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 simp le 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 IMPLEMENTATI ON PLAN FOR OZONE IN THE SAN JOAQUIN VALLEY

Air Resources Board Meeting Begins October 28, 2004 9:00 a.m. San Joaquin Valley Unified Ai r 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 s ubmit written comment s through regular mail, e-mail or fax. To be considered by t he Board, written comments not physically submitted at the meeting must be received no later than 12:00 noon, October 27, 2004and 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 notsignify that the contents nec essarily 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 Info rmation Office, 1001 I Street, 1 stFloor, 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 fo r TDD calls from outside the Sacramento area.

PRINCIPAL AUTHOR Ravi Ramalingam, P.E., Staff Liais on 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, Regi onal Air Quality Modeling Section Vernon Hughes, Manager, AtmosphericModeling and Support Section Bruce Jackson, Staff Air Pollution Specialist Cheryl Taylor, Air Resources Engineer Emissions Inventory Michael Benjamin, Ph.D., Manager, Em ission Inventory Systems Section Michael FitzGibbon, P.E., Manager, Em ission Inventory Analysis Section Douglas Thompson, Manager, Moto r 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., Ai r 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 Distric t staff for the high le vel of coordination between the agencies in developing the technica l elements of this plan. We would like to recognize Mr. Dave Jones, Mr. Dave Mitc hell, 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 manyhours to this interagency cooperation.TABLE OF CONTENTS
Page

EXECUTIVE SU MMARY...............................................................................................1

I. BACKGRO UND..................................................................................................5 A. Profile of the S an Joaquin Va lley ...............................................................5 B. Historical Ai r Quality ...................................................................................6 C. Central Califor nia Ozone Study ..................................................................8
II. AIR QUALITY PLANNI NG..................................................................................9 A. Ozone Planning Background......................................................................9 B. 2003 PM10 Plan.......................................................................................10 C. 8-Hour Ozone Planni ng Requirem ents.....................................................10 D. PM2.5 Pl anning Requir ements ................................................................11 E. California Clean Air Ac t Plans ..................................................................11

III. PLAN EVAL UATION ........................................................................................12 A. Emission In ventory ...................................................................................12 B. Emission Reduction Cr edits .....................................................................13 C. Air Quality Modelin g .................................................................................14 1. Oz one Epis ode.................................................................................14 2. Air Quality Model ..............................................................................14 3. Modeli ng Perform ance .....................................................................15 4. Attainment Em issions Ta rget............................................................16 5. Peer Review .....................................................................................17 D. Control St rategy........................................................................................17 1. Local Measur es ................................................................................19 2. Stat e Measur es ................................................................................26 3. Federal Meas ures.............................................................................31 4. Long-Te rm Meas ures .......................................................................31 5. Conti ngency Meas ures.....................................................................34 E. Attainment De monstrat ion ........................................................................34 F. Rate-of-Progress Demonstrat ion..............................................................35 G. Transportation Conformity B udgets..........................................................37

IV. FUTURE FEDERAL OZONE PL ANS ...............................................................38 A. 2007 1-Hour Ozone Plan Updat e .............................................................38 B. 8-Hour Ozone Pl ans.................................................................................38

V. ENVIRONMENTA L IMPAC TS..........................................................................39

VI. LEGAL AU THORITY ........................................................................................41

VII. STAFF RECO MMENDATION S........................................................................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 c onsider local adoption ata hearing scheduled for October 8, 2004. Contingent on prior adoption by the Distric t, the Air Resources Board (ARB or Board) will consider approval of the 2004 Ozone SIP at a public meeting on October 28, 2004. If t he Board adopts the plan, it will be submitted to the U.S. Environmental Protection Agen cy (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 commitm ents that provide the last increment of reductions to meetthe 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 populati on, 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 bythe 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 “bum p up”) from severe to extreme, requiring tighter emission controls and attainment by2010. Although U.S. EPA intends to revoke the 1-hour standard in 2005 (and replace it with the 8-hou r 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 qua lity 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, St ate, and federal regulations, together with local and State commitments for additional emi ssion reductions from new measures; a demonstration of attainment by 2010; a rate-of-progress demonstration through 2010; new motor vehicle emission bud gets 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 t he 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-priva te $18 million program of meteorological and air quality monitoring, emission inv entory development, data analysis, and air quality simulation modeling.
Control Strategy . The plan shows that the Va lley needs to reduce ozone-forming emissions of volatile organic compounds (VOC) and nitrogen oxides (NOx) by a combined 342 tons per day (tpd) betw een 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 next13 percent of the reducti ons are from new measures identified in the adopted 2003 Valley PM10 SIP. This plan introduces additional commitments to achieve the last 17 percent of t he 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 concent rated animal feeding operations by over 15 tpd. This plan takes full credit for t he 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 r eductions from new State m easures. To provide the additional reductions needed for ozone attainm ent, 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 St rategy 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 Local 1 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 nea rly 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 ru lemaking 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 incrementof reductions for the 1-hour standard, the 2004 Ozone SIP lays the groundwork for the 8-hour plan and a ttainment 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 commitmentto achieve the aggregate local emission reductions from the defined newmeasures or from alternative measures in the same timeframe.

• Clarification of the District’s intentto 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 calculat ions 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 J oaquin 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 descr ibes 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 Count ies. The San Joaquin Valley comprises nearly 25,000 square miles and covers approx imately 16 percent of the geographic area of California. It is a continuous vall ey 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, Modes to, 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 ex periencing the greatest number of violations of that standard are southeast and downwind of Fresno and Bakersfield. Ozone peaks generally occur during July through Oct ober, with daily maximum concentrations between noon and 6:00 p.m.
The long-term trend in San Joaquin Valley oz one 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 s hown in Figure I-2. As the figure shows, ozone air quality is improving in the Valley ov er the long-term. Despite fluctuations due to differences in weather each year, t he 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 st andard 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 reduc tion progress has been steady, the annual variation in ozone air quality is strongly influenced by di fferences 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. Prelim inary data indicates fewer than 10 federal 1-hour exceedances for the Valley to date in Summer 2004. 0 50 100 150 200 250

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2 Days Over Federal 1-Hour Ozone Standard Maximum 1-Hour Ozone Concentration (ppb)-7- The northern region of the Valley – San J oaquin, Stanislaus and Merced Counties–has the cleanest air. The Valley’s peak c oncentrations 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 l east twice as many days above the national 1-hour standard as any of the rema ining 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 st andard). 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 fe wer 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. 

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8-Hour (compared to standard of 84 ppb)-8- C. Central California Ozone Study
The San Joaquin Valley’s last attainmentdemonstration 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 J oaquin Valley Air Quality Study.
A decade later, air quality experts conduc ted 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 capab ility for all of California north of the Tehachapi Mountai ns. 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 m odeling 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 nonattain ment 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, m oderate, 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 nonatta inment with a serious classification, which carried an automatic attainment date of 1999.
The San Joaquin Valley did not attain t he 1-hour ozone standard in 1999. U.S. EPA found that the area failed to attain by t he 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, whic h 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 Distr ict 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 mo tor vehicle emission estimates projected by EMFAC2002. These plans satisfied a ll planning requirements for a severe nonattainment area, except for a demonstration of attainment by the 2005 deadline.
Preliminary analysis at that time indicated t hat 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 emissi on levels. Recognizing the inability to identify sufficient emission reductions from control measures to bring the Valley into attainment by 2005, the District Board vot ed on December 18, 2003 to request voluntary reclassification to extreme with an a ssociated 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 reclassifyi ng the Valley to extrem e effective May 17, 2004 and established the fo llowing requirements:
Due November 15, 2004

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

• Demonstrate reasonable progress* in reduc ing 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 st ationary 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 PM 10 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 exis ting 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 co mmitments 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 te chnical 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 show s a need for control strategy changes, the Plan revision will include t he appropriate measures.
C. 8-Hour Ozone Planning Requirements
On April 15, 2004, U.S. EPA finalized both des ignations 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 significantfurther 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 reducti ons 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. Ba sed 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 attainmentdemonstration plan is due to U.S. EPA in early 2008.
The Valley will need significantadditional NOx (a precursor to PM2.5) reductions for PM2.5 attainment. Therefore, the strat egies for 1-hour ozone, 8-hour ozone, and PM10 are complementary.

