavy equipment, forklifts and pumps, lawn and garden

equipment, pleasurecraft, and over 100 categories of consumer products. To

complement these regulatory programs, the State has contributed over $60 million since

1998 to fund a variety of District clean engine incentive programs throughout the Valley. 

The Bureau of Automotive Repair’s (BAR) Smog Check program is also providing

essential reductions in the Valley. The District took an important step in 2001 to request

that BAR expand the most rigorous form of the program to apply beyond the major

urban areas. BAR implemented Smog Check II in six additional Valley cities in 2002.

This increased the portion of the Valley’s fleet subject to Smog Check II to 95 percent.

The benefits of this change are reflected as an external adjustment to the baseline

inventory in this report since the expansion was in place by 2002. 

b. New Defined State Measures 

The Board has previously approved commitments to develop new State measures that

will generate further emission reductions in the Valley. State commitments for 10 tons

of NOx reductions from these measures were already submitted to and approved by

U.S. EPA as part of the Valley’s 2003 PM10 SIP. ARB will add 15 tpd VOC and another

10 tpd NOx to generate a total combined State commitment of 35 tpd VOC plus NOx for

this Ozone SIP.

To help achieve the federal health-based air quality standards, ARB adopted the

2003 State and Federal Strategy for the California State Implementation Plan

(Statewide Strategy) on October 23, 2003. ARB submitted the Statewide Strategy to

the U.S. EPA for approval as a revision to the California SIP on January 4, 2004.
-27-

The Statewide Strategy identifies the Board’s near-term regulatory agenda to reduce

ozone and particulate matter by developing and adopting new measures from 2002

through 2009, with implementation prior to the 2010 ozone season. It includes: 

• Commitments for the Board to consider 19 specific statewide measures. 

• BAR’s planned improvements to the Smog Check program. The recent repeal of the

rolling 30-year exemption for older vehicles will further increase the air quality

benefits of the program. 

• Continuation of the Department of Pesticide Regulation’s approved SIP obligation1

to reduce volatile emissions from pesticides. For the San Joaquin Valley, this

means a pesticide VOC emissions target of 12 percent less than 1990 levels.

 

The Statewide Strategy also describes a process to identify longer-term solutions to

achieve additional reductions from sources under State, federal, and local control. 

The defined control measures in the Statewide Strategy cover on-road vehicles, off-road

equipment, ports and harborcraft, fuels and refueling, and consumer products. Lower

emission standards for new engines and consumer products are complemented by

measures to clean up the existing fleet of mobile sources. Other measures would

reduce vapor emissions from gasoline storage and refueling. These defined measures

are listed in Table III-9. The Statewide Strategy, which includes detailed descriptions of

each measure, is available at http://www.arb.ca.gov/planning/sip/stfed03/stfed03.htm.

Public Process. The 2003 Statewide Strategy relied on an extensive public process.

Using feedback from workshops in 2001, staff compiled a list of potential control

measures for sources under State, federal, and local control. In 2003, staff participated

in eleven public workshops with the local air districts in the South Coast and San

Joaquin Valley, as well as an ARB technical workshop in both those regions plus

Sacramento, to discuss the draft Statewide Strategy. ARB staff considered the public

concerns and suggestions voiced at these workshops and additional stakeholder

meetings, as well as over 300 comment letters. Staff incorporated revisions into the

proposed Strategy and recommended further changes in response to public comment.

In October 2003, the Board held a public hearing and approved the 2003 State and

Federal Strategy for the California SIP. 

Current Implementation Status. ARB is actively working to implement the Statewide

Strategy. Several of the measures in the Strategy are comprehensive approaches for

the source category, encompassing multiple rulemakings or other actions that will

contribute to the total reductions expected. As of September 1, 2004, ARB has taken

action on the following measures, which provide benefits towards the State’s

commitment for emission reductions beyond the 2010 baseline. 

 

1 40 CFR Part 52, Federal Register, January 8, 1997, pages 1150-1187.
-28-

• The low sulfur diesel fuel regulation adopted in July 2003 fulfills SIP measure

FUEL-2.

• The small off-road engine emission standards adopted in September 2003 fulfill SIP

measures SMALL OFF-RD-1 and SMALL OFF-RD-2.

• The particulate matter control measure for diesel-powered solid waste collection

vehicles adopted September 2003 fulfills part of SIP measure ON-RD HVY DUTY-3.

• The voluntary emission control software upgrade program for diesel trucks approved

in March 2004 fulfills part of SIP measure ON-RD HVY DUTY-3. This voluntary

measure includes a regulatory backstop to ensure that the anticipated emission

reductions occur by 2010.

• The engine manufacturer diagnostics requirements for new diesel trucks adopted in

May 2004 fulfill part of SIP measure ON-RD HVY DUTY-3.

• The consumer products regulation adopted in June 2004 fulfill SIP measure CONS-1.

• The restriction on idling time for commercial diesel trucks and vehicles adopted in

July 2004 fulfills part of SIP measure ON-RD HVY DUTY-3.

• By 2004, ARB had begun implementing an expanded community-based inspection

program for diesel trucks and buses, fulfilling SIP measure ON-RD HVY DUTY-1.

• In addition to these defined SIP measures, ARB adopted three controls for diesel

stationary engines, portable engines, and transportation refrigeration units in

February 2004 that will contribute to meeting the State’s obligations. 

In addition, BAR has implemented two of the three Smog Check improvements

(directing more vehicles to Test-Only stations and requiring dynamometer testing for

heavier gasoline vehicles up to 9,999 pounds gross vehicle weight rating). These

improvements fulfill part of SIP measure LT/MED-DUTY-2.

State Funding for Incentive Programs. The Statewide Strategy discusses the need

to obtain continued funding for the Carl Moyer incentive program to supplement

regulatory actions requiring clean up of the existing fleet of diesel vehicles and

equipment. Governor Schwarzenegger’s approval of the current State budget

established a permanent source of funding for the Moyer program at $61 million per

year statewide, with the Valley due to receive several million annually. The projects

funded with these State monies will provide emission reductions creditable towards the

State’s obligation. 

A coalition of industry, environmental, and government stakeholders has also been

working legislatively to secure additional incentive funding to further accelerate cleanup

of air pollution sources. On September 23, the Governor signed a bill that authorizes

another $80 million per year of combined State and local monies for a broad range of

incentive programs to reduce mobile source pollution. The new local monies are

expected to come in response to the authorization for local air districts to raise the

motor vehicle registration fee that consumers pay to support air quality programs by $2

per vehicle per year.
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State Emission Reduction Commitment. In Resolution No. 03-22, adopting the

Statewide Strategy, the Board delegated 

“...authority to the Executive Officer to calculate and commit to new emission

reductions from implementation of the Final Statewide Strategy that she

determines to be appropriate for specific areas violating the NAAQS in California,

as attainment SIPs are developed or revised in those areas."

ARB commits to adopt and implement measures to achieve, at a minimum, 15 tpd VOC

and 20 tpd NOx emission reductions in the San Joaquin Valley Air Basin by the 2010

ozone season as part of the attainment demonstration for the federal 1-hour ozone

standard. Measures to achieve these reductions will be adopted by 2009. ARB may

meet this commitment by adopting one or more of the control measures in Table III-9,

by adopting one or more alternative control measures, or by implementing incentive

program(s), so long as the aggregate emission reduction commitment is achieved.

ARB’s prior commitment to achieve 10 tpd of new NOx reductions as part of the Valley

PM10 SIP is a subset of the 20 tpd NOx discussed here.
-30-

Table III-9

Defined State Measures from the 2003 Statewide Strategy

Strategy

(Agency) Name

LT/MED-DUTY-1

(ARB) Replace or Upgrade Emission Control Systems on Existing Passenger Vehicles 

LT/MED-DUTY-2

(BAR) Improve Smog Check to Reduce Emissions from Existing Passenger & Cargo Vehicles

