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Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

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### B - 1 

# APPENDIX B

Emissions Reduction Analysis for Proposed Rule 9510 (Indirect Source Review) and Rule 3180 (Administrative Fees for Indirect Source Review)

December 15, 2005

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 2 EMISSION REDUCTION ANALYSIS FOR

RULE 9510 (Indirect Source Review)

I. INTRODUCTION

Both the 2003 PM10 Plan and the Extreme Ozone Attainment Demonstration Plan, contain emissions reduction commitments for proposed Rule 9510 of 4.1 tons per day of NOx and 5.2 tons per day of PM10 to be achieved by 2010. Those estimates were based on assumptions at the time and are commitments that are necessary to assist the district in meeting the federal and state PM10 and ozone standards. This appendix contains emissions and emissions reduction estimates that update those original estimates.

II. BASELINE EMISSIONS

A. Sources of Emissions from New Development

It is generally accepted in both air quality and transportation planning, as well as in case law that new emissions occur from new development. The construction of new structures is undertaken in order to accommodate the growth in population of a particular area. With the projected growth and development in the San Joaquin Valley Air Basin (SJVAB), there will also be a corresponding growth in emissions from energy usage, landscape maintenance equipment, wood combustion, motor vehicles, and entrained dust from paved and unpaved roads.

Energy Usage Emissions associated with energy usage from new development primarily occur from two different sources, electricity generation and fuel combustion. NOx and PM10 emissions result from using space heating, water heating, cooking, and from other miscellaneous electrical appliances/equipment. ARB estimates fuel combustion emissions from natural gas, distillate oil or LPG, using EPA emission factors, and gas sales. 1 

### Emissions attributed to use of electricity generated at power plants are not easily quantified due to the variety of sources that supply electricity, which are located in and out of the basin and the state. Therefore, electrical generation emissions associated with new development will not be quantified or addressed for this program.

1 Air Resources Board, Emissions Inventory Procedural Manual, Vol. III, Methods for Assessing Area Source Emissions, October 1997 with revisions through November 1998, section 7.2-7.3.

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### B - 3 Landscape maintenance equipment Landscape maintenance equipment generates NOx and PM10 emissions from fuel combustion (gasoline, diesel, or LPG or CNG) and from evaporation of unused fuel. Equipment in this category can include leaf blowers, lawn mowers, trimmers, edgers, chainsaws, chippers, etc. ARB uses the OFF-ROAD model to estimate PM10 and NOx emissions using population, activity duration, and emission factors. 2 

### URBEMIS uses OFF-ROAD results and quantifies emissions by the number of homes and business units. 3 

### Based on District analysis, the growth in NOx and PM10 emissions from residential landscape maintenance equipment is relatively small, 15 tons per year, despite a projected increase of nearly 1.8 million pieces of residential landscape equipment in the SJVAB. The primary reason for the small emissions increase is that the new equipment is significantly cleaner than the older equipment.

Wood Combustion Residential wood combustion emissions of PM10 and NOx come from burning wood or similar materials inside fireplaces, wood stoves and inserts. ARB estimates emissions totals using the following factors: tons of wood used per house, BTU rating per cord, number of houses, fraction of active wood combustion devices, average number of days burned per house, and other representative factors. 4 

### The recent amendment to Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters) will reduce a significant portion of emissions from those devices. Rule 4901 contains limits on wood combustion devices in new development, however, it still allows new devices in a development of a certain size or larger. Therefore, reductions from this category can still occur if the development can still install those devices and chooses not to.

Motor Vehicle Emissions Motor vehicle emissions is the largest category of emissions attributed to new development. The inventory includes estimates of exhaust and evaporative VOCs, NOx, and PM10 associated with exhaust, tire wear and brake wear. On-road motor vehicles account for approximately 43% of the entire NOx inventory for 2002. 5 

### ARB estimates emissions from on-road vehicles using the EMFAC2002 model, which uses emission factors, vehicle numbers and vehicle activity. Emission rates are derived primarily from direct testing by the state or EPA. Vehicle population and vehicle age data are obtained from the Department of Motor Vehicles (DMV). Travel activity, which includes vehicle miles traveled (VMT), distribution of VMT by speed, the number of trips taken per vehicle each day, are provided by the California Department of Transportation

2 Staff report for Public Meeting to Consider Approval of the California Small Off-road engine emissions inventory, http://www.arb.ca.gov/msei/off-road/pubs/sore_final.doc

3 URBEMIS2002 Users’ Guide, Version 7.4, May 2003, Appendix B.

4 Air Resources Board, Emissions Inventory Procedural Manual, Vol. III, Methods for Assessing Area Source Emissions, October 1997 with revisions through November 1998, section 7.1.

5 2003 PM10 Plan, Chapter 3, NOx Emissions Inventory

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### B - 4 (Caltrans), local Metropolitan Planning Organizations (MPOs), local Councils of Governments (COGs), and fleet monitoring. 6 

### URBEMIS quantifies vehicle emissions attributed to a particular development based on the emission factors and vehicle activity found in EMFAC2002, in combination with project specific data. While the motor vehicle emissions inventory in both the PM10 and ozone plans show that vehicle emissions are declining, emissions would have declined even more if growth were not to occur, thus hampering the ability of the region to reach attainment of the PM10 and ozone standards. The following chart shows the emissions from all motor vehicles for the current population if it would have remained constant (No-Growth), and the emissions from vehicles for the projected population as reported in the 2003 PM10 Plan emissions inventory (Growth). Based on an analysis performed by ARB using EMFAC2002, which can be found in Attachment 1, the difference is an estimated 17.3 tons per day of NOx attributed to projected increase in growth in the SJVAB between 2006 and 2010.

Figure 1 Difference in NOx Emissions for All Vehicle Types

0 50 100 150 200

2006 2010 2015

Yeartons 

### Growth

No Growth



### Re-entrained Road Dust PM10 emissions from road dust occur by vehicles driving on unpaved roads, or by vehicles entraining or re-entraining dust on paved roads. ARB estimates PM10 emissions by using the following factors for different road types: silt loading on roads, vehicle weight, and VMT traveled. The majority of new development occurs on or creates new paved roads, however, some development in rural areas still use unpaved roads. Unpaved road emissions are estimated by using an emission factor and total VMT traveled. 7

6 Overview of the On-Road Emissions Inventory, http://www.arb.ca.gov/msei/on-road/briefs/emfac6.pdf

7 Air Resources Board, Emissions Inventory Procedural Manual, Vol. III, Methods for Assessing Area Source Emissions, October 1997 with revisions through November 1998, section 7.9-7.10.

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### B - 5 Construction This category of emissions differ slightly from the others, since all emissions from construction are due to new development, regardless of growth in the category. Emissions associated with construction activities occur for the purpose of building residential, commercial, industrial, institutional, or governmental structures. Emissions result predominantly from equipment associated with site preparation work, which may include scraping, grading, loading, digging, compacting, and other operations. ARB estimates construction emissions by utilizing a computer model called OFF-ROAD. The construction emissions in the OFF-ROAD model are estimated using the population, activity, and fuel usage of the varied types of construction equipment.

The following figure demonstrates PM10 emissions and emissions growth from construction equipment, re-entrained paved road dust, and vehicle exhaust associated with new development.

Figure 2 PM10 Emissions from Development

0 2 4 6 8 10 12 14 16

2006 2010 2015

YearEmissions (tpd) Re-entrained Paved Road Dust Growth

Motor Vehicle Exhaust Growth

Construction Exhaust



### B. Projected Emissions from New Development

The following table illustrates the projected growth in emissions, as can be discerned from the emissions inventory:

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Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 6 Total Emissions Attributed to Land Use Growth in the SJVAB in 2010 NOx Emissions Category Emissions from Growth In 2010 (tpd) Emissions from Growth during 2006-2010 (tpd) On-road Vehicles A 

### 2.2 17.3 Construction Equipment C 

### 21.3 21.3 Total NOx 23.5 137.8

PM10 Construction Equipment C 

### 1.4 1.4 On-road Vehicles A 

### 0.2 0.6 Paved Road Dust B 

### 1.1 5.2 Total PM10 2.7 13.4

A . Emissions Growth between 2006 and 2010 was estimated based on an ARB EMFAC 2002 version 2.2 run, dated June 10, 2005 (Attachment 1). This will be revised to obtain a total for 2006. B. 2003 PM10 Plan emissions inventory C. ARB Emission Inventory for 2010



### It should be noted that some sources of emissions from new development are not included in the above table for several reasons. While there may be difficulties in assessing what portions of the emissions inventory are resulting from new growth, there are new emissions from growth occurring. Therefore, the above table represents a conservative estimate of what will occur, and does not overestimate. Therefore, any reductions applied to the emissions outlined in the above table will represent a conservative estimate of actual reductions resulting from this program.

III. EMISSIONS REDUCTION OPTIONS FOR NEW DEVELOPMENT

A. On-site Project-Specific Emissions Reductions

On-site mitigation measures and their corresponding emission reduction methodologies were developed by Nelson/Nygaard and put into URBEMIS. The following discussion lists measures/conditions, if implemented that would result in emissions reductions from a development project. The maximum percent reduction is in general terms. The actual reduction relies on project specific information and factors, and how the mitigation measure is used in combination with other measures.

Increase Energy Efficiency Beyond Title 24 This measure would reduce emissions by decreasing the amount of natural gas that is needed and in turn combusted for a particular development. Examples of how this could be achieved include: using insulation in the attic and walls, insulating ductwork, using whole house fans, double-paned and/or high performance glazed windows, maximizing the use of natural lighting, installing EnergyStar appliances, orienting the

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Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 7 building north or south to utilize passive heating and cooling, designing the building to maximize natural ventilation, or any number of other items that would decrease the use of natural gas, and therefore decrease emissions. The emissions reductions associated with this mitigation measure in URBEMIS would require a quantification of the % reduction beyond what is already required by Title 24 as determined by a computer model developed for Title 24 purposes.

Electrical landscape maintenance equipment This measure would reduce emissions by eliminating some or all of the combustion of gasoline or diesel in standard landscape equipment by replacing it with equipment that relies on batteries, an electrical outlet, or manually-powered equipment. Emissionsreductions are quantified by using the % of the development that would use noncombustion powered equipment.

Hearth This measure would reduce emissions by eliminating construction of a wood combustion device that would have otherwise been allowed under Rule 4901.

Net Residential Density Emissions reductions from this measure would occur when an individual from a particular residential use forgoes the use of the automobile and uses an alternate form of transportation. A considerable volume of research has investigated the links between density and travel behavior and has determined that there is a significant and quantifiable relationship between residential density and automobile use. Three key studies of travel behavior and density itself have identified elasticities, which has been used to develop a formula to determine the reduction in vehicle trips and vehicle miles traveled, and the corresponding emissions reductions. The maximum reduction in trips/VMT and resulting emissions that may occur from this measure is calculated to be 55%.

Mix of Uses Emissions reductions from this measure would occur when an individual forgoes the use of the automobile and uses other forms of transportation. Research has shown that there is an impact of diversity or mix of uses on travel behavior, which can occur at the macro-scale, such as jobs-housing balance. Numerous studies of travel behavior and mix of uses have identified elasticities, which has been used to develop a formula to determine the reduction in vehicle trips and vehicle miles traveled, and the corresponding emissions reductions. The maximum reduction in trips/VMT and resulting emissions that may occur from this measure is calculated to be 9%.

Local Serving Retail Emissions reductions from this measure occur when an individual forgoes the use of the automobile, since the proximity of the retail encourages other forms of transportation. The maximum reduction in trips/VMT and resulting emissions that may occur from this measure is calculated to be 2%.

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### B - 8 Transit Service Emissions reductions from this measure would occur when an individual forgoes the use of the automobile and uses transit. Transit choices could include buses, light rail, dedicated shuttles, and trolleys. Since emissions from transit services already exist, the elimination of trip(s) from the automobile would result in emissions reductions. URBEMIS determines emissions reductions from transit use based on a Transit Service Index, which is based on the latest California-specific research on transit use. The maximum reduction in trips/VMT and resulting emissions that may occur from this measure is calculated to be 15%.

Bicycle and Pedestrian Facilities Emissions reductions from this measure would when an individual forgoes the use of the automobile and uses a bicycle or walks. Since the use of a bicycle or the action of walking does not emit emissions, the elimination of trip(s) from the automobile would result in emissions reductions. URBEMIS determines emissions reductions from bicycle use and pedestrian activities based on quantitative values of network density, sidewalk completeness and bike lane completeness. The maximum reduction in trips/VMT and resulting emissions that may occur from this measure is calculated to be 9%.

Affordable Housing/Senior Housing/ Assisted LivingThis measure would reduce emissions by designating residential units as deedrestricted below-market-rate (BMR) housing. Research has shown that lower-income households and senior citizens own fewer vehicles and drive less. By designating residential units as deed-restricted BMR, only lower-income individuals that use the automobile less would occupy those units, which would result in lower emissions due to less automobile use. The maximum reduction in trips/VMT and resulting emissions and resulting emissions that may occur from this measure is calculated to be 4%.

Transportation Demand Management Programs TDM Programs can include free transit passes, parking restrictions and telecommuting. Emissions reductions from this measure would occur when a landlord provides an incentive, such as transit passes, to individual(s), who then forgoes the use of the automobile and uses transit. These programs provide an incentive for the individual(s) to use the transit, and studies have show that these programs both increase transit ridership and reduce vehicle trips. The maximum reduction in trips/VMT and resulting emissions and resulting emissions that can be achieved under this measure is 25%.

Fleet Modifications Reductions from this measure occur when a fleet owner makes vehicle specific modifications or agrees to purchase and/or use only vehicles with controls, such as a particulate filters or catalysts. There are numerous options available. The maximum reduction in emissions that can be achieved under this measure varies by control option.

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### B - 9 It is important to note that many of the mitigation listed above requires a change in travel behavior of an individual in order for the emissions reductions to occur. It is not guaranteed that the mitigation measures will be successful at changing travel behavior to the exact amount as calculated, however, it represents the best estimate/projection of what will occur based on the most recent research conducted on existing travel behavior to date.

B. Off-site Emissions Reductions

In the event that the emissions impact of a particular project is not fully mitigated on site a proportional fee will be assessed and collected for the NOx and PM10 emissions not mitigated. The fees collected would be placed into a mitigation fund for each pollutant and county, and expended on projects that reduce emissions of that pollutant in that county, utilizing a grant-like program. The district has over eleven years experience with grant programs designed to reduce primarily NOx, and some VOC. Each grant program has had strict guidelines on emissions reductions, qualifying equipment, and the related administration of the program. Based on that experience, the District has decided that a grant program would provide the most cost-effective emissions reductions for the money that will be collected.

The District has employed the California Air Resources Board (ARB) and the California Department of Transportation document “ Methods to Find the Cost Effectiveness of Funding Air Quality Projects” for finding the cost effectiveness and emission reduction benefits for a wide variety of emission reduction projects. This document can also be accessed through an associated on-line database. The methods described are generally accepted and include: a list of information needed to calculate costeffectiveness, emission factors, project life, defaults that may be used when projectspecific data is not available (assumptions) and formulas to calculate vehicle emission reductions for three major pollutants, NOx, PM10, and VOC’s. Many of those methods were used to develop the grant programs that could be funded under this program.

The most successful District grant program has been the Heavy-Duty Engine Incentive Program. This program replaces older model high polluting engines with newer and cleaner burning engines. Eligible project types funded under the heavy-duty program include, but are not limited to: on-road and off road vehicles and equipment, agricultural pump engines, marine vessels, forklifts, truck stop electrification technology, and school bus projects.

The Voluntary Accelerated Vehicle Retirement (Scrap) Program is designed to accelerate the voluntary retirement of older, higher polluting passenger vehicles. Monetary incentives are provided to individuals who agree to scrap their high polluting passenger vehicles. Ideally, this incentive money will help them purchase newer vehicles with cleaner burning engines.

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### B - 10 The Light and Medium Duty Vehicle Incentive Program is designed to encourage the purchase and use of cleaner engine technology for passenger vehicles. To be eligible under the program, the light and medium duty vehicles must be powered by natural gas, electricity, fuel cells, or gasoline-electric hybrid technology.

The Carl Moyer Program provides incentive funds for significant near-term reductions in NOx. Eligible project types under the Carl Moyer Program include: new alternative fuel vehicle projects, on and off-road vehicle engine replacement projects, agricultural pump engine replacements, locomotive engine replacements, marine vessels, forklifts, and airport ground support equipment engine replacements. Projects are funded based on cost effectiveness, utilizing criteria developed by the state in coordination with the air districts and the statewide Incentive Program Implementation Team (IPI).

In addition to the sources listed above, the District receives grant funds from other state and federal funding sources including: the State’s Lower Emission School Bus Program, Peaker Plant Offset funds, and the State’s NOx and PM Program funds.

IV. EMISSIONS REDUCTION OPTIONS FOR CONSTRUCTION

Construction PM10 emissions can be mitigated in numerous ways. The following discussion lists measures/conditions, if implemented that would result in emissions reductions from construction activities. The percent reduction identified was based on the URBEMIS2002 Users’ Guide.

A. On-site Reduction Options

There are several on-site construction emissions reductions available. The following lists the current mitigation measures that reduce PM10 and NOx. There is a statewide effort to update the construction portion of URBEMIS, so there may be more mitigation measures identified that are not included in this appendix.

Equipment Exhaust Control There are several options available for controlling NOx and PM10 emissions from equipment used for construction. Options can include, purchasing newer equipment, altering fuel usage, modifying an engine, using exhaust after-treatments, or renting equipment that help meet the rule requirements. New equipment can provide a high percentage of emissions reductions, depending on the horsepower and the year of the equipment. Reductions that can occur from using newer equipment reductions range from 8-62% for PM10, and 20-38% for NOx. Different fuels are available for use that would reduce emissions from construction equipment. Ultra-low sulfur diesel can achieve a 5-9% reduction in PM10. Alternative diesel fuels can achieve 5-16% reduction in NOx and a 40-63% reduction in PM10. Diesel oxidation catalysts can reduce PM10 by 25-50%. Diesel particulate filters can reduce PM10 by 85%. Selective Catalytic Reduction can reduce NOx by 80% and PM10 by 25%.

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### B - 11 Worker Commute Trip Reductions This measure would entail using a shuttle to take construction workers to a retail establishment for lunch. This would eliminate numerous trips, which would reduce vehicle exhaust, and entrained and/or re-entrained road dust. The maximum PM10 reduction from this measure is 1.3%.

B. Off-site Reduction Options

Since any fees collected will reduce construction emissions off-site, the same emissions reduction options listed in section III above apply.

V. PROJECT-SPECIFIC EMISSIONS REDUCTIONS

Each development project, subject to Rule 9510, will have an assessment of the project performed. The assessment will include an APCO-approved model run that identifies the project or project phase baseline emissions and the emissions reduction resulting from on-site mitigation measures. The remaining emissions will be quantified and will fund emissions reduction project(s), using the fee formulas identified below.

Area and Operational NOx Fee Formula The NOx fee formula must identify the total tonnage of mitigation required, subtract the tonnage mitigated on-site, and multiply the remaining tonnage by the cost of reductions in order to determine the cost to reduce emissions off-site.

Figure 3

Baseline tons

1⁄2 baseline tons

0 (Years) 10

Figure 3 represents a development project’s NOx emissions over a period of ten years. Section A represents the emissions reductions projected to be achieved from ARB’s tailpipe control, which is 25% of the total project’s 10 years emissions. The remaining 75% is the project’s estimated NOx emissions for ten years. The mitigation required by Rule 9510 is represented by the triangle B, which equal to a third of the non-A section. Thus, the total tonnage of mitigation required can be identified as follows: A

B

C

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### B - 12 Estimated Baseline Emissions (tons) x 10 years x 75% 3

which is equal to:

EBE (tons) x 2.5

The next step is to subtract the percent reduction achieved from on-site mitigation measures. This is determined by using the estimated baseline emissions over ten years and applying the percent mitigation, as follows:

Estimated Baseline Emissions (tons) x 10 years x 75% x Actual % Mitigation =EBE x 7.5 x APM

Thus, (EBE x 2.5)

- (EBE x 7.5 x APM)

determines the total emissions remaining to mitigate off-site. That number then needs to multiplied by dollars per ton, in order to determine total dollars required to mitigation emissions off-site. The resulting NOx Air Impact Mitigation Fee is as follows:

[EBE x 2.5] - [EBE x 7.5 x APM] x [Cost of NOx Reductions/ton]

It is important to note that the percent reduction achieved onsite, results in a greater reduction of the NOx fee. While on-site mitigation is not required, the “bigger bang for the buck” is achieved with as much on-site mitigation as possible.

Area and Operational PM10 Fee Formula The Air Impact Mitigation Fee for PM10 is more straightforward since a project’s PM10 emissions remain relatively constant over the life of the project. For ease of understanding, Figure 4 below demonstrates the relationship between baseline emissions, mitigated emissions and half of the baseline emissions.

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### B - 13 Figure 4 

### PM10 Project Emissions and Reductions Compared to 50% of the First Year Emissions

0 0.005

0.01 0.015

0.02 0.025

1 2 3 4 5 6 7 8 9 10

Number of YearsEmissions (tons)

Baseline Project Emissions On-site Mitigation at 20%

50% of First Year



### The required PM10 mitigation is half of the baseline emissions for ten years. In order to determine the emissions that are subject to a fee, half of the baseline emissions need to be subtracted from the Mitigated Emissions and multiplied by cost of reductions in dollars per ton. Thus the resulting PM10 Air Impact Mitigation Fee is calculated as follows:

(Mitigated PM10 emissions – 1⁄2 Baseline PM10 emissions) (Cost of PM10 Reductions)

Construction Formulas

The Air Impact Mitigation Fees for construction are based on the project’s estimated construction equipment emissions, and compared to the statewide fleet average emissions. The required information is as follows: 1)a list of construction equipment used, 2)the model year, and 3)the hours estimated to be used is compiled, which can be determined from the National Construction Estimator or using project-specific information if known. Then the model specific emission factors are used to determine the actual estimated emissions (designated as AEE). The same hours are multiplied by a statewide average fleet emission factor for a particular year, to determine the statewide average estimated emissions (designated as SEE). Since the requirement is to reduce construction NOx emissions by 20% beyond the statewide average, this is determined as follows:

NOx Construction = (AEE) – [(1.00 x SEE) – (SEE x 0.20)] (AEE) – [1.00SEE – 0.20SEE] (AEE – 0.8SEE)

PM10 is almost identical, except that the requirement is to reduce construction PM10 emissions by 45% beyond the statewide average.

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### B - 14 PM10 Construction = (AEE) – [(1.00 x SEE) – (SEE x 0.45)] (AEE) – [1.00SEE – 0.45SEE] (AEE – 0.55SEE)

VI. EMISSIONS REDUCTIONS FROM RULE 9510

Both the 2003 PM10 Plan and the Extreme Ozone Attainment Demonstration Plan, contain emissions reduction commitments for proposed Rule 9510 of 4.1 tons per day of NOx and 5.2 tons per day of PM10 to be achieved by 2010. Those estimates were based on assumptions at the time and are commitments that are necessary to assist the district in meeting the federal and state PM10 and NOx standards. The methodology contained in this section and related attachments demonstrate the draft emission reductions for the program.

As part of determining the emissions reductions, sources that are exempt from the rule need to be subtracted out. The District has numerous years of experience in commenting on projects subject to CEQA. Based on that experience and the thresholds contained in Rule 9510, it is estimated that 15% of all development project emissions will be exempt from the provisions that rule. Attachment 2 and Attachment 3 identify the growth in emissions for each pollutant for each year, and subtract the emissions that will be exempt from the program. Once the emissions subject to the program are identified, the required mitigation is applied, which is 33.3% of baseline NOx emissions over ten years, 50% of baseline operational PM10 emissions over ten years, 20% of constructionNOx emissions and 45% of construction PM10 emissions. The reductions achieved onsite were calculated by multiplying the estimated percent of sources opting to use onsite measures, the percent reduction achieved on-site, by the baseline emissions. Offsite reductions were estimated differently. Since grant programs typically rely on project life to determine cost effectiveness and emissions reductions, the reduction was divided by the average project life for that pollutant’s cost-effectiveness, which is 7 years for NOx and 12 years for PM10, and spread out over that number of years. Attachment 2 and 3 contain the detailed emission reductions calculations. The results of those calculations reveal that the program, as currently defined, will result in reductions of 5.4 tons per day of NOx in 2010 and 5.8 tons per day of PM10 in 2010.

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### B - 15 

## Attachment 1 - Emissions and Growth in Emissions from Motor Vehicles

Passenger Cars

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 46,763,000 1,186,080 27.53 25.64 1.69 282.88 CY 2007 48,037,000 1,215,840 25.06 23.34 1.73 260.25 CY2008 49,324,000 1,246,060 22.80 21.26 1.77 239.16 CY2009 50,625,000 1,276,970 20.74 19.32 1.81 219.49 CY2010 51,952,000 1,308,670 18.80 17.52 1.85 200.89 CY2011 53,253,000 1,340,690 17.11 15.87 1.90 184.01 CY2012 54,544,000 1,373,190 15.61 14.39 1.94 168.64 CY2013 55,835,000 1,406,290 14.28 13.07 1.99 154.78 CY2014 57,127,000 1,440,000 13.12 11.89 2.04 142.42 CY2015 58,427,000 1,474,400 12.12 10.85 2.08 131.38 Total - No Growth VMT Pop ROG NOx PM10 CO CY 2006 46,763,000 1,186,080 27.53 25.64 1.69 282.88 CY 2007 46,817,000 1,184,970 23.52 21.39 1.68 242.70 CY2008 46,857,000 1,183,740 20.86 18.97 1.68 217.58 CY2009 46,878,000 1,182,430 18.52 16.81 1.67 194.91 CY2010 46,885,000 1,181,030 16.38 14.86 1.67 174.13 CY2011 46,849,000 1,179,460 14.55 13.13 1.67 155.73 CY2012 46,784,000 1,177,840 12.96 11.61 1.67 139.41 CY2013 46,702,000 1,176,250 11.58 10.29 1.66 125.00 CY2014 46,601,000 1,174,680 10.39 9.13 1.66 112.39 CY2015 46,487,000 1,173,100 9.37 8.14 1.66 101.32 Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 1,220,000 30,870 1.54 1.95 0.05 17.55 CY2008 2,467,000 62,320 1.94 2.29 0.09 21.58 CY2009 3,747,000 94,540 2.22 2.51 0.14 24.58 CY2010 5,067,000 127,640 2.42 2.66 0.18 26.76 CY2011 6,404,000 161,230 2.56 2.74 0.23 28.28 CY2012 7,760,000 195,350 2.65 2.78 0.27 29.23 CY2013 9,133,000 230,040 2.70 2.78 0.33 29.78 CY2014 10,526,000 265,320 2.73 2.76 0.38 30.03 CY2015 11,940,000 301,300 2.75 2.71 0.42 30.06



## Light-Duty Truck (GVWR < 3,751 lbs)

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 19,277,000 504,871 16.65 16.97 0.75 191.39 CY 2007 19,879,000 518,651 15.59 15.63 0.77 177.66

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Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 16 CY2008 20,503,000 532,766 14.54 14.39 0.78 164.45 CY2009 21,148,000 547,300 13.50 13.21 0.80 151.41 CY2010 21,810,000 562,308 12.50 12.10 0.82 138.99 CY2011 22,456,000 577,812 11.70 11.10 0.84 128.18 CY2012 23,103,000 593,638 10.97 10.22 0.86 118.33 CY2013 23,754,000 609,742 10.27 9.41 0.88 109.08 CY2014 24,410,000 626,177 9.61 8.68 0.90 100.56 CY2015 25,072,000 642,987 9.02 8.01 0.93 92.73 Total - No Growth VMT Pop ROG NOx PM10 CO CY 2006 19,277,000 504,871 16.65 16.97 0.75 191.39 CY 2007 19,374,000 505,480 14.54 14.03 0.75 163.40 CY2008 19,478,000 506,121 13.21 12.57 0.74 147.26 CY2009 19,582,000 506,782 11.96 11.22 0.74 132.09 CY2010 19,683,000 507,465 10.80 10.01 0.74 118.19 CY2011 19,756,000 508,326 9.87 8.96 0.74 106.40 CY2012 19,816,000 509,186 9.04 8.04 0.74 95.88 CY2013 19,869,000 510,001 8.26 7.22 0.74 86.35 CY2014 19,912,000 510,803 7.55 6.49 0.74 77.79 CY2015 19,949,000 511,590 6.93 5.86 0.74 70.11 Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 505,000 13,171 1.05 1.60 0.02 14.26 CY2008 1,025,000 26,645 1.33 1.82 0.04 17.19 CY2009 1,566,000 40,518 1.54 1.99 0.06 19.32 CY2010 2,127,000 54,843 1.70 2.09 0.08 20.80 CY2011 2,700,000 69,486 1.83 2.14 0.10 21.78 CY2012 3,287,000 84,452 1.93 2.18 0.12 22.45 CY2013 3,885,000 99,741 2.01 2.19 0.14 22.73 CY2014 4,498,000 115,374 2.06 2.19 0.16 22.77 CY2015 5,123,000 131,397 2.09 2.15 0.19 22.62



## Light-Duty Truck (GVWR 3,751 to 5,750 lbs)

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 14,206,000 363,542 11.60 15.81 0.74 133.05 CY 2007 14,550,000 373,494 11.03 14.80 0.76 125.36 CY2008 14,919,000 383,713 10.48 13.85 0.78 117.89 CY2009 15,308,000 394,213 9.95 12.93 0.80 110.66 CY2010 15,718,000 405,048 9.44 12.05 0.83 103.67 CY2011 16,150,000 416,094 8.90 11.17 0.85 96.52 CY2012 16,591,000 427,382 8.39 10.34 0.87 89.90 CY2013 17,045,000 438,884 7.89 9.56 0.90 83.57 CY2014 17,507,000 450,596 7.40 8.83 0.92 77.55 CY2015 17,972,000 462,557 6.97 8.16 0.95 72.09

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 17 Total - No Growth VMT Pop ROG NOx PM10 CO CY 2006 14,206,000 363,542 11.60 15.81 0.74 133.05 CY 2007 14,180,000 364,010 10.37 13.49 0.74 116.90 CY2008 14,173,000 364,523 9.61 12.29 0.74 107.14 CY2009 14,175,000 365,028 8.90 11.17 0.74 98.08 CY2010 14,185,000 365,543 8.25 10.14 0.74 89.63 CY2011 14,208,000 366,056 7.59 9.16 0.75 81.45 CY2012 14,230,000 366,582 6.99 8.27 0.75 74.06 CY2013 14,257,000 367,092 6.42 7.46 0.75 67.24 CY2014 14,281,000 367,573 5.87 6.72 0.75 60.96 CY2015 14,300,000 368,032 5.41 6.06 0.75 55.36 Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 370,000 9,484 0.66 1.31 0.02 8.46 CY2008 746,000 19,190 0.87 1.56 0.04 10.75 CY2009 1,133,000 29,185 1.05 1.76 0.06 12.58 CY2010 1,533,000 39,505 1.19 1.91 0.09 14.04 CY2011 1,942,000 50,038 1.31 2.01 0.10 15.07 CY2012 2,361,000 60,800 1.40 2.07 0.12 15.84 CY2013 2,788,000 71,792 1.47 2.10 0.15 16.33 CY2014 3,226,000 83,023 1.53 2.11 0.17 16.59 CY2015 3,672,000 94,525 1.56 2.10 0.20 16.73



## Medium-Duty Truck (GVWR 5,751 to 8,500 lbs)

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 5,521,000 141,790 5.01 7.94 0.29 57.52 CY 2007 5,679,000 146,113 4.79 7.46 0.30 54.45 CY2008 5,844,000 150,494 4.57 7.00 0.31 51.57 CY2009 6,017,000 155,025 4.36 6.56 0.32 48.81 CY2010 6,196,000 159,717 4.16 6.15 0.33 46.11 CY2011 6,369,000 164,373 3.96 5.74 0.33 43.46 CY2012 6,547,000 169,143 3.77 5.35 0.34 40.99 CY2013 6,728,000 174,015 3.60 4.99 0.36 38.71 CY2014 6,914,000 178,995 3.44 4.65 0.37 36.65 CY2015 7,105,000 184,102 3.29 4.34 0.38 34.70 Total - No Growth VMT Pop ROG NOx PM10 CO CY 2006 5,521,000 141,790 5.01 7.94 0.29 57.52 CY 2007 5,535,000 142,403 4.47 6.84 0.29 50.71 CY2008 5,552,000 142,967 4.16 6.25 0.29 46.84 CY2009 5,571,000 143,548 3.87 5.71 0.29 43.19 CY2010 5,591,000 144,140 3.60 5.20 0.29 39.82 CY2011 5,603,000 144,606 3.35 4.73 0.29 36.65 CY2012 5,615,000 145,080 3.12 4.30 0.30 33.75

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 18 CY2013 5,628,000 145,550 2.91 3.91 0.30 31.12 CY2014 5,640,000 146,015 2.72 3.55 0.30 28.80 CY2015 5,653,000 146,480 2.54 3.24 0.30 26.65 Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 144,000 3,710 0.32 0.62 0.01 3.74 CY2008 292,000 7,527 0.41 0.75 0.02 4.73 CY2009 446,000 11,477 0.49 0.85 0.03 5.62 CY2010 605,000 15,577 0.56 0.95 0.04 6.29 CY2011 766,000 19,767 0.61 1.01 0.04 6.81 CY2012 932,000 24,063 0.65 1.05 0.04 7.24 CY2013 1,100,000 28,465 0.69 1.08 0.06 7.59 CY2014 1,274,000 32,980 0.72 1.10 0.07 7.85 CY2015 1,452,000 37,622 0.75 1.10 0.08 8.05



## Light Heavy-Duty Truck (GVWR 8,501 to 10,000 lbs)

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 2,281,000 34,879 2.13 5.00 0.12 12.85 CY 2007 2,304,000 35,651 1.96 4.95 0.12 11.55 CY2008 2,321,000 36,449 1.84 4.89 0.13 10.52 CY2009 2,334,000 37,270 1.74 4.84 0.13 9.70 CY2010 2,344,000 38,123 1.68 4.71 0.13 9.01 CY2011 2,351,000 38,998 1.65 4.58 0.13 8.49 CY2012 2,356,000 39,887 1.63 4.46 0.13 8.06 CY2013 2,362,000 40,784 1.63 4.34 0.13 7.67 CY2014 2,371,000 41,696 1.63 4.23 0.13 7.34 CY2015 2,384,000 42,634 1.64 4.13 0.13 7.04 Total - No Growth VMT Pop ROG NOx PM10 CO CY 2006 2,281,000 34,879 2.13 5.00 0.12 12.85 CY 2007 2,246,000 34,746 1.91 4.82 0.12 11.24 CY2008 2,205,000 34,626 1.74 4.64 0.12 9.99 CY2009 2,161,000 34,511 1.61 4.48 0.12 8.97 CY2010 2,115,000 34,405 1.51 4.24 0.12 8.13 CY2011 2,068,000 34,309 1.45 4.02 0.11 7.46 CY2012 2,021,000 34,213 1.40 3.82 0.11 6.91 CY2013 1,976,000 34,113 1.36 3.63 0.11 6.42 CY2014 1,934,000 34,014 1.33 3.45 0.11 5.98 CY2015 1,897,000 33,921 1.31 3.28 0.10 5.60

Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 58,000 905 0.05 0.13 0.00 0.31 CY2008 116,000 1,823 0.10 0.25 0.01 0.53 CY2009 173,000 2,759 0.13 0.36 0.01 0.73

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 19 CY2010 229,000 3,718 0.17 0.47 0.01 0.88 CY2011 283,000 4,689 0.20 0.56 0.02 1.03 CY2012 335,000 5,674 0.23 0.64 0.02 1.15 CY2013 386,000 6,671 0.27 0.71 0.02 1.25 CY2014 437,000 7,682 0.30 0.78 0.02 1.36 CY2015 487,000 8,713 0.33 0.85 0.03 1.44



## Light Heavy-Duty Truck (GVWR 10,001 to 14,000 lbs)

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 624,000 10,645 0.76 2.78 0.06 4.45 CY 2007 626,000 10,885 0.75 2.67 0.05 4.18 CY2008 630,000 11,133 0.74 2.57 0.05 3.93 CY2009 637,000 11,387 0.72 2.47 0.05 3.67 CY2010 645,000 11,651 0.70 2.33 0.05 3.42 CY2011 653,000 11,922 0.68 2.19 0.05 3.18 CY2012 664,000 12,200 0.66 2.06 0.05 2.98 CY2013 674,000 12,484 0.64 1.93 0.05 2.79 CY2014 686,000 12,773 0.62 1.81 0.05 2.63 CY2015 699,000 13,071 0.60 1.70 0.05 2.46 Total - No Growth VMT Pop ROG NOx PM10 CO CY 2006 624,000 10,645 0.76 2.78 0.06 4.45 CY 2007 611,000 10,609 0.73 2.60 0.05 4.07 CY2008 599,000 10,576 0.70 2.43 0.05 3.73 CY2009 590,000 10,544 0.67 2.29 0.05 3.40 CY2010 582,000 10,514 0.63 2.10 0.05 3.09 CY2011 575,000 10,489 0.60 1.92 0.04 2.80 CY2012 569,000 10,465 0.56 1.76 0.04 2.56 CY2013 564,000 10,442 0.53 1.61 0.04 2.34 CY2014 560,000 10,420 0.50 1.48 0.04 2.15 CY2015 556,000 10,400 0.47 1.35 0.04 1.96 Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 15,000 276 0.02 0.07 0.00 0.11 CY2008 31,000 557 0.04 0.14 0.00 0.20 CY2009 47,000 843 0.05 0.18 0.00 0.27 CY2010 63,000 1,137 0.07 0.23 0.00 0.33 CY2011 78,000 1,433 0.08 0.27 0.01 0.38 CY2012 95,000 1,735 0.10 0.30 0.01 0.42 CY2013 110,000 2,042 0.11 0.32 0.01 0.45 CY2014 126,000 2,353 0.12 0.33 0.01 0.48 CY2015 143,000 2,671 0.13 0.35 0.01 0.50

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 20 

## Medium Heavy-Duty Truck (GVWR 14,001 to 33,000 lbs)

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 1,844,000 32,324 4.23 20.26 0.61 31.38 CY 2007 1,897,000 33,004 3.94 19.34 0.58 29.10 CY2008 1,951,000 33,694 3.69 18.42 0.57 27.07 CY2009 2,005,000 34,411 3.45 17.53 0.56 25.24 CY2010 2,058,000 35,155 3.22 16.29 0.54 23.47 CY2011 2,113,000 35,925 3.00 15.10 0.52 21.80 CY2012 2,168,000 36,711 2.79 13.96 0.50 20.22 CY2013 2,223,000 37,512 2.60 12.87 0.49 18.77 CY2014 2,279,000 38,329 2.40 11.85 0.48 17.36 CY2015 2,334,000 39,167 2.23 10.88 0.46 16.05 Total - No Growth VMT Pop ROG NOx PM10 CO CY 2006 1,844,000 32,324 4.23 20.26 0.61 31.38 CY 2007 1,849,000 32,166 3.83 18.83 0.56 28.33 CY2008 1,853,000 32,009 3.49 17.48 0.54 25.68 CY2009 1,856,000 31,864 3.19 16.21 0.52 23.34 CY2010 1,857,000 31,726 2.90 14.68 0.49 21.15 CY2011 1,859,000 31,605 2.64 13.27 0.46 19.15 CY2012 1,860,000 31,488 2.39 11.96 0.43 17.32 CY2013 1,859,000 31,376 2.17 10.76 0.41 15.68 CY2014 1,859,000 31,267 1.96 9.65 0.39 14.15 CY2015 1,857,000 31,163 1.77 8.65 0.37 12.76 Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 48,000 838 0.11 0.51 0.02 0.77 CY2008 98,000 1,685 0.20 0.94 0.03 1.39 CY2009 149,000 2,547 0.26 1.32 0.04 1.90 CY2010 201,000 3,429 0.32 1.61 0.05 2.32 CY2011 254,000 4,320 0.36 1.83 0.06 2.65 CY2012 308,000 5,223 0.40 2.00 0.07 2.90 CY2013 364,000 6,136 0.43 2.11 0.08 3.09 CY2014 420,000 7,062 0.44 2.20 0.09 3.21 CY2015 477,000 8,004 0.46 2.23 0.09 3.29



## Heavy Heavy-Duty Truck (GVWR 33,001 to 60,000 lbs)

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 4,845,000 31,643 6.00 82.30 1.85 44.21 CY 2007 4,978,000 32,260 5.70 78.05 1.72 41.00 CY2008 5,123,000 32,896 5.44 73.87 1.65 38.44 CY2009 5,281,000 33,555 5.18 69.88 1.60 36.18 CY2010 5,449,000 34,235 4.90 64.43 1.52 33.93 CY2011 5,628,000 34,939 4.64 59.06 1.44 31.99

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 21 CY2012 5,817,000 35,648 4.39 53.91 1.37 30.10 CY2013 6,019,000 36,370 4.13 49.01 1.31 28.31 CY2014 6,235,000 37,118 3.91 44.50 1.26 26.84 CY2015 6,451,000 37,891 3.68 40.44 1.22 25.19 Total - No Growth VMT Pop ROG NOx PM10 CO CY 2006 4,845,000 31,643 6.00 82.30 1.85 44.21 CY 2007 4,852,000 31,440 5.49 75.87 1.67 39.47 CY2008 4,866,000 31,251 5.10 69.98 1.57 36.07 CY2009 4,890,000 31,071 4.73 64.51 1.48 33.09 CY2010 4,918,000 30,896 4.37 57.97 1.37 30.23 CY2011 4,951,000 30,738 4.03 51.80 1.27 27.78 CY2012 4,989,000 30,577 3.71 46.09 1.18 25.48 CY2013 5,034,000 30,420 3.41 40.86 1.10 23.37 CY2014 5,086,000 30,279 3.15 36.19 1.03 21.61 CY2015 5,133,000 30,148 2.90 32.08 0.97 19.78 Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 126,000 820 0.21 2.18 0.05 1.53 CY2008 257,000 1,645 0.34 3.89 0.08 2.37 CY2009 391,000 2,484 0.45 5.37 0.12 3.09 CY2010 531,000 3,339 0.53 6.46 0.15 3.70 CY2011 677,000 4,201 0.61 7.26 0.17 4.21 CY2012 828,000 5,071 0.68 7.82 0.19 4.62 CY2013 985,000 5,950 0.72 8.15 0.21 4.94 CY2014 1,149,000 6,839 0.76 8.31 0.23 5.23 CY2015 1,318,000 7,743 0.78 8.36 0.25 5.41



## School Bus

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 186,000 3,982 0.32 2.54 0.10 3.59 CY 2007 190,000 4,082 0.31 2.57 0.10 3.39 CY2008 195,000 4,185 0.31 2.60 0.10 3.35 CY2009 200,000 4,290 0.31 2.63 0.10 3.26 CY2010 205,000 4,398 0.31 2.65 0.10 3.22 CY2011 210,000 4,512 0.31 2.67 0.10 3.19 CY2012 216,000 4,627 0.32 2.66 0.10 3.15 CY2013 221,000 4,743 0.31 2.64 0.10 3.03 CY2014 227,000 4,861 0.31 2.62 0.10 2.93 CY2015 232,000 4,981 0.31 2.60 0.10 2.81 Total - No Growth VMT Pop ROG NOx PM10 CO CY 2006 186,000 3,982 0.32 2.54 0.10 3.59 CY 2007 185,000 3,978 0.30 2.50 0.10 3.30 CY2008 185,000 3,975 0.29 2.47 0.10 3.17

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 22 CY2009 185,000 3,972 0.29 2.43 0.09 3.01 CY2010 185,000 3,969 0.28 2.39 0.09 2.90 CY2011 185,000 3,969 0.28 2.34 0.09 2.80 CY2012 185,000 3,968 0.27 2.27 0.09 2.69 CY2013 185,000 3,967 0.26 2.20 0.09 2.53 CY2014 185,000 3,966 0.25 2.13 0.08 2.39 CY2015 185,000 3,963 0.24 2.06 0.08 2.23 Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 5,000 104 0.01 0.07 0.00 0.09 CY2008 10,000 210 0.02 0.13 0.00 0.18 CY2009 15,000 318 0.02 0.20 0.01 0.25 CY2010 20,000 429 0.03 0.26 0.01 0.32 CY2011 25,000 543 0.03 0.33 0.01 0.39 CY2012 31,000 659 0.05 0.39 0.01 0.46 CY2013 36,000 776 0.05 0.44 0.01 0.50 CY2014 42,000 895 0.06 0.49 0.02 0.54 CY2015 47,000 1,018 0.07 0.54 0.02 0.58



## Urban Bus

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 330,000 2,407 1.30 4.70 0.08 11.25 CY 2007 338,000 2,468 1.29 4.69 0.08 11.08 CY2008 347,000 2,531 1.28 4.68 0.08 10.88 CY2009 356,000 2,595 1.28 4.67 0.08 10.78 CY2010 365,000 2,661 1.27 4.66 0.08 10.55 CY2011 374,000 2,730 1.27 4.64 0.08 10.29 CY2012 384,000 2,800 1.26 4.56 0.08 9.87 CY2013 393,000 2,870 1.26 4.54 0.08 9.41 CY2014 403,000 2,942 1.26 4.44 0.08 9.05 CY2015 413,000 3,014 1.25 4.40 0.08 8.47 Total - No Growth VMT Pop ROG NOx PM10 CO CY 2006 330,000 2,407 1.30 4.70 0.08 11.25 CY 2007 330,000 2,406 1.25 4.56 0.07 10.78 CY2008 329,000 2,404 1.21 4.44 0.07 10.32 CY2009 329,000 2,403 1.17 4.31 0.07 9.97 CY2010 329,000 2,402 1.14 4.19 0.07 9.51 CY2011 329,000 2,402 1.11 4.07 0.07 9.04 CY2012 329,000 2,401 1.07 3.90 0.07 8.45 CY2013 329,000 2,401 1.04 3.79 0.06 7.86 CY2014 329,000 2,400 1.02 3.61 0.06 7.37 CY2015 329,000 2,398 0.98 3.49 0.06 6.72

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 23 Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 8,000 62 0.04 0.13 0.01 0.30 CY2008 18,000 127 0.07 0.24 0.01 0.56 CY2009 27,000 192 0.11 0.36 0.01 0.81 CY2010 36,000 259 0.13 0.47 0.01 1.04 CY2011 45,000 328 0.16 0.57 0.01 1.25 CY2012 55,000 399 0.19 0.66 0.01 1.42 CY2013 64,000 469 0.22 0.75 0.02 1.55 CY2014 74,000 542 0.24 0.83 0.02 1.68 CY2015 84,000 616 0.27 0.91 0.02 1.75



## Motorhome

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 531,000 34,851 0.84 2.04 0.03 21.00 CY 2007 552,000 36,150 0.80 2.01 0.03 19.78 CY2008 574,000 37,508 0.75 1.97 0.03 18.26 CY2009 598,000 38,927 0.70 1.93 0.03 16.91 CY2010 624,000 40,417 0.66 1.86 0.03 15.57 CY2011 651,000 42,003 0.60 1.79 0.03 14.09 CY2012 679,000 43,650 0.56 1.72 0.03 12.73 CY2013 709,000 45,360 0.50 1.63 0.04 11.26 CY2014 741,000 47,134 0.45 1.54 0.04 9.86 CY2015 772,000 48,973 0.40 1.46 0.04 8.67 Total - No Growth VMT Pop ROG NOx PM10 CO CY 2006 531,000 34,851 0.84 2.04 0.03 21.00 CY 2007 538,000 35,232 0.78 1.95 0.03 19.27 CY2008 546,000 35,632 0.71 1.87 0.03 17.33 CY2009 554,000 36,045 0.65 1.78 0.03 15.65 CY2010 563,000 36,475 0.59 1.68 0.03 14.04 CY2011 573,000 36,951 0.53 1.57 0.03 12.39 CY2012 583,000 37,440 0.48 1.47 0.03 10.92 CY2013 593,000 37,940 0.42 1.36 0.03 9.41 CY2014 604,000 38,449 0.37 1.25 0.03 8.04 CY2015 615,000 38,965 0.32 1.15 0.03 6.89

Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 14,000 918 0.02 0.06 0.00 0.51 CY2008 28,000 1,876 0.04 0.10 0.00 0.93 CY2009 44,000 2,882 0.05 0.15 0.00 1.26 CY2010 61,000 3,942 0.07 0.18 0.00 1.53 CY2011 78,000 5,052 0.07 0.22 0.00 1.70 CY2012 96,000 6,210 0.08 0.25 0.00 1.81 CY2013 116,000 7,420 0.08 0.27 0.01 1.85

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 24 CY2014 137,000 8,685 0.08 0.29 0.01 1.82 CY2015 157,000 10,008 0.08 0.31 0.01 1.78



## Motorcycle

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 342,000 38,680 2.17 0.55 0.02 20.14 CY 2007 352,000 39,251 2.14 0.57 0.03 20.42 CY2008 361,000 39,854 2.06 0.57 0.02 19.23 CY2009 369,000 40,483 1.99 0.56 0.02 18.12 CY2010 376,000 41,132 1.93 0.56 0.02 17.19 CY2011 383,000 41,807 1.88 0.56 0.02 16.31 CY2012 389,000 42,499 1.85 0.56 0.02 15.62 CY2013 395,000 43,204 1.83 0.56 0.02 15.05 CY2014 401,000 43,920 1.81 0.57 0.02 14.58 CY2015 408,000 44,655 1.80 0.57 0.02 14.21 Total - No Growth VMT Pop ROG NOx PM10 CO CY 2006 342,000 38,680 2.17 0.55 0.02 20.14 CY 2007 343,000 38,255 2.08 0.55 0.02 19.89 CY2008 343,000 37,861 1.95 0.54 0.02 18.27 CY2009 342,000 37,486 1.84 0.52 0.02 16.79 CY2010 339,000 37,121 1.74 0.51 0.02 15.52 CY2011 337,000 36,780 1.66 0.49 0.02 14.37 CY2012 333,000 36,453 1.59 0.48 0.02 13.42 CY2013 330,000 36,136 1.53 0.47 0.02 12.61 CY2014 327,000 35,827 1.48 0.46 0.02 11.91 CY2015 324,000 35,529 1.43 0.45 0.02 11.32 Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 9,000 996 0.06 0.02 0.01 0.53 CY2008 18,000 1,993 0.11 0.03 0.00 0.96 CY2009 27,000 2,997 0.15 0.04 0.00 1.33 CY2010 37,000 4,011 0.19 0.05 0.00 1.67 CY2011 46,000 5,027 0.22 0.07 0.00 1.94 CY2012 56,000 6,046 0.26 0.08 0.00 2.20 CY2013 65,000 7,068 0.30 0.09 0.00 2.44 CY2014 74,000 8,093 0.33 0.11 0.00 2.67 CY2015 84,000 9,126 0.37 0.12 0.00 2.89

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 25 

## San Joaquin Valley - Total

Total - Growth VMT Pop ROG NOx PM10 CO CY 2006 96,748,000 2,385,690 78.53 186.52 6.33 813.73 CY 2007 99,384,000 2,447,850 73.37 176.07 6.25 758.21 CY2008 102,094,000 2,511,290 68.48 166.08 6.27 704.76 CY2009 104,878,000 2,576,430 63.91 156.53 6.30 654.24 CY2010 107,741,000 2,643,520 59.57 145.29 6.30 606.01 CY2011 110,590,000 2,711,800 55.70 134.46 6.30 561.51 CY2012 113,456,000 2,781,370 52.19 124.18 6.32 520.59 CY2013 116,360,000 2,852,260 48.93 114.56 6.34 482.43 CY2014 119,300,000 2,924,540 45.95 105.61 6.38 447.77 CY2015 122,271,000 2,998,430 43.32 97.54 6.43 415.80 Total - No Growth VMT Pop* ROG NOx PM10 CO CY 2006 96,748,000 2,385,690 78.53 186.52 6.33 813.73 CY 2007 96,860,000 2,385,690 69.25 167.42 6.09 710.08 CY2008 96,988,000 2,385,690 63.03 153.93 5.95 643.40 CY2009 97,114,000 2,385,690 57.40 141.45 5.83 582.49 CY2010 97,233,000 2,385,690 52.20 127.97 5.68 526.32 CY2011 97,291,000 2,385,690 47.65 115.47 5.54 476.01 CY2012 97,315,000 2,385,690 43.59 103.99 5.42 430.85 CY2013 97,326,000 2,385,690 39.89 93.55 5.30 389.92 CY2014 97,319,000 2,385,690 36.58 84.13 5.20 353.53 CY2015 97,284,000 2,385,690 33.68 75.81 5.12 320.71 Total - Difference VMT Pop ROG NOx PM10 CO CY 2007 2,524,000 62,160 4.12 8.65 0.16 48.13 CY2008 5,106,000 125,600 5.45 12.15 0.32 61.36 CY2009 7,764,000 190,740 6.51 15.08 0.47 71.75 CY2010 10,508,000 257,830 7.37 17.32 0.62 79.69 CY2011 13,299,000 326,110 8.05 18.99 0.76 85.50 CY2012 16,141,000 395,680 8.60 20.19 0.90 89.74 CY2013 19,034,000 466,570 9.04 21.01 1.04 92.51 CY2014 21,981,000 538,850 9.37 21.48 1.18 94.24 CY2015 24,987,000 612,740 9.64 21.73 1.31 95.09 * Note: The EMFAC model slightly redistributed vehicle populations within vehicle classes; however, the total vehicle population are all CY2006 numbers. See below:

CY2007 with CY2006 Veh Pop: 2,385,695Compared to: 2,385,690 % Difference: 0.00021%

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 26 Attachment 2 NOx Emissions and Emissions Reductions NOx Emissions (tons per day) Emission Inventory Category 2006 2007 2008 2009 2010 2011 2012 2013 2014

Total Growth in Motor Vehicle Emissions A 0.0 8.3 11.6 14.3 16.4 17.9 19.0 19.8 20.2

Total Annual Growth in Motor Vehicles Emissions A 0.0 8.3 3.2 2.7 2.1 1.5 1.1 0.7 0.5 Rule Penetration (tpd) B 0.0 7.1 2.7 2.3 1.8 1.3 1.0 0.6 0.4 On-Site Reductions

Estimated Sources to perform on-site reductions C 40% 45% 50% 55% 60% 65% 70% 70% 70% Average Mitigation achieved on-site (%) C 7% 9% 11% 13% 14% 15% 15% 15% 15% Reductions from 2006 Development 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Reductions from 2007 Development 0.3 0.3 0.3 0.2 0.2 0.2 0.2 0.2 Reductions from 2008 Development 0.2 0.1 0.1 0.1 0.1 0.1 0.1 Reductions from 2009 Development 0.2 0.2 0.1 0.1 0.1 0.1 Reductions from 2010 Development 0.1 0.1 0.1 0.1 0.1 Reductions from 2011 Development 0.1 0.1 0.1 0.1 Reductions from 2012 Development 0.1 0.1 0.1 Reductions from 2013 Development 0.1 0.1 Reductions from 2014 Development 0.0

Total On-site Reductions D 0.0 0.3 0.4 0.6 0.7 0.8 0.8 0.8 0.8 Off-site Reductions Remaining Subject Emissions E 0.0 6.8 2.6 2.2 1.6 1.2 0.9 0.5 0.4 Reductions from 2006 Development 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Reductions from 2007 Development 2.4 2.4 2.4 2.4 2.4 2.4 2.4 Reductions from 2008 Development 0.9 0.9 0.9 0.9 0.9 0.9 0.9 Reductions from 2009 Development 0.8 0.8 0.8 0.8 0.8 0.8 Reductions from 2010 Development 0.6 0.6 0.6 0.6 0.6 Reductions from 2011 Development 0.4 0.4 0.4 0.4 Reductions from 2012 Development 0.3 0.3 0.3 Reductions from 2013 Development 0.2 0.2 Reductions from 2014 Development 0.1

Total Off-site Reductions F 0.0 2.4 3.4 4.1 4.7 5.1 5.4 5.6 3.3

Total Reductions 0.0 2.7 3.8 4.7 5.4 5.9 6.3 6.5 4.2

A. ARB performed an EMFAC2002 model run that estimated the growth between 2006 and 2015 (Attachment 1). Since this analysis needs growth per year, the current year's missions are subtracted by the previous year's emissions to obtain the annual growth. Medium-Heavy and Heavy-Heavy Duty emissions have been reduced by 12% to account for through-valley traffic

B. Rule penetration is estimated to be 85% based on District experience with CEQA projects. C. Staff estimate

D. Determined by multiplying rule penetration of operational emissions, estimated sources to perform on-site reductions, average mitigation achieved on-site, and adding the reductions for each year

E. Determined by subtracting a particular years on-site reduction from the Rule Penetration of Operational Emissions for that year

. F. Determined by multiplying Remaining Subject Emissions with 250%, and dividing by 7 to account for the average project life of the estimated emission reduction projects.

G. The rule requires mitigation of 250% of the first years emissions. That total was then divided by 7 to account for the average project life of the estimated emission reduction projects. On-Site reductions are reduced over time to account for the reduction in mobile emissions

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 27 Attachment 3 PM10 Emissions and Emissions Reductions

ANNUAL GROWTH IN PM10 EMISSIONS (tons per day) A

EMISSIONS INVENTORY CATEGORY 2006 2007 2008 2009 2010 2011 2012 2013 2014 Operational PM10 Emissions

Re-entrained Paved Road Dust B : Freeway 0.4 0.4 0.4 0.3 0.3 0.3 0.3 0.3 0.3 Collector Streets 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 Major Streets 0.4 0.4 0.4 0.4 0.4 0. 5 0. 5 0.5 0. 5 Local Streets 0.2 0.2 0.1 0.2 0.2 0.2 0.2 0.2 0.2 Rural Streets 0.4 0.4 0.4 0.4 0.4 0. 5 0. 5 0.5 0. 5 On-road vehicles C 0.0 0.2 0.2 0.2 0.2 0.1 0.1 0.1 0.1 Total Annual Growth in Operational PM10 Emissions 1.1 1.2 1.1 1.3 1.3 1.5 1.5 1.5 1.5 Cumulative Growth in Operational PM10 Emissions D 1.1 2.3 3.4 4.7 6.0 7.5 9.1 10.6 12.2 Rule Penetration of Operational Emissions (tpd) E 0.9 1.0 1.0 1.1 1.1 1.3 1.3 1.3 1.3 On-site Reductions Estimated Sources to perform on-site reductions F 40% 45% 50% 55% 60% 65% 70% 70% 70% Average Mitigation achieved on-site (%) F 7% 9% 11% 13% 14% 15% 15% 15% 15% Reductions from 2006 Development 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 Reductions from 2007 Development 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 Reductions from 2008 Development 0.05 0.05 0.05 0.05 0.05 0.05 0.05 Reductions from 2009 Development 0.08 0.08 0.08 0.08 0.08 0.08 Reductions from 2010 Development 0.09 0.09 0.09 0.09 0.09 Reductions from 2011 Development 0.13 0.13 0.13 0.13 Reductions from 2012 Development 0.14 0.14 0.14 Reductions from 2013 Development 0.14 0.14 Reductions from 2014 Development 0.14 Total On-site Reductions (tpd) G 0.0 0.1 0.1 0.2 0.3 0.4 0.6 0.7 0.8 Off-site Reductions Remaining Subject Emissions H 0.9 1.0 0.9 1.0 1.0 1.2 1.2 1.2 1.2 Reductions from 2006 Development 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 Reductions from 2007 Development 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 Reductions from 2008 Development 0.4 0.4 0.4 0.4 0.4 0.4 0.4 Reductions from 2009 Development 0.4 0.4 0.4 0.4 0.4 0.4 Reductions from 2010 Development 0.4 0.4 0.4 0.4 0.4 Reductions from 2011 Development 0.5 0.5 0.5 0.5 Reductions from 2012 Development 0.5 0.5 0.5 Reductions from 2013 Development 0.5 0.5 Reductions from 2014 Development 0.5

Total Off-site Reductions I 0.4 0.8 1.2 1.6 2.0 2.5 3.0 3.5 4.0 Total Operational PM10 Reductions J 0.4 0.9 1.3 1.8 2.3 2.9 3.5 4.2 4.8

A-P See footnotes on following pages.

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 28 ANNUAL EMISSIONS (tons per day) K

EMISSIONS INVENTORY CATEGORY 2006 2007 2008 2009 2010 2011 2012 2013 2014 Construction Equipment Emissions Total Construction Equipment NOx Emissions L 26.9 25.5 24.1 22.7 21.3 20.1 18.9 17.6 16.4 Construction Equipment PM10 Equivalent M 17.9 17.0 16.1 15.1 14.2 13.4 12.6 11.7 10.9 Rule Penetration of Construction Equipment Emissions (tpd) E 15.2 14.4 13.7 12.9 12.1 11.4 10.7 10.0 9.3 On-site Reductions Estimated Sources to perform fleet reductions (%) F 10% 20% 30% 40% 50% 50% 50% 50% 50% Average Fleet Reductions (%) N 20% 20% 20% 20% 20% 20% 20% 20% 20% Construction Fleet Reductions G 0.3 0.6 0.8 1.0 1.2 1.1 1.1 1.0 0.9 Off-site Reductions Remaining Emissions (tpd) 4 14.9 13.9 12.8 11.8 10.9 10.3 9.6 9.0 8.4 Reductions from 2006 Development 0.4 0.4 0.4 0.4 0.4 0.4 0.4 Reductions from 2007 Development 0.4 0.4 0.4 0.4 0.4 0.4 0.4 Reductions from 2008 Development 0.4 0.4 0.4 0.4 0.4 0.4 0.4 Reductions from 2009 Development 0.3 0.3 0.3 0.3 0.3 0.3 Reductions from 2010 Development 0.3 0.3 0.3 0.3 0.3 Reductions from 2011 Development 0.3 0.3 0.3 0.3 Reductions from 2012 Development 0.3 0.3 0.3 Reductions from 2013 Development 0.3 0.3 Reductions from 2014 Development 0.2

Total Off-site Reductions O 0.4 0.8 1.2 1.5 1.8 2.1 2.4 2.2 2.1 Construction Equipment Reductions J 0.7 1.4 2.0 2.5 3.0 3.2 3.4 3.2 3.0

A. Annual Growth in emisions were determined by subtracting one years emissions from the previous year's emissions. Emissions' growth in 2011-2014 were determined by taking the difference between 2015 and 2010 and dividing that by 5 years.

B. The growth in these emissions were taken directly from the emissions inventory, and were reported by road type. Control for Regulation VIII is accounted for.

C. These totals were obtained from ARB. Current year's emissions are subtracted by the previous year's emissions to obtain the an nual growth.

D. Cumulative growth was determined by creating a running total of emissions from each year

E. Rule penetration is estimated to be 85% based on District experience with CEQA projects.

F. District staff estimate

G. Determined by multiplying rule penetration of operational emissions, estimated sources to perform on-site reductions, average mitigation achieved on-site, and adding the reductions for each year.

H. Determined by subtracting a particular years on-site reduction from the Rule Penetration of Operational Emissions for that year

. I. Equals 5 x Remaining Subject Emissions That total was then divided by 12 to account for the average project life of the estim ated emission reduction projects.

J. Determined by adding On-site Reductions and Off-site Reductions

K. Total emissions were used for each year, since all construction activity each year is for new development

L. These emissions were taken from ARB and interpolated based on 2005, 2010, and 2015.

M. Modeling in the 2003 PM10 indicated that 1.5 tons of NOx are equivalent to 1.0 tons of PM10.

N. This is a rule requirement

O. Determined by multiplying Remaining Subject Emissions with 20%, and dividing by 7 to account for the average project life of th e estimated emission reduction projects.

P. Determined by multiplying Remaining Subject Emissions with 45%, and dividing by 12 to account for the average project life of t he estimated emission reduction projects.

ANNUAL PM10 EMISSIONS (tons per day) K

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 29 EMISSIONS INVENTORY CATEGORY 2006 2007 2008 2009 2010 2011 2012 2013 2014 Construction PM10 Exhaust Emissions PM10 Exhaust from Construction Equipment L 1.7 1.6 1.5 1.4 1.4 1.3 1.2 1.2 1.1 Rule Penetration of Construction PM10 & PM10 Equiv. Emissions (tpd) E 1.4 1.4 1.3 1.2 1.2 1.1 1.0 1.0 0.9 On-site Reductions

Estimated Sources to perform on-site reductions (%) F 10% 20% 30% 40% 50% 50% 50% 50% 50% Average Mitigation achieved on-site (%) N 45% 45% 45% 45% 45% 45% 45% 45% 45% Onsite Reductions (tpd) G 0.1 0.1 0.2 0.2 0.3 0.2 0.2 0.2 0.2 Off-site Reductions Remaining Emissions (tpd) H 1.4 1.2 1.1 1.0 0.9 0.8 0.8 0.8 0.7 Reductions from 2006 Development 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 Reductions from 2007 Development 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 Reductions from 2008 Development 0.04 0.04 0.04 0.04 0.04 0.04 0.04 Reductions from 2009 Development 0.04 0.04 0.04 0.04 0.04 0.04 Reductions from 2010 Development 0.03 0.03 0.03 0.03 0.03 Reductions from 2011 Development 0.03 0.03 0.03 0.03 Reductions from 2012 Development 0.03 0.03 0.03 Reductions from 2013 Development 0.03 0.03 Reductions from 2014 Development 0.03 Reductions from 2015 Development

Total Off-site Reductions P 0.1 0.1 0.1 0.2 0.2 0.2 0.3 0.3 0.3 Total Construction PM10 Reductions (tpd) J 0.1 0.2 0.3 0.4 0.5 0.5 0.5 0.5 0.5

TOTAL ESTIMATED PM10 REDUCTIONS (tpd) 1.2 2.4 3.6 4.7 5.8 6.6 7.5 7.9 8.3

A. Annual Growth in emisions were determined by subtracting one years emissions from the previous year's emissions. Emissions' growth in 2011-2014 were determined by taking the difference between 2015 and 2010 and dividing that by 5 years.

B. The growth in these emissions were taken directly from the emissions inventory, and were reported by road type. Control for Regulation VIII is accounted for.

C. These totals were obtained from ARB. Current year's emissions are subtracted by the previous year's emissions to obtain the an nual growth.

D. Cumulative growth was determined by creating a running total of emissions from each year

E. Rule penetration is estimated to be 85% based on District experience with CEQA projects.

F. District staff estimate

G. Determined by multiplying rule penetration of operational emissions, estimated sources to perform on-site reductions, average mitigation achieved on-site, and adding the reductions for each year.

H. Determined by subtracting a particular years on-site reduction from the Rule Penetration of Operational Emissions for that year

. I. Equals 5 x Remaining Subject Emissions That total was then divided by 12 to account for the average project life of the estim ated emission reduction projects.

J. Determined by adding On-site Reductions and Off-site Reductions

K. Total emissions were used for each year, since all construction activity each year is for new development

L. These emissions were taken from ARB and interpolated based on 2005, 2010, and 2015.

M. Modeling in the 2003 PM10 indicated that 1.5 tons of NOx are equivalent to 1.0 tons of PM10.

N. This is a rule requirement

O. Determined by multiplying Remaining Subject Emissions with 20%, and dividing by 7 to account for the average project life of th e estimated emission reduction projects.

P. Determined by multiplying Remaining Subject Emissions with 45%, and dividing by 12 to account for the average project life of t he estimated emission reduction projects.

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions Reduction Analysis for Rule 9510 and 3180 December 15, 2005

Final Draft Staff Report for Proposed Rule 9510 and Rule 3180 

### B - 30 This page intentionally blank.