PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

-- REVISED --

PROPOSED 

2003 STATE AND FEDERAL STRATEGY FOR 

THE CALIFORNIA STATE IMPLEMENTATION PLAN 

Release Date: August 25, 2003

Hearing Date: September 24-25, 2003

California Environmental Protection Agency

Air Resources Board
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

DOCUMENT AVAILABILITY

Electronic copies of this document, the September hearing notice, and related materials

can be found on ARB’s web site at: http://www.arb.ca.gov/planning/sip/sip.htm.

Alternatively, paper copies may be obtained from the Board’s Public Information Office,

1001 I Street, 1st Floor, Environmental Services Center, Sacramento, California 95814,

(916) 322-2990.

If you are a person with a disability and desire to obtain this document in an alternative

format, please contact our Americans with Disabilities Act Coordinator at

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

the Sacramento area.

PROJECT LEADERS

Cynthia Marvin, Chief, Air Quality and Transportation Planning Branch 

Renee Kemena, P.E., Manager, Planning and Regulatory Development Section

David Mallory, P.E., Manager, Measures Development Section

Cindy Castronovo, Staff Air Pollution Specialist, Engineering and Certification Branch

Kim Heroy-Rogalski, P.E., Manager, State Implementation Plan Development Section

Edie Chang, P.E., Staff Air Pollution Specialist, State Implementation Plan Section

Robert Jenne, Senior Staff Counsel

CONTRIBUTORS

Managers and staff throughout the Air Resources Board contributed their expertise and

time on this project. While too numerous to recognize individually, their contributions

were vital to the final product.

CONTACTS

For questions, please see the contacts listed in Sections I through V.

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

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

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

September 23, 2003 and sent to:

Clerk of the Board

Air Resources Board

1001 I Street, 23rd Floor

Sacramento, California 95814

or by e-mail to: 2003sip@listserv.arb.ca.gov

or by facsimile transmission to the Clerk of the Board at (916) 322-3928
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

CONTENTS OF DOCUMENT

EXECUTIVE SUMMARY

SECTION I: OVERVIEW OF COMMITMENTS

SECTION II: MOBILE SOURCES

SECTION III: CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

SECTION IV: LONG-TERM STRATEGY

SECTION V: POTENTIAL IMPACTS

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

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

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

commercial products constitute endorsement or recommendation for use. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

EXECUTIVE SUMMARY

QUESTIONS AND ANSWERS

1. How would Board approval of the Proposed Strategy benefit public health? .... ES-1

2. What are the harmful effects of air pollution on our health? .............................. ES-1

3. Who regulates sources of air pollution in California? ........................................ ES-2

4. What areas violate the federal ozone and particulate standards?..................... ES-3

5. What is the State Implementation Plan (SIP)? .................................................. ES-3

6. How does the Proposed Strategy relate to the 1994 SIP? ................................ ES-3

7. Why is ARB proposing to update the State and federal SIP strategy now? ...... ES-4

8. How is the SIP connected to federal transportation funding?............................ ES-4

9. What air pollutants are targeted in the Proposed Strategy? ............................. ES-4

10. How did we develop the Proposed Strategy and seek public input? ................ ES-5

11. How does this document revise the May 2003 Proposed Strategy? ................. ES-5

12. How is the Proposed Strategy document structured? ....................................... ES-6

13. What is the legal framework for the proposed State commitments? ................. ES-6

14. What kinds of new measures are included in the Proposed Strategy? ............. ES-6

15. How would a defined SIP measure become a regulation?................................ ES-7

16. What is the federal government’s responsibility to reduce emissions from sources

under its control? ............................................................................................. ES-7

17. What emission reductions are needed for ozone attainment in

the South Coast? .............................................................................................. ES-8

18. What are the proposed near-term State commitments for the South Coast?.... ES-8

19. What are the proposed long-term State commitments for the South Coast? .... ES-8

20. What is the backstop if the federal government does not agree to achieve

additional reductions in South Coast by 2010? ............................................... ES-10
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

21. Is the State control strategy for the South Coast commensurate with the emissions

from sources under State jurisdiction?............................................................ ES-10

22. What commitments did the Board approve for the San Joaquin Valley

PM10 SIP? ..................................................................................................... ES-12

23. What about State commitments for other SIPs? ............................................. ES-12

24. How would the Proposed Strategy affect generation of emission

reduction credits?............................................................................................ ES-12