ON-RD HVY DUTY-1

(ARB) Augment Truck and Bus Highway Inspections with Community-Based Inspections

ON-RD HVY DUTY-2

(ARB) Capture and Control Vapors from Gasoline Cargo Tankers

ON-RD HVY DUTY-3

(ARB) Pursue Approaches to Clean Up the Existing and New Truck/Bus Fleet 

OFF-RD CI-1

(ARB)

Pursue Approaches to Clean Up the Existing Heavy-Duty Off-Road Equipment Fleet

(Compression Ignition Engines) 

OFF-RD CI-2

(ARB)

Implement Registration and Inspection Program for Existing Off-Road Equipment to Detect

Excess Emissions (Compression Ignition Engines)

OFF-RD LSI-1

(ARB)

Set Lower Emission Standards for New Off-Road Gas Engines (Spark Ignited Engines 25

hp and Greater)

OFF-RD LSI-2

(ARB)

Clean Up Existing Off-Road Gas Equipment Through Retrofit Controls and New Emission

Standards (Spark-Ignition Engines 25 hp and Greater)

SMALL OFF-RD-1

(ARB)

Set Lower Emission Standards for New Handheld Small Engines and Equipment (Spark

Ignited Engines Under 25 hp such as Weed Trimmers, Leaf Blowers, and Chainsaws) 

SMALL OFF-RD-2

(ARB)

Set Lower Emission Standards for New Non-Handheld Small Engines and Equipment

(Spark Ignited Engines Under 25 hp such as Lawnmowers)

MARINE-1

(ARB)

Pursue Approaches to Clean Up the Existing Harbor Craft Fleet –Cleaner Engines and

Fuels

MARINE-2

(ARB)

Pursue Approaches to Reduce Land-Based Port Emissions – Alternative Fuels, Cleaner

Engines, Retrofit Controls, Electrification, Education Programs, Operational Controls

FUEL-1

(ARB) Set Additives Standards for Diesel Fuel to Control Engine Deposits

FUEL-2

(ARB) 

Set Low-Sulfur Standards for Diesel Fuel for Trucks/Buses, Off-Road Equipment, and

Stationary Engines

CONS-1

(ARB) Set New Consumer Products Limits for 2006

CONS-2

(ARB) Set New Consumer Products Limits for 2008-2010

FVR-1

(ARB) Increase Recovery of Fuel Vapors from Aboveground Storage Tanks

FVR-2

(ARB) Recover Fuel Vapors from Gasoline Dispensing at Marinas

FVR-3

(ARB) Reduce Fuel Permeation Through Gasoline Dispenser Hoses

PEST-1

(DPR) Implement Existing Pesticide Strategy
-31-

3. Federal Measures

The emission sources under the legal or practical control of the federal government

include heavy-duty diesel trucks registered outside California, some new farm and

construction equipment, locomotives, and aircraft. These federal sources account for

18 percent of the Valley’s inventory of ozone-forming emissions (VOC plus NOx) in

2000. Nationwide regulations promulgated by U.S. EPA achieve over 50 tpd of

emission reductions in the Valley between 2000 and 2010, contributing 15 percent of

the total reductions needed for attainment in this SIP. There are no additional federal

measures included in this plan. 

Although U.S. EPA is developing additional rules to reduce emissions from federal

sources, the timeline for achieving reductions is beyond the 2010 attainment deadline of

this SIP. U.S. EPA recently adopted more stringent emission standards and low-sulfur

diesel fuel requirements for new off-road diesel equipment, based on the transfer of

emission control technology for on-road engines. The benefits will be critical in the

post-2010 timeframe, both to offset growth in goods movement and to make progress

toward the federal 8-hour ozone and PM2.5 standards. U.S. EPA also released an

advance notice of proposed rulemaking to phase in more stringent emission standards

for locomotives and ships nationwide, with implementation beginning post-2010. ARB

has provided extensive comments on this proposal, urging the federal government to

set the most effective emission standards possible and to accelerate implementation.

Such federal action will be essential as the Valley transitions to the 8-hour ozone

standard.

In the 2010 timeframe, we need the federal government to focus on funding an incentive

program to clean up diesel engines that parallels California’s Moyer program. The

benefits realized from federal incentives would help deal with the remaining 10 tpd of

reductions needed from long-term measures in this plan. 

ARB will continue to push U.S. EPA to achieve its fair share of the emission reductions

needed to meet health-based air quality standards in the Valley and across California.

4. Long-Term Measures

The federal Clean Air Act recognizes that extreme ozone nonattainment areas, such as

the San Joaquin Valley, must rely on evolving technologies to meet attainment goals. 

After accounting for the anticipated benefits of both adopted and new defined State and

local measures, the 2004 Ozone SIP demonstrates a need for another 5 tpd VOC

reductions and 5 tpd NOx reductions from long-term measures. This represents three

percent of the total reductions needed for attainment between 2000 and 2010. The

District is committing to identify and adopt long-term measures to achieve the last 10

tpd VOC plus NOx reductions. In 2007, the District will reevaluate the 1-hour ozone

attainment control strategy using available new information on ozone formation. At that

time, the District will add new measures as warranted by the updated assessment.
-32-

In this plan, the District has already begun the process of identifying additional

strategies via the described “further study measures” and “future study measures.”

a. Further Study Measures

Further study measures are potential measures from emission categories without

adequately developed emission inventories or for which emission control strategies

must be further researched and developed. Some of these may be developed into

control measures in 2006 or later, yielding emission reductions in the pre-2010

timeframe. Others may be discarded after District evaluation.

The further study measures address the following source categories:

• Portable equipment registration program;

• Asphalt plant dryers/heaters;

• Sumps, pits and wastewater processing equipment;

• Heavy oil stream fugitives;

• Adhesives;

• Graphic arts;

• Cutback asphalt application;

• Under-fired restaurant charbroilers;

• Residential water heaters;

• Furnaces; and

• Brandy production.

ARB staff has comments on three of the further study measures, as described below.

Staff has relied on recent rule stringency assessments by the California Air Pollution

Control Officers Association (CAPCOA) and four districts in central California. The four

Districts -- the Bay Area Air Quality Management District, Sacramento Metropolitan Air

Quality Management District, San Joaquin Valley District, and Yolo-Solano Air Quality

Management District – have worked together with ARB to compare the technical

requirements of their rules against each other and the best in the State. The goal of this

exercise is to identify source categories with potential additional reductions.

Adhesives: This measure was identified on both the four District comparison list and

CAPCOA’s All Feasible Measures list. ARB staff suggests the District prioritize review

of this category when evaluating the further study measures.

Graphic Arts: The four District comparison did not find sufficient differences between

the Districts’ rules to warrant amendments. However this category was identified in

CAPCOA’s All Feasible Measures list. ARB staff suggests the District prioritize review

of this category when evaluating the further study measures.
-33-

Portable Engines. In February 2004, ARB adopted an airborne toxic control measure

for portable engines that applies statewide. Districts may choose to adopt their own

version, which must be at least as stringent as the State rule. The timeframe for

implementation of the ARB toxics measure is compatible with a further study measure

for the District. The State measure affects all diesel-fueled portable engines that are

larger than 50 horsepower. Included are engines registered under ARB’s Portable

Equipment Registration Program, engines permitted by the districts, and engines

historically exempt from district permits. The measure requires all portable engines to

be certified to U.S. EPA /ARB off-road engine standards by 2010. After 2010, it

requires all fleets of portable engines to meet diesel PM emission averages that

become more stringent in 2013, 2017, and 2020. The measure will also achieve

reductions in NOx through expedited engine replacement.

b. Future Study Measures

Stakeholders at District workshops on the 2004 Ozone SIP have suggested control

measure concepts for mobile sources. The District will investigate the feasibility of

these additional programs that reduce emissions from mobile sources. The stakeholder

suggestions target:

• Detection of gross emitting passenger and heavy-duty vehicles via remote sensing;

• Enforcement of truck speed limits;

• Funding for ARB to increase its heavy-duty vehicle roadside inspections;

• Designation of a no through-truck traffic route along Highway 99;

• Restrictions on truck idling; and

• Revising the vehicle registration fee structure to charge according to emissions

rather than value of the vehicle.

In addition, the District also lists as future study measures programs for emissions from

non-mobile sources, such as vegetation used for landscaping. 

The State is already working on two of these concepts. ARB and BAR are conducting a

pilot study to evaluate the effectiveness of remote sensing equipment in identifying

gross emitting vehicles. Also, the Bureau is restarting its vehicle retirement program.

Eligible consumers whose vehicles fail the Smog Check test can opt to retire their

vehicle and receive $500, based on available funds. 

In July 2004, ARB adopted an airborne toxic control measure to limit diesel-fueled

commercial motor vehicle idling. The new measure will restrict idling of diesel-fueled

commercial motor vehicles with a gross vehicle weight rating greater than 10,000

pounds to no more than five minutes at any location. The Board will consider a

companion measure next year that addresses idling in sleeper cabs.
-34-

5. Contingency Measures

Contingency measures are intended to provide additional reductions in case the control

measures identified for attainment and progress do not deliver the expected reductions.

Contingency measures are therefore required both for the 2008 progress milestone, the

2010 progress milestone, and the 2010 attainment demonstration.

To meet rate of progress requirements for 2008 and 2010, the District relies on adopted

measures, increasing the certainty that the emission reductions will be achieved as

expected. Contingency reductions for this plan are provided by the District’s

commitments for new measures and the growing emission reductions from turnover of

the vehicle fleet to cleaner models under ARB’s regulations. 

The District is subject to a requirement for contingency measures unique to extreme

areas. Three years before the proposed implementation date, the District will submit

enforceable commitments to develop and adopt contingency measures if the advanced

technology measures do not achieve planned reductions. For purposes of U.S. EPA’s

review under section 110(k) of the Clean Air Act, these measures should be treated in

the same way as fully adopted rules because they are fully developed in the manner

contemplated by the Act at this point in time. The timing of this requirement dovetails

with submittal of the 8-hour ozone SIP in June 2007, and the expected transition to the

federal 8-hour standard.

E. Attainment Demonstration

Table III-10 summaries the Valley’s attainment demonstration for the federal 1-hour

ozone standard. The 2010 attainment emission targets are 314.4 tpd VOC and 343.5

tpd NOx. The attainment demonstration relies on a combination of reductions from

already adopted local, State, and federal controls, both local and State commitments for

new reductions, and finally, reductions from future measures authorized by section

182(e)(5) of the Federal Clean Air Act.

Table III-10

Control Strategy for 2004 Ozone SIP

(San Joaquin Valley, Summer Planning, tons per day)

VOC NOx

Emissions

2000 baseline emissions 443.5 556.8

Emission reductions, 2000-2010 

--- Measures adopted as of September 2002

--- Commitments for near-term defined measures 

--- Commitment for further reductions from long-term measures

Total

-78.4

-45.7

-5.0

-129.1

-160.0

-48.3

-5.0

-213.3

Modeled 2010 attainment emissions target 314.4 343.5
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F. Rate-of-Progress Demonstration

In addition to developing an attainment demonstration as part of the San Joaquin

Valley’s reclassification to extreme, the District is also required to show sufficient

emission reductions to achieve the required rate-of-progress (ROP). As a severe area,

the District adopted and submitted an ROP Plan for 2002 and 2005. U.S. EPA found

adequate for transportation conformity purposes the motor vehicle emission budgets in

that plan on July 10, 2003. On September 4, 2003, U.S. EPA found the 2002 and 2005

ROP Plan to be complete.

The purpose of the ROP requirement is to ensure that nonattainment areas make

steady progress toward their attainment goals. Areas must reduce their emissions of

VOC by three percent per year, averaged over a three-year period Specifically, the

Valley must demonstrate that its VOC emissions in 2008 are 51 percent below the

levels in 1990, the baseline year for ROP plans. In addition, 2010 VOC emissions must

be shown to be at or below 57 percent of the 1990 levels. NOx reductions may be

substituted for VOC reductions on an equivalent basis, to the extent that NOx

reductions are necessary for attainment. 

U.S. EPA has expressed a policy preference for using reductions from adopted controls,

instead of from commitments, in ROP demonstrations.2,3 The District is revising the

ROP demonstration for 2008 and 2010 in the Proposed 2004 Ozone SIP to show that

the Valley meets the progress requirements on the strength of adopted measures alone.

The District takes credit for reductions from all adopted VOC measures and also relies

on substitution of NOx reductions from adopted measures. Table III-11 summarize the

key steps in the revised ROP demonstration.

 

2 U.S. EPA, memorandum, Guidance on Issue Related to 15 Percent Rate-of-Progress Plans, August 23, 1993. 3

 U.S. EPA, memorandum, November 1994 Submittal Policy, September 1, 1994.
-36-

Table III-11

Rate of Progress Demonstration with Adopted Measures Only

(San Joaquin Valley, Summer Planning, in tons per day)

2008 Milestone

Line

No. ROP Demonstration Steps Emissions 

1 Adjusted 1990 VOC inventory 1 553.0

2 VOC reductions required from 1990-2008 (51% of line 1) 282.0

3 VOC reductions from adopted measures, 1990-2008 183.6

4 VOC reduction shortfall in 2008 98.4

5 VOC-equivalent NOx reduction needed 2 125.1

6 NOx reductions, 1990-2008, from adopted measures available for

substitution 3 291.6

7 NOx reductions used for substitution 125.1

8 NOx emissions remaining after substitution>attainment target? Yes

9 Rate of Progress Achieved in 2008? Yes

2010 Milestone

Line

No. ROP Demonstration Steps Emissions 

1 Adjusted 1990 VOC inventory 1 548.5

2 VOC reductions required from 1990-2010 (57% of line 1) 312.6

3 VOC reductions from adopted measures, 1990-2010 185.6

4 VOC reduction shortfall in 2010 126.8

5 VOC-equivalent NOx reduction needed 2 161.2

6 NOx reductions, 1990-2010, from adopted measures available for

substitution 3 192.9

7 NOx used for substitution 161.2

8 NOx emissions remaining after substitution>attainment target? Yes

9 Rate of Progress Achieved in 2010? Yes

1

 Baseline inventory of 633.1 tpd is reduced by 80.2 tpd for 2008 milestone, and by 84.7 tpd for 2010

milestone, to account for noncreditable reductions from the federal motor vehicle control program. 2

 Computed by multiplying the VOC shortfall by 1.27 to reflect the VOC/NOx ratio in the baseyear. 3

 After subtracting out NOx reductions used in previous milestone years for substitution.
-37-

G. Transportation Conformity Budgets

This Plan establishes county level on-road motor vehicle emissions transportation

conformity budgets for the years 2008 and 2010. The emissions budgets reflect the

latest planning assumptions and were developed using ARB’s latest on-road mobile

source emission factor model EMFAC2002 (approved by U.S. EPA on April 1, 2003).

The Valley’s 2002/2005 Ozone Rate of Progress Plan contained budgets for 2002 and

2005, which U.S. EPA found adequate, effective August 8, 2003.

The new emissions budget, based on summer planning daily emissions for VOC and

NOx, are shown in Table III-12. The budgets are matched to activity data reported by

the eight county Councils of Government using ARB's VMT matching methodology.

These results are adjusted to account for any baseline emission reductions not included

in the model. Finally, the new State and local commitments to reduce on-road vehicle

and road construction emissions are subtracted from the adjusted baseline to arrive at

the conformity budgets. These budgets would become applicable when U.S. EPA finds

the budgets adequate. Conformity assessments for these budgets will use the emission

factors in this SIP with updated activity. 

Table III-12

Sub-Area On-Road Motor Vehicle Emission Budgets for Ozone 1 

(San Joaquin Valley, Summer Planning, in tons per day)

2008 2010

County VOC NOx VOC NOx

Fresno 15.8 33.7 13.0 27.7

Kern (SJVAB) 11.5 32.7 9.6 27.2

Kings 2.5 6.2 2.1 5.4

Madera 3.9 8.4 3.3 7.2

Merced 5.0 11.4 4.0 9.1

San Joaquin 9.3 22.4 7.7 17.9

Stanislaus 8.5 17.4 7.0 14.0

Tulare 8.5 18.8 6.9 15.3

Total2 65.0 151.0 53.6 123.8

1

 The District released these revised budget numbers on October 8, 2004.

2

 Total is for informational purposes only.

The emission budgets established in this plan fulfill the requirements of the Act and

U.S. EPA regulations to ensure that transportation activities support progress and

attainment of the federal 1-hour ozone standard.
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IV. FUTURE FEDERAL OZONE PLANS

The District must develop a new ozone plan in less than three years to meet federal

requirements for 8-hour ozone, and satisfy any outstanding requirements applicable to

1-hour ozone planning. 

A. 2007 1-Hour Ozone Plan Update

The 2004 Ozone SIP does not fully define all measures needed for attainment of the

federal 1-hour ozone standard in 2010. The District proposes defining and adopting

long-term measures in 2007. The District will reassess the emission reductions needed

at that time, using the latest information on ozone formation, available control strategies,

and precursor inventories. The District will develop and submit a 1-hour SIP update

including defined long-term measures in 2007.

B. 8-Hour Ozone Plans

ARB and the districts across Northern California have kicked off the process of

developing 8-hour plans. The Valley must submit two types of 8-hour plans: an 8-hour

rate of progress plan and an 8-hour attainment demonstration plan that is due June

2007. As a serious 8-hour ozone nonattainment area, the Valley’s 8-hour attainment

date is 2013.

Staff from ARB and the 8-hour ozone nonattainment districts in central California have

already met several times to discuss development of 8-hour ozone SIPs. This major

collaborative undertaking will rely on upcoming emission inventory upgrades,

enhancements to CCOS modeling, and will benefit from a joint review of the relative

stringency of local controls. Staff is coordinating on sharing resources, and is mapping

out schedules for deliverables needed for SIP development. 
-39-

V. ENVIRONMENTAL IMPACTS

The California Environmental Quality Act (CEQA) requires that State and local agency

projects be assessed for potential significant environmental impacts. Air quality plans

are “projects” that are potentially subject to CEQA requirements. In its Notice of

Preparation/Initial Study for this plan, the District identified three areas with potential for

significant impacts (air quality, utilities/service systems, and water) and therefore

warranting evaluation in a Draft Environmental Impact Report (EIR). In the Draft EIR,

District staff determined that there were no significant impacts in these areas.

The Draft EIR evaluated all the proposed near-term control measures (Control

Measures A through U), all of the further study measures (Further Study Measures A

through K), and the future study measures. In addition, the Draft EIR evaluated three

feasible alternatives to the 2010 Ozone SIP and found that the SIP approach was

environmentally superior.

We reviewed the Draft EIR prepared by the District, and find that it accurately describes

the potential environmental impacts of the plan. Staff concurs with the District’s

conclusions and finds that the District has met its obligations under CEQA.

The 2003 Statewide Strategy was already subject to a separate environmental review

under CEQA prior to adoption by the Board. Our evaluation is presented in the

2003 State and Federal Strategy for the California State Implementation Plan.

Environmental Justice. In December 2001, ARB adopted a set of policies and

associated actions that provide the framework for incorporating environmental justice

into ARB’s programs consistent with the directives of State law. The policies and

actions are based on State law, which describes "environmental justice" as "the fair

treatment of people of all races, cultures, and incomes with respect to the development,

adoption, implementation, and enforcement of environmental laws, regulations, and

policies." ARB’s environmental justice policies help ensure that we take into account

neighborhood impacts as we prioritize and develop controls and pollution-prevention

strategies.

The environmental justice policies touch virtually every ARB program, including motor

vehicles, air-quality planning, toxics, research, enforcement, and air monitoring. They

apply to all communities in California but recognize that extra efforts may be needed in

some communities due to historical land-use patterns, limited participation in public

processes in the past, and a greater concentration of air pollution sources in these

communities. 

The 2003 Statewide Strategy included in the Valley’s 2004 Ozone SIP reflects our

environmental justice policies. While all of the new State measures would result in

better air quality for residents throughout California, we are making measures that cut

exposure and risk in communities with high air pollution burdens a high priority for

development. ARB has focused on controlling particulate emissions from diesel
-40-

engines, the dominant source in California of known risk from air toxics. ARB has

already adopted measures to reduce diesel emissions from trash trucks, stationary and

portable engines, transportation refrigeration units, and truck idling. Board staff have

begun conducting more truck inspections in communities with high truck traffic as well. 

ARB staff is committed to working with districts, local governments, and affected

communities to improve statewide compliance for all air pollution sources, whether

under ARB or district jurisdiction. ARB staff has already begun to incorporate

environmental justice perspectives into our program activities. ARB staff is working with

districts to assure that all air pollution complaints are promptly investigated and that

feedback is provided to the public on the actions taken in response to those complaints.

ARB staff is also working with the local air districts to improve accessibility of

information regarding enforcement activities, including notices of violations, monetary

penalties, and other settlement of violations. ARB is also reviewing its own enforcement

activities and redirecting efforts where we can achieve a more direct community benefit.
-41-

VI. LEGAL AUTHORITY

The Clean Air Act Amendments of 1990 (42 U.S.C. section 7401 et seq.) require states

such as California to submit to U.S. EPA revisions to the SIP for ozone and PM10 for

certain areas. The primary tool to be used in the effort to attain national ambient air

quality standards is a plan to be developed by any state with one or more nonattainment

areas which provides for implementation, maintenance and enforcement of the

standards—the SIP (section 110(a)(1)). Section 110(a)(2)(A) broadly authorizes and

directs states to include in their SIPs: 

"...enforceable emission limitations and other control measures, means, or techniques

(including economic incentives such as fees, marketable permits, and auctions of

emissions rights), as well as schedules and timetables for compliance, as may be

necessary or appropriate to meet the applicable requirements of the Act."

Pursuant to these statutory provisions, ARB is charged with coordinating State,

regional, and local efforts to attain and maintain both State and national ambient air

quality standards. The direct statutory link between ARB and the mandates of the

Clean Air Act is found in section 39602 of the Health and Safety Code. This provision

states:

"The state board is designated the air pollution control agency for all purposes set forth in

federal law.

The state board is designated as the state agency responsible for the preparation of the

state implementation plan required by the Clean Air Act (42 U.S.C., Sec. 7401, et seq.)

and, to this end, shall coordinate the activities of all districts necessary to comply with

that act. 

Notwithstanding any other provision of this division, the state implementation plan shall

only include those provisions necessary to meet the requirements of the Clean Air Act."
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VII. STAFF RECOMMENDATIONS

As described in this report, ARB staff has reviewed the Proposed 2004 Valley Ozone

SIP and consulted extensively with District staff during this review. District staff

indicates it will make technical corrections to the plan at or prior to the October 8, 2004

local hearing. These changes include:

• Clarification of the District’s commitment to achieve the aggregate local emission

reductions from the defined new measures or from alternative measures in the same

timeframe.

• Clarification of the District’s intent to adopt the long-term measures.

• Clarification that the District will use the SIP update mechanism for changes to the

rule development schedule.

• An update to the rate-of-progress calculations demonstrating the required emission

reduction progress based on adopted measures.

• Corrections to the emission inventory and other minor revisions.

ARB staff finds that the Proposed 2004 Ozone SIP, with the technical corrections

characterized above, meets applicable requirements. We believe that implementation

of this plan would clearly reduce ozone levels throughout the San Joaquin Valley and

benefit public health. Therefore, we recommend that the Board take the following

actions: 

(1) Adopt the 2004 San Joaquin Valley Ozone SIP as a revision to the California

SIP, including the control strategy, emission inventories, progress demonstration,

attainment demonstration, and motor vehicle emission budgets.

(2) Direct the Executive Officer to submit the plan to U.S. EPA as a revision to the

California SIP.