E. California Clean Air Act Plans
The California Clean Air Act (CCAA) require s districts that vi olate the State 1-hour ozone standard to demonstrate ev ery three years that theyare making steady progress towards attainment through a five percentannual reduction in ozone precursors, or implementation of all feasib le 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 thatsend “overwhelming” pollutant transport to other regions are also required to mitigate their transport contribution.

The District’s 2004 Ozone SIP includes elem ents to address both federal and State ozone planning requirements. This evaluati on covers only the federal element; we will assess the CCAA element in a separate, subs equent analysis of all districts’ triennial plans.-12- III. PLAN EVALUATION
This chapter reviews the contents of t he Proposed San Joaquin Valley 1-Hour Ozone SIP and provides ARB staff’s evaluat ion of each significant element.
A. Emission Inventory
California’s emission inventory is an estima te of the amounts and types of pollutants emitted from thousands of industrial and co mmercial facilities, millions of mobile sources, and hundreds of millions of applicati ons of other products such as paint and consumer products. The development and main tenance of the inventory is a multiagency effort involving ARB, 35 local air pollution control and air quality management districts (districts), metropolitan pl anning organizations (MPOs), councils of governments (COGs), and the California Department of Transpo rtation (Caltrans). ARB staff compiles the final, statewide emission in ventory and maintains this information in a complex electronic database. An inventory re flects the best information available about the emission rate and activity (including proj ected growth) for each category of sources.
The San Joaquin Valley 1-Hour Ozone SIP ut ilizes the latest estimates of VOC and NOx for stationary, area-wi de, and on-road and off-road mob ile sources. These are consistent with emission estimates re flected in the Valley’s 2003 PM10 SIP.
The emission analyses in the SIP focus on t he years 2000 (the starting point for the air quality modeling analysis) and 2010 (the attain ment 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 emission s 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 emissi ons from on-road motor vehicles, and a 32 percent decline in emissions from of f-road vehicles and equipment. Table III-1 shows the breakdown of VOC and NOx emi ssions 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 Valle y Air Basin, unless otherwise noted.

We note that the ozone seas on 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 thatwork was not complete at the time the planning inventory was developed, this invent ory does not include es timates of the NOx emissions from prescribed burning. Until the seasonal NOx estimates from prescribed burning are finalized and reflected in a s ubsequent SIP, evaluat ion of prescribed burning emissions against the SIP planning inventory should focus on VOC, carbon monoxide, and PM10. This approach does notimpact the attainment demonstration because the day-specific emissi on 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 Measu res 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 57.0 2 -51% 223.8 134.2 2 -40% 339.1 191.2 -44%

Off-Road Vehicles and Equipment 69.2 42.4 3 -39% 171.5 120.1 3 -30% 240.7 162.5 3 -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 fo r 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 t he 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 invent ory baseyear must be explicitly treated as emissions in the air. In other words, t he plan must account for ERC use. The District does this by including projected ERC use in the emissi on 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 Stationa ry 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 meas urements of meteorology and air quality, to establish this relationship. The performanc e of the model is determined by comparing the modeled or predicted ozone value to t he 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 repr esentative of days thatexceed the standard and appropriate scientific tools (like the air qua lity model, the meteorological model, and the atmospheric chemistry mechanism for oz one formation) that can best predict ozone levels. ARB and District staff made thes e decisions together, aided by input from agency, industry, and scientific peer reviewers.
The tools and data used in the modeling ana lysis for the 2004 Ozone SIP represent the state-of–the-science and a significant step forw ard in our collective ability to understand the level of emission controls needed to meet the ozone standards. The modeling results meet the performanc e criteria established byboth U.S. EPA and ARB.
1. Ozone Episode
During Summer 2000, intensive measurement s 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 Va lley, 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 Riv erside, together with District staff, conducted extensive m odel performance evaluations with two meteorological models, two air quality models, and two chemical mechanisms within the air quality models. Each of the air qua lity 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 simu lated using the CAMx air quality model, alternatively with Carbon Bond IV and S APRC99f chemical mechanisms. The meteorological models MM5 and the CALMET/MM5 hybrid were also used to provide inputs to CAMx. Overall model performanc e of CAMx using the CALMET/MM5 hybrid and SAPRC99f was superior to t hat resulting from MM5 alone.

The attainment demonstration in this SIP uses the CAMx model, with the CALMET/MM5 hybrid meteorological model, and t he SAPRC99f chemical mechanism.
3. Modeling Performance
Four of the Valley’s ozone monitors recorded 1-hour exceedances during the July/August 2000 episode. Recorded val ues 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 t he 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 (t he 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 val ues, and provided the most conservative estimates of further reductions needed for attain ment. Table III-4 shows the relationship between monitored and modeled values at the two Valley sites with the highest measured ozone on July 30, t he modeled 2010 ozone level us ing 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 le vel 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 em issions, NOx emissions, and VOC plus NOx emissions. The resulting chart shows how each of these incremental changes in VOC and/or NOx emissions is pred icted 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 oz one 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 Distric t is a scientifically valid and effective approach.
The control strategy identifies the measur es 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 Target (tpd) Episode 3-Year Design Value 1

(ppb) Peak Concentration

Observed in Episode

(ppb) Peak Concentration Simulated by Model in 2000 2 (ppb) Peak Concentration Simulated by

Model from 2010 Baseline

Emissions 2 (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, tec hnical tools, and results occurred on several levels. There were inventory work groups with representatives from multiple air agencies, transportation agencies, and cons ultants. The experts on the CCOS Technical Committee reviewed and provided feedback on all aspects of the modeling. Overall, the Technical Committee concurr ed that the technical approach for the air quality modeling used by ARB and District st aff was reasonable. The modeling analysis was circulated in both draft and propos ed form for public review and comment.
D. Control Strategy
The Proposed 2004 Ozone SIP includes a contro l strategy to attain the federal 1-hour ozone standard based on reductions from existi ng regulations as well as additional reductions from enforceable commitments to adopt new control measures and clean engine incentive programs. The Distric t 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 Automoti ve Repair for vehicle inspection and maintenance (Smog Check); the California Department of Pesticide Regulation for pesticides; and U.S. EPA for national transpor tation 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, St ate, and federal measures contributing to attainment. The combined control stra tegy provides enforceable measures or commitments that meet the app licable requirements for approval. The District, local transportation agencies, and ARB have previ ously demonstrated in the materials-18- supporting the 2002/2005 Ozone Rate-of-Progre ss Plan and the 2003 PM10 SIP that all reasonably available control measures are being implem ented or are committed for implementation. The commitment s 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 2002 1 Local State Federal Total +8.5 2 -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 e ffect of growth (primarilyin 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 th e 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 contro l account for 36 perc ent of the Valley’s inventory of ozone-forming emissions (VOC pl us 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 cont rol 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 ai r quality, but the strategies do not have quantified emission reductions a ssociated with them. In the SIP, the District and transportation planning agencies did not specifically id entify 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 rule s for a wide range of the stationary and areawide sources under its jurisdiction. This plan includes the benef its of local, State, and federal controls adopted through Sept ember 2002 as part of the 2010 baseline emission inventory. Rules adopted after t hat 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 meas ure allows the plan to be consistent with the 2003 Valley PM10 SIP and ARB’s 2003 St atewide 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 ne xt several years will ensure net reductions in both pollutants in the future.-20- b. New Defined District Measures
The category of new defined District m easures includes those adopted subsequent to the September 2002, remaining 2003 PM10 SIP commitments, and new Ozone SIP commitments the District is propos ing 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 Reductions 1 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 Programs 2 - - -- 5.0
Totals 2.4 12.2 1 Emission reductions creditable against PM 10 SIP commitments are different for some

measures because of the shift from annual av erage 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 t hat reduce VOC or NOx emissions. The District also proposes to add commitment s 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 defin ed measures between 2004 and 2007, and with implementati on 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 require s the District Board to adopt alternative measures sufficient to achieve equivalentaggregate 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 Adoption Date FullImplementation Date Baseline Emissions Reductions Baseline Emissions 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 t he production of crude oil, natural gas, and natural gas liquids. These sources house pipes, valves, flanges, hatches, pumps, compressors, and many other components with t he potential to leak fluids or gases, releasing fugitive VOC emissions. Contro ls could include lowering the permissible gaseous leak threshold of 10,000 ppmv, e liminating some existing exemptions, increasing the frequency of inspection, s hortening the repair period for leaking components, and replacing fr equently 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 com ponents 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 elem entary 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 t hat 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 vehi cle 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 phas e 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 t he 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 buildin gs, schools, prisons and military facilities. Combustion modifications appropriate for t hese units include low excess air, low NOx burners, water/steam injection, and flue gas re circulation. Post-combustion treatment of the exhaust stream may include selective cata lytic 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 dete rmined that the emissions exceed the de minimus threshold and are subject to Reas onably Available Contro l 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 in cineration, condensation, and additional temperature control. The District has refined the inventory for this category over the last year. The measure anticipates the same c ontrol efficiency as in the PM10 Plan, with the lower baseline inventory transla ting 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, munici pal 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 se t 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 est ablishes 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, comm itted to in the Valley’s PM10 Plan that will affect dryers used to remove wa ter from process materi al by heating. The District determined that these dryers exc eed the de minimus threshold and are subject to Best Available Control Measures (BAC M) requirements for PM10. These units are currently subject to District permitting requi rements, but there is no specific rule. Emission controls appropriate for dryers include Public Utilities Commission-quality natural gas, low excess air, low NO x burners, and flue gas recirculation.
J. Composting/Biosolid Operations. This new measure would reduce VOC emissions from the composting of biosolid s, including sewage sludge, agricultural waste, and other green waste (s uch as from residential landscaping). Controls could include vapor collection and c ontrol systems, forced aeration, and windrow of materials.

K. Automotive Coating. This new measure would reduce VOC emissions from any new or existing operations thatapply coatings to automobile parts or accessories. This measure would be amended to align with Ca lifornia Air Pollution Control Officers’ Association (CAPCOA) recommendations.
L. Concentrated Animal Feeding Operations. The District is proposing to reduce VOC emissions from dairies, cattle feedlot s, poultry ranches, and other agricultural operations involving animal husbandry. VOC emissions may be reduced by controlling emissions from feedlots and from supporti ng operations such as waste treatment lagoons. The measure is intended to comp ly 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 VO C 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 current ly not regulated by the District. NOx prohibitory rules may be coupled with a financ ial 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 replac ement 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 syst ems. 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 activiti es 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 Sectio n 41855.5(a), which phases out open burning between 2005 and 2010, and exemptions allow ed 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-effectiv e 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 c ontrol 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 po wer generation. Turbines rated greater than 10 MW are subject to Distric t requirements similar to t he 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, includi ng filling aviation fuel bulk storage tanks using primary fuel delivery tr ucks, 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 t anks. 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 Distr ict must adopt RACT control measures applicable to sources with emissions great er than 10 tons per year of an ozone precursor, rather t han the current 25 tons per year cutoff applicable to severe areas. The District must also upgrade its rules for t he 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. Similarl y, 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 classificati on. With respect to Jet Engi nes and Test Cells, the District was unable to identify viable control measures . The District is listing this as a further study measure and will investigat e potential controls. Meanw hile, 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 Stat e regulatory jurisdiction (e.g., vehicles, fuels, some offroad equipment, and consumer products) are a si gnificant contributor to the Valley’s pollution problems. These sources under Stat e control account for 46 percent of the Valley’s inventory of ozone-forming emissi ons (VOC plus NOx) in 2000, becoming a smaller share (37 percent) of the total by2010 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 attain ment 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 Progr am and California Reformulated Gasoline, together with a series of progressively ti ghter emission standards for new engines used in big diesel trucks and heavy equipment, forklifts and pumps, lawn and garden equipment, pleasurecraft, and over 100 cat egories of consumer products. To complement these regulatory programs, the State has cont ributed over $60 million since 1998 to fund a variety of District clean engine inc entive programs throughoutthe Valley.

The Bureau of Automotive Repair’s (BAR ) Smog Check program is also providing essential reductions in the Valley. The Distr ict 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 fleetsubject 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 commitm ents to develop new State measures that will generate further emission reductions in the Valley. State commitments for 10 tons of NOx reductions from t hese measures were already submitted to and approved by U.S. EPA as part of the Valley’s 2003 PM10 SI P. ARB will add 15 tpd VOC and another 10 tpd NOx to generate a total combined Stat e commitment of 35 tpd VOC plus NOx for this Ozone SIP.
To help achieve the federal health-bas ed 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 vehicl es will further increase the air quality benefits of the program.

• Continuation of the Department of Pestic ide Regulation’s approved SIP obligation 1 to reduce volatile emissions from pesticides. For the San Joaquin Valley, this means a pesticide VOC emissions targetof 12 percent less than 1990 levels.
The Statewide Strategy also describes a process to identify longer-term solutions to achieve additional reductions from source s under State, federal , and local control.

The defined control measures in the Statewi de Strategy cover on-road vehicles, off-road equipment, ports and harborcraft, fuels and refueling, and c onsumer products. Lower emission standards for new engines and c onsumer 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 Stra tegy, 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 reli ed on an extensive public process. Using feedback from workshops in 2001, st aff compiled a list of potential control measures for sources under Stat e, federal, and local control. In 2003, staff participated in eleven public workshops with the loca l air districts in the South Coast and San Joaquin Valley, as well as an ARB techni cal workshop in both those regions plus Sacramento, to discuss the draft Statewide Strategy. ARB staff considered the public concerns and suggestions voiced at thes e 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 publichearing 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 reducti ons beyond the 2010 baseline.

1 40 CFR Part 52, Federal Register, January 8, 1997, pages 1150-1187.-28- • The low sulfur diesel fuel regulati on adopted in July 2003 fulfills SIP measure FUEL-2.

• The small off-road engine emission standar ds adopted in September 2003 fulfill SIP
measures SMALL OFF-RD-1 and SMALL OFF-RD-2.

• The particulate matter control measure fo r 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 adopt ed in June 2004 fulfill SIP measure CONS-1

. • The restriction on idling time for commerc ial 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 st ations 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 ex isting 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 rece ive 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 in centive 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 St ate 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 authoriz ation for local air districts to raise the motor vehicle registration fee that consum ers pay to support air quality programs by $2 per vehicle per year.-29- 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 mi nimum, 15 tpd VOC and 20 tpd NOx emission reductions in the S an Joaquin Valley Air Basin by the 2010 ozone season as part of the attainment dem onstration 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 emi ssion 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 Sy stems 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 Inspecti ons 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 Existi ng 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-Ro ad 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 Handh eld 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 No n-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 Po rt Emissions – Alternative Fuels, Cleaner Engines, Retrofit Controls, Electrificati on, 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 pr actical control of the federal government include heavy-duty diesel trucks register ed outside California, some new farm and construction equipment, locomotives, and airc raft. These federal sources account for 18 percent of the Valley’s inventory of ozone-forming emissions (VOC plus NOx) in 2000. Nationwide regulations promulgat ed by U.S. EPA achieve over 50 tpd of emission reductions in the Valley betw een 2000 and 2010, contributing 15 percent of the total reductions needed for attainment in th is 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 reducti ons 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 engi nes. 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 beginni ng 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 t he Valley transitions to the 8-hour ozone standard.
In the 2010 timeframe, we need the federal government to fo cus on funding an incentive program to clean up diesel engines that para llels 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 achiev e 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 benefit s of both adopted and new defined State and local measures, the 2004 Ozone SIP demons trates 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 l ong-term measures to achieve the last 10 tpd VOC plus NOx reductions. In 2007, t he District will reevaluat e the 1-hour ozone attainment control strategy using availabl e 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 alreadybegun the process of identifying additional strategies via the described “further st udy measures” and “fut ure study measures.”
a. Further Study Measures
Further study measures ar e potential measures from emission categories without adequately developed emission inve ntories 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, yiel ding emission reductions in the pre-2010 timeframe. Others may be disca rded after District evaluation.
The further study measures addre ss the following source categories:

• Portable equipment r egistration 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 furt her study measures, as described below. Staff has relied on recent rule stringency a ssessments by the California Air Pollution Control Officers Association (CAPCOA) and four districts in central California. The four Districts -- the Bay Area Air Quality M anagement District, Sacramento Metropolitan Air Quality Management District, S an Joaquin Valley District, and Yolo-Solano Air Quality Management District – have worked together with ARB to compare the technical requirements of their rules agai nst each other and the best in t he State. The goal of this exercise is to identify source categor ies with potential addi tional 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 evaluati ng 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 evaluati ng the further study measures.-33- Portable Engines. In February 2004, ARB adopted an ai rborne 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 to xics measure is compatible with a further study measure for the District. The State measure affects all diesel-fuel ed 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 ex pedited engine replacement.
b. Future Study Measures
Stakeholders at District workshops on the 2004 Ozone SIP have suggested control measure concepts for mobile sources. T he 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-tru ck traffic route along Highway 99;

• Restrictions on truck idling; and

• Revising the vehicle registration fee stru cture to charge according to emissions rather than value of the vehicle.
In addition, the District also lists as futurestudy measures programs for emissions from non-mobile sources, such as vegetation used for landscaping.
The State is already working on two of t hese 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 v ehicle weight rating greater than 10,000 pounds to no more than five minutes at anylocation. The Board will consider a companion measure next year thataddresses idling in sleeper cabs.-34- 5. Contingency Measures
Contingency measures are intended to provi de additional reductions in case the control measures identified for attainment and progr ess do not deliver the expected reductions. Contingency measures are t herefore required both for the 2008 progress milestone, the 2010 progress milestone, and the 2010 attainment demonstration.
To meet rate of progress requirement s 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 th is plan are provided by the District’s commitments for new measures and the growi ng emission reductions from turnover of the vehicle fleet to cleaner m odels under ARB’s regulations.
The District is subject to a requirement for contingency measures unique to extreme areas. Three years before the proposed im plementation date, t he 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 Ai r 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 ti me. The timing of this requirement dovetails with submittal of the 8-hour ozone SIP in J une 2007, and the expected transition to the federal 8-hour standard.

E. Attainment Demonstration
Table III-10 summaries the Valley’s attain ment demonstration for the federal 1-hour ozone standard. The 2010 attainment emi ssion 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 cont rols, 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 314.4 343.5-35- F. Rate-of-Progress Demonstration
In addition to developing an attainment dem onstration 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 ra te-of-progress (ROP). As a severe area, the District adopted and submitted an RO P 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 Septem ber 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 goal s. Areas must reduce their emissions of VOC by three percent per year, averaged over a three-year period Specifically, the Valley must demonstrate t hat its VOC emissions in 2008 are 51 percent below the levels in 1990, the baseline year for ROP pl ans. 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 equiva lent basis, to the extent that NOx reductions are necessary for attainment.
U.S. EPA has expressed a policy preference fo r 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 t he 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 adopt ed measures. Table III-11 summarize the key steps in the revised ROP demonstration.

2 U .S. EPA, memorandum, Guidance on Issue Related to15 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 inventory1 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 inventory1 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 m ilestone, 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 devel oped 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 adequat e, 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 Governmentusing 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 lo cal commitments to reduce on-road vehicle and road construction emissions are subtracted from the adjusted baseline to arrive at the conformity budgets. These budgets w ould become applicable when U.S. EPA finds the budgets adequate. Conformity assessment s 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 Total 2 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 pl an 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.-38- IV. FUTURE FEDERAL OZONE PLANS
The District must develop a new ozone plan in less than three y ears 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. T he 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 Distric t 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 Ca lifornia have kicked off the process of developing 8-hour plans. The Valley must s ubmit two types of 8-hour plans: an 8-hour rate of progress plan and an 8-hour attain ment demonstration plan that is due June 2007. As a serious 8-hour ozone nonattainmentarea, the Valley’s 8-hour attainment date is 2013.

Staff from ARB and the 8-hour ozone nonattainm ent districts in central California have already met several times to discuss devel opment 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 significa nt 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 Dis trict identified three areas with potential for significant impacts (air quality, utilitie s/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 Oz one SIP and found that the SIP approach was environmentally superior.
We reviewed the Draft EIR pr epared by the District, and find t hat it accurately describes the potential environmental impa cts 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 s ubject 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 framew ork for incorporating environmental justice into ARB’s programs consistent with the dire ctives of State law. The policies and actions are based on State law, which descri bes "environmental justice" as "the fair treatment of people of all races, cultures , and incomes with respect to the development, adoption, implementatio n, and enforcement of environm ental laws, regulations, and policies." ARB’s environmental justice polic ies help ensure that we take into account neighborhood impacts as we prioritize and develop controls and pollution-prevention strategies.
The environmental justice policies touch virt ually every ARB program, including motor vehicles, air-quality planning, toxics, resear ch, enforcement, and ai r monitoring. They apply to all communities in California but re cognize 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 concent ration of air pollution sources in these communities.
The 2003 Statewide Strategy included in t he 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 Califor nia, 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 em issions from trash trucks, stationary and portable engines, transportation re frigeration units, and truck idling. Board staff have begun conducting more truck inspections in co mmunities with high truck traffic as well.
ARB staff is committed to working with di stricts, local governments, and affected communities to improve statewide compli ance for all air pollution sources, whether under ARB or district jurisdiction. AR B 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 c an achieve a more direct community benefit.-41- VI. LEGAL AUTHORITY
The Clean Air Act Amendments of 1990 (42 U.S. C. section 7401 et se q.) 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 byany state with one or more nonattainment areas which provides for implementati on, maintenance and enforcement of the standards—the SIP (section 110(a)(1)). Se ction 110(a)(2)(A) broadly authorizes and directs states to include in their SIPs:

"...enforceable emission limitations and othe r 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 ma intain 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 a gency responsible for the preparation of the state implementation plan required by the Cle an 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."-42- 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 commitmentto achieve the aggregate local emission reductions from the defined newmeasures or from alternative measures in the same timeframe.

• Clarification of the District’s intentto 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 calculat ions 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 Oz one SIP, with the technical corrections characterized above, meets applicable require ments. We believe that implementation of this plan would clearly reduce ozone le vels throughout the San Joaquin Valley and benefit public health. Therefore, we reco mmend that the Board take the following actions:
(1) Adopt the 2004 San Joaquin Valley Ozone SI P as a revision to the California SIP, including the control strategy, em ission inventories, progress demonstration, attainment demonstration, and motor vehicle emission budgets.
(2) Direct the Executive Officer to submit t he plan to U.S. EPA as a revision to the California SIP.