25. How would the Proposed Strategy support environmental justice and reduce

community exposure to air pollution?.............................................................. ES-13

26. How would the Proposed Strategy impact the State’s environment? .............. ES-13

27. How would the Proposed Strategy impact the State’s economy? ................... ES-13

28. What are the opportunities for public comment on the Proposed Strategy?.... ES-14

29. What is the staff recommendation for Board action?....................................... ES-14
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

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EXECUTIVE SUMMARY

1. How would Board approval of the Proposed Strategy benefit public health?

This Proposed 2003 State and Federal Strategy (Strategy) for the California

State Implementation Plan (SIP) reaffirms the Air Resources Board’s (ARB or Board)

commitment to achieve health-based air quality standards in all California communities

through specific near-term actions and development of additional longer-term strategies.

It maps out the next generation of statewide measures to reduce air pollution and the

associated harmful effects on our health, environment, and economy. It identifies the

Board’s near-term regulatory agenda to reduce ozone and particulate matter by

establishing enforceable targets to develop and adopt new measures for each year from

2003 to 2006. It provides emission reduction benchmarks for the Board and the public

to use in assessing proposed regulations to meet the overall goal. It includes

commitments for the Board to consider 19 specific measures that are potentially

capable of reducing ozone-forming emissions statewide by over 240 tons per day in

2010. It would also set into motion a concurrent initiative to identify longer-term

solutions to achieve the full scope of emission reductions needed to meet federal air

quality standards in the South Coast and San Joaquin Valley by 2010. In addition to

meeting federal requirements, this Strategy will ensure continued progress towards

California’s own health-based standards.

2. What are the harmful effects of air pollution on our health?

Current levels of air pollution exact a toll on our lives. Numerous studies have

linked particulate pollution to premature death in the elderly and other vulnerable

populations. Furthermore, researchers are concerned that particulate pollution may

also play a role in infant mortality and are currently investigating this possibility.

Research in Southern California also shows that children exposed to unhealthful levels

of ozone suffer decreased lung function growth and increased asthma. And air toxics,

like particles from diesel engines and benzene from gasoline, significantly increase our

cancer risk. 

Monitored air quality data and a health model allow us to quantify the potential

scope of harm to Californians from air pollution each year – from premature death to

asthma attacks, as well as the impacts on health care and productivity. For example,

attaining the State’s own health-based air quality standards for particulate matter and

ozone would annually prevent: 

• 6,500 premature deaths,

• 10,000 hospital admissions,

• 350,000 asthma attacks, and 

• 2.8 million lost work days. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

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3. Who regulates sources of air pollution in California?

In California, primary responsibility for controlling air pollution is shared by the

State ARB, 35 local air pollution control and air quality management districts (districts),

and the U.S. Environmental Protection Agency (U.S. EPA). 

State. ARB is responsible for improving outdoor air quality by controlling

emissions from mobile sources (except where federal law preempts ARB’s authority)

and consumer products, developing fuel specifications, adopting statewide control

measures for air toxics, establishing gasoline vapor recovery standards and certifying

vapor recovery systems, providing technical support to the local air districts, and

overseeing local air district compliance with State and federal law. The State

Department of Pesticide Regulation (DPR) is responsible for control of agricultural,

commercial and structural pesticides, while the Bureau of Automotive Repair (BAR)

runs the State’s Smog Check programs to identify and repair polluting cars.

Local. Local air districts are primarily responsible for controlling emissions from

stationary and areawide sources (with the exception of consumer products) through

rules and permitting programs. Examples of stationary and areawide sources include

industrial sources like factories, refineries, power plants, and smelters; commercial

sources like gas stations, dry cleaners, and paint spray booth operations; and

residential sources like fireplaces, water heaters, and house paints. Districts also

inspect and test fuel vapor recovery systems to check that such systems are operating

as certified. In addition, local transportation agencies are responsible for developing

and implementing transportation control measures aimed at reducing vehicle activity

and emissions.

Federal. U.S. EPA has the authority to control emissions from mobile sources,

including sources under exclusive federal jurisdiction (like interstate trucks, some farm

and construction equipment, aircraft, marine vessels, and locomotives based in this

country). International organizations develop standards for aircraft and marine vessels

that operate outside the United States. Federal agencies have the lead role in

representing the U.S. in the process of developing international standards. U.S. EPA

sets national ambient air quality standards for specific pollutants like ozone, inhalable

particulate matter (PM10), and the subset of fine particles (PM2.5). The agency also

has oversight authority for state air programs as they relate to the federal Clean Air Act. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

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4. What areas violate the federal ozone and particulate standards?

Air quality in the South Coast, San Joaquin Valley, and Imperial County

continues to violate the federal one-hour ozone and PM10 standards; the Sacramento

Region also experiences ozone levels above the existing federal standard. Coastal

regions including San Diego, Santa Barbara, Ventura, and the San Francisco Bay Area

have come into compliance with the one-hour ozone standard over the last few years.

San Diego and Santa Barbara have been redesignated as attainment. Ventura and

San Francisco also qualify for redesignation, but have not yet submitted redesignation

requests and maintenance plans. 

South Coast, San Joaquin Valley, Sacramento Region, Ventura, San Diego and

a number of counties downwind from these regions are expected to be designated as

nonattainment for the federal 8-hour ozone standard in 2004, based on monitoring data

through 2002. The Bay Area is just below the ozone standard and might be designated

as nonattainment if additional exceedances occur in 2003. The San Joaquin Valley,

South Coast, and San Diego are likely to be designated nonattainment for the federal

PM2.5 standards, based on monitoring data through 2002.

5. What is the State Implementation Plan (SIP)?

The SIP is our blueprint for meeting federal air quality standards by the

applicable deadlines set in the federal Clean Air Act. California’s SIP is a compilation of

region-specific plans that detail how each area will meet the air quality standards. The

plan includes an estimate of the emission reductions needed to meet each air quality

standard based on air monitoring results, data on emission sources, and complex air

quality modeling. It reflects the benefits of the pollution control program adopted by air

agencies at all levels, and may also include commitments to implement new strategies.

Together, these elements must reduce emissions by an amount sufficient to meet the

air quality standard in each region. Once the local element of the plan is adopted by the

air district(s) and other responsible local agencies, it is sent to ARB for adoption and

then formally submitted to the U.S. EPA for approval as a revision to the California SIP.

6. How does the Proposed Strategy relate to the 1994 SIP?

In 1994, ARB and local districts covering six regions of the State developed a

comprehensive control strategy to attain the federal one-hour ozone standard.

U.S. EPA approved that plan in 1997, and agreed to pursue appropriate measures for

sources under federal control as well. Most of the measures anticipated in the 1994

SIP, and many others, have since been adopted. We are proposing this Strategy to

update the existing State and federal SIP element. Upon approval by ARB, the Strategy

would identify a series of new State commitments to achieve the next increment of

progress toward the federal one-hour ozone and PM10 standards in the most polluted

urban areas. It also describes feasible approaches to reduce emissions from sources

under the jurisdiction of the federal government. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

ES-4

This Proposed 2003 State and Federal Strategy for the California SIP (Strategy)

would update and entirely replace the comprehensive statewide control strategy

contained in the existing 1994 Ozone SIP (as modified in 1999 for South Coast). For

areas of the State that have not yet achieved the full amount of emission reductions

committed to in the existing SIP, this proposed strategy would retain the existing

statewide commitments to achieve all of these emission reductions. However, the

specific statewide measures identified in the existing SIP would be entirely replaced by

the new proposed measures and control strategy to achieve these emission reductions.

For those areas, we will reflect the new Strategy in the region’s next SIP revision.

7. Why is ARB proposing to update the State and federal SIP strategy now?

First, recent scientific studies in the South Coast and San Joaquin Valley –

including improved emission inventories and air quality modeling – show that both

regions need further emission reductions to meet all of the existing federal air quality

standards by 2010. With virtually all of the State’s 1994 SIP measures already adopted

and being implemented, we must develop new measures to continue progress.

Second, new ozone SIPs are needed to address federal transportation conformity

requirements. Third, the San Joaquin Valley failed to attain the federal 1-hour ozone

standard in 1999 which triggered the requirement for a new attainment demonstration. 

8. How is the SIP connected to federal transportation funding?

The Clean Air Act says that the emissions from the transportation system must

“conform” or fit within the motor vehicle emissions budget established in the SIP to

support attainment of the air quality standards in each region. A transportation agency

must use the latest data to analyze the emissions projected to result from new

transportation projects and plans to determine “conformity.” A positive conformity

finding is required to obtain federal approval and funding to expand the transportation

system.

 

ARB has greatly improved the accuracy of its vehicle emissions inventory. More

extensive real-world testing of vehicles and greater numbers of older vehicles on the

road result in higher emissions than estimated in prior SIPs. Thus, transportation

agencies using the current vehicle data cannot make new conformity findings until the

SIPs and their vehicle budgets are updated with the same data. The higher vehicle

emissions also create a need for more control measures in the SIP to reduce them. 

9. What air pollutants are targeted in the Proposed Strategy? 

The Proposed Strategy will reduce the reactive organic gases (ROG) and

nitrogen oxides (NOx) that contribute to both ozone and PM10 formation; as well as

direct PM10 emissions, primarily from diesel soot. Some of the measures also provide

ancillary benefits – reducing emissions of toxic air pollutants and carbon monoxide.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

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10. How did we develop the Proposed Strategy and seek public input? 

As the Board neared adoption of all the defined measures in the 1994 SIP, ARB

staff began to outline the next generation of State and federal control measures. In

2001, we initiated a public process to identify new emission reduction strategies for

California. We solicited public input on options for reducing ozone, particulate, toxics,

and greenhouse gas pollution across California. We held two sets of workshops

throughout the State to hear ideas from the public and share our concepts. From those

efforts, the staff compiled an extensive list of potential control measures for sources

under State, federal, and local control. 

In January 2003, ARB staff released a draft of this document focused on the

subset of potential measures for sources under State and federal authority that would

help reduce ozone and PM10 by 2010 (the latest existing SIP deadline). In March and

April, we participated in eleven public workshops with the local air districts in the

South Coast and San Joaquin Valley, as well as an ARB technical workshop in both

those regions plus Sacramento, to discuss the draft State and federal SIP strategy.

ARB staff considered the public concerns and suggestions voiced at these workshops

and additional stakeholder meetings, as well as over 300 comment letters on the draft

Strategy. 

In May, we issued the Proposed Strategy document to support district actions on

the 2003 San Joaquin Valley PM10 SIP and the 2003 South Coast Ozone SIP. On

June 26, the Board approved a subset of the commitments to develop defined

measures on a statewide basis, with specified emission reductions to support the

San Joaquin Valley PM10 SIP. To address public concern and suggestions from the

regulated industry, staff proposed and the Board approved a change that consolidated

two defined measures for large spark-ignition equipment like forklifts. 

11. How does this document revise the May 2003 Proposed Strategy?

This document makes revisions to the May 2003 proposal based on subsequent

information. The measures and strategies are largely unchanged. A significant revision

is the consolidation of two measures proposed for large spark-ignited equipment like

forklifts (see Section II, Measure OFF-RD LSI-2). This version reflects the Board’s

actions on June 26 to approve the State commitments for the San Joaquin Valley PM10

SIP, as well as its July 24 adoption of low-sulfur requirements for on-road and off-road

diesel fuel throughout California. Another significant addition is the proposed State

long-term strategy for the South Coast, including staff’s proposal if U.S. EPA does not

carry out its responsibilities for new emission reductions (see questions 19 and 20). We

have also included minor updates to the range of anticipated reductions and timing for a

few near-term measures without changing the overall benefits of the proposed State

commitment. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

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12. How is the Proposed Strategy document structured?

• Executive Summary includes general questions and answers about the plan. 

• Section I: Overview of Commitments presents the legal framework for the

proposed State commitments, summarizes the measures and emission

reductions, and includes the legal authority.

• Section II: Mobile Sources presents existing and proposed measures for all

types of vehicles (cars, trucks, buses), off-road equipment, recreational boats

and vehicles, marine vessels and ports, aircraft and airports, locomotives and

railyards, plus conventional and alternative fuels.

• Section III: Consumer Products, Vapor Recovery, and Pesticides describes the

existing and proposed measures for these sources.

• Section IV: Long-Term Strategy identifies our initial thoughts on additional

approaches to further reduce emissions beyond the benefits of the defined

measures. This section also outlines concepts that the federal government could

use to reduce emissions from the sources it is responsible for controlling.

• Section V: Potential Impacts describes the possible effects of the defined

measures on California’s environment and economy, as well as the

environmental justice impacts. 

13. What is the legal framework for the proposed State commitments?

We are proposing a three-tiered commitment, described in Section I of this

document. The foundation is a near-term commitment to develop and propose for

Board consideration 19 defined statewide control measures. The Board could take any

action within its discretion in response to these proposals. The next element is an

annual commitment to adopt measures through 2006 to achieve specified further

emission reductions in the South Coast. Specific commitments for other regions, such

as the San Joaquin Valley, will be included in future SIPs for those regions. The final

tier is a long-term commitment to identify additional measures by 2007. These

measures would be adopted between 2007 and 2009 in order to reach attainment

targets for the federal one-hour ozone standard in the South Coast, and likely San

Joaquin Valley, by 2010. 

 

14. What kinds of new measures are included in the Proposed Strategy?

The Strategy proposes 19 defined measures that ARB staff would develop, plus

BAR’s planned improvements to the Smog Check program and continuation of DPR’s

existing commitment to reduce volatile emissions from pesticides. The ARB measures

cover on-road vehicles, off-road equipment, marine vessels/ports, fuels and refueling,

and consumer products. Lower emission standards for new engines and consumer
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

ES-7

products are complemented by measures to clean up the existing fleet of mobile

sources. Other measures would reduce gasoline vapor emissions from storage tanks,

service stations, and fuel tanker trucks. Tighter limits on fuel properties are also

proposed. Sections II and III of this document discuss each measure in detail.

15. How would a defined SIP measure become a regulation?

Each defined measure would go through the full public, regulatory development

process. ARB staff’s steps in this process typically include:

• Meetings with the affected industry to better understand the source, its uses, and

its emissions; 

• A rigorous technical evaluation to determine the potential technologies and

techniques to reduce emissions, including the feasibility, effectiveness, cost, and

impacts;

• Public workshops to discuss the technical evaluation and staff’s ideas for

regulatory concepts, as well as participants’ suggestions;

• Release of a staff report with the formal regulatory proposal, including an

assessment of the potential environmental and economic impacts for a 45-day

public comment period; and 

• Consideration by the Board at a public hearing.

16. What is the federal government’s responsibility to reduce emissions from

sources under its control?

Statewide, the emission sources under the exclusive legal or practical control of

the federal government account for over one-quarter of all NOx emissions and almost

two-thirds of all diesel particulate matter. In the South Coast, these sources contribute

over 30 percent of NOx emissions and 60 percent of diesel particulate. Like State and

local agencies, the federal government has a responsibility to further control emissions.

The federal Clean Air Act directs U.S. EPA to continue reducing mobile source

emissions that cause or contribute to air pollution that endangers public health. The

ozone and particulate levels in the South Coast, San Joaquin Valley, and Sacramento

Region clearly meet this test. 

U.S. EPA needs to pursue new requirements for national and international

sources, and complement them with financial incentives to speed turnover of the diesel

fleet to cleaner engines. Federal action is essential to meet health-based air quality

goals in these regions and throughout the State. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

ES-8

17. What emission reductions are needed for ozone attainment in the

South Coast?

The 2003 revision to the Ozone SIP for South Coast shows a need for much

greater emission reductions than the existing 1999 SIP for two reasons. First, improved

mobile estimates raise the emissions starting point in the 1997 baseline. We have a

much better understanding of what vehicles and equipment emit in real life, which is

enabling us to tailor our control strategies accordingly. Despite growth, total emissions

from both on-road vehicles and off-road equipment continue to drop steadily over time

in response to controls. And second, the plan uses a more severe modeling episode

that increases the ROG1 control requirement by 100 tons per day (tpd). 

The 2003 SIP identifies a need to reduce ROG and NOx emissions by a

combined 1,540 tpd between 1997 and 2010 to attain the federal one-hour ozone

standard. Over 960 tpd of these reductions are coming from measures already on the

books – with three-fourths of those reductions from regulations adopted by ARB or other

State agencies. The SIP revision focuses on strategies to reduce emissions by another

352 tpd ROG and 231 tpd NOx in 2010. 

18. What are the proposed near-term State commitments for the South Coast?

ARB staff is proposing that the State commit to additional reductions of 49 tpd

ROG and 37 tpd NOx in South Coast in 2010 through new measures to be adopted

between 2003-2006. These reductions would be achieved from the defined new

statewide measures or alternative measures. Section I.D.1. contains the specific

language for the South Coast, including the proposed annual adoption commitments for

this region. 

 

19. What are the proposed long-term State commitments for the South Coast?

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

such as the South Coast, must rely on evolving technologies to meet attainment goals.

Consistent with section 182(e)(5) of the Act, prior SIPs for South Coast have included a

long-term commitment to achieve the last increment of emission reductions, with the

remaining measures to be defined by 2007. 

After accounting for the anticipated benefits of both adopted and new near-term

defined State and local measures, the 2003 SIP demonstrates a need for another 265

tpd ROG reductions and 181 tpd NOx reductions from long-term measures. This

represents 30 percent of the total reductions needed by 2010. We believe that this gap

can be bridged through a cooperative effort by the local, State and federal agencies

responsible for specific emission sources. This effort should focus on how to most

effectively achieve the additional reductions, considering the availability and cost of

potential controls. As the State agency charged with ensuring California’s SIP

 

1

The South Coast plan uses the term “volatile organic compound,” or “VOC,” rather than ROG.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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compliance, ARB is ultimately responsible for ensuring the necessary measures are

identified by 2007 and the emission reductions are achieved by 2010.

We propose that ARB lead a multi-agency (State, federal, local) effort with the

public to assess potential control concepts for every type of emission source and

develop the full scope of strategies needed to achieve these reductions. In this report,

we identify potential concepts to explore for the long-term measures. We have also

received suggestions from others. In early 2004, ARB staff plans to initiate a public

process to solicit further ideas for development of the long-term measures. 

The South Coast Air Quality Management District (District) assigned

responsibility for long-term emission reductions by agency. The District committed to 31

tpd ROG reductions from long-term measures and assigned the remaining 234 tons of

ROG and all 181 tons of NOx reductions to be achieved by ARB and U.S. EPA. We

view this as a placeholder between now and 2007, when the long-term measures must

be defined. Until that process is complete, the relative long-term emission reduction

split among agencies can’t realistically be defined. Nonetheless, it’s clear that ARB,

U.S. EPA, the District and local government need to obtain additional reductions and we

acknowledge ARB’s responsibility to ensure that measures to achieve those reductions

are ultimately identified and implemented.

We believe that all agencies must actively seek to identify additional costeffective control strategies to achieve the maximum feasible reductions from all source

categories. Part of this evaluation will include a discussion of which agency or agencies

can most effectively obtain the emission reductions in practice. We expect that the

appropriate agency will begin development as soon as practicable. Once all of the

specific long-term measures are identified, the resulting reductions to be achieved by

each agency may be different than envisioned by the District. 

To reconcile the District’s adopted strategy with ARB staff’s recommendations,

we propose that: (1) the Board approve the local air district commitment for 31 tpd

ROG reductions and the targets for the federal government of 18 tpd ROG and 68 tpd

NOx reductions, and (2) the State assume overall responsibility to assure that measures

are identified by 2007 and implemented by 2010 to achieve the remaining 216 tpd ROG

and 113 tpd NOx reductions needed for ozone attainment in the South Coast. 

By 2007, the District and ARB will prepare a revision to the Ozone SIP that

(1) reflects any modifications to the 2010 emission reduction target based on updated

science, and (2) identifies the additional strategies, including the implementing

agencies, needed to achieve the necessary emissions reductions by 2010. 

 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

ES-10

20. What is the backstop if the federal government does not agree to achieve

additional reductions in South Coast by 2010?

If U.S. EPA does not agree to carry out its legal responsibility for new emission

reductions, the District adopted a backstop approach to relax the region’s NOx control

target by a corresponding 68 tpd. Because stringent NOx control is essential for

addressing the health threat from fine particulate pollution, ARB staff is proposing that

the Board allow the federal reductions of 18 tpd ROG and 68 tpd NOx to be added to

the overall State long-term commitment if needed, with no modifications to the control

target at this time. As part of the process of developing the long-term measures, we

continue to use every possible means to press our federal counterparts to act where the

State and local air agencies cannot. 

21. Is the State control strategy for the South Coast commensurate with the

emissions from sources under State jurisdiction?

Yes. The State will continue leading the effort to improve air quality in the South

Coast and statewide, providing a greater share of the emission reductions than

contributed by sources under its jurisdiction. This is essential since these sources are

major contributors to the overall emissions. State actions to date are delivering

three-fourths of all emission reductions to cut ozone in the South Coast. Table ES-1

shows the emissions accounting (between the 1997 baseline and 2010) to demonstrate

attainment of the federal one-hour ozone standard, including the share of combined

ROG and NOx emissions and reductions by jurisdiction. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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ES-11

Table ES-1

Ozone Attainment Demonstration for the South Coast by Jurisdiction

(tons per day in 2010)

ROG NOx

Percent of

Combined

ROG+NOx by

Jurisdiction

1997 Baseline Emissions

 State

 Local 

 Federal

 Total 

835

298

89

1222

758

128

279

1165

67%

18%

15%

Emission Reductions from Adopted Measures

 State

 Local 

 Federal

 Total 

-418

-105

-37

-560

-317

-43

-44

-404

76%

15%

 8%

2010 Baseline Emissions

 State

 Local

 Federal

 Total

417

193

52

662

441

85

235

761

60%

20%

20%

Emission Reductions from New Near-Term Measures

 State 

 District

 Southern California Association of Governments 

 Federal

 Total

-49

-22

-16

0

-87

-37

-5

-8

0

-50

63%

20%

17%

0

Emission Reductions from New Long-Term Measures

 Proposed State Commitment for Multi-Agency Effort

 Local Commitment

 Federal Obligation

 Total

-216*

-31

-18

-265

-113*

0

-68

-181

74%

 7%

19%

2010 Attainment Emissions Target 310 530

*Staff is proposing to increase this commitment to 234 TPD ROG and 181 TPD NOx reductions

if U.S. EPA does not carry out its legal responsibility for new emission reductions.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

ES-12

22. What commitments did the Board approve for the San Joaquin Valley PM10

SIP?

On June 26, 2003, the Air Resources Board approved a State commitment to

develop five of the defined measures in the Proposed Strategy and a commitment to

achieve 10 tpd of NOx reductions and 0.5 tpd of PM10 reductions in the San Joaquin

Valley by 2010. Section I.D.2. describes the Board’s actions, including approval of the

local elements of the PM10 Plan. We have submitted these items to U.S. EPA for

approval as SIP revisions. 

23. What about State commitments for other SIPs?

We anticipate that the San Joaquin Valley will require new emission reduction

measures to achieve further ROG and NOx reductions from State and federal sources

to attain the federal one-hour ozone standard. State commitments beyond those in the

region’s PM10 SIP will be considered as part of the San Joaquin Valley’s Ozone SIP. 

If the commitment to develop the State defined measures is approved by the

Board, we will provide the appropriate language and benefit estimates to other regions

developing attainment SIPs that demonstrate a need for these measures in the

proposed implementation timeframe. As part of this process, ARB will also work with

each region to identify any additional strategies that are needed based on the nature of

the problems in a particular region. 

24. How would the Proposed Strategy affect generation of emission reduction

credits?

Emission reduction credits are generated when sources clean up their pollution

to a greater extent than required. They can then bank, sell, or use these credits to fund

new emissions growth, or as a means to comply with certain control requirements.

State and federal law require emission reduction credits to be surplus to regulations and

air quality plans. Credits may not be used to comply with technology-based

requirements for new and modified sources of air pollution.

Board approval of the Proposed Strategy would provide advance notice of the

source categories ARB intends to regulate in the future, helping to define opportunities

to generate emission reduction credits and the potential life of those credits. Until the

time new, more stringent regulations become effective, emissions from these sources

can be voluntarily reduced beyond current requirements for credits. Once reductions

are required for clean air purposes, further credits can’t be generated. 

For any measures that show a range of possible implementation dates, voluntary

reductions from those sources will be reliably surplus only until the beginning of that

range. If ARB establishes a later implementation date when the Board adopts the

regulation, voluntary reductions may be considered surplus until the actual effective

date of new requirements.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

ES-13

25. How would the Proposed Strategy support environmental justice and

reduce community exposure to air pollution?

The Proposed Strategy would reduce emissions of ozone and PM10 precursors

in communities across California. The Proposed Strategy includes measures that use

cleaner technologies to reduce multiple air pollutants – ROG, NOx, and direct PM10 –

as well as the toxic constituents of those pollutants.

The Proposed Strategy incorporates environmental justice policies in order to

help prioritize our activities to reduce public exposure to air toxics as well as regional

pollutants whose sources are concentrated in some communities. For example, the

series of measures to clean up the existing truck fleet would require the earliest controls

on vehicles that travel through neighborhoods – solid waste collection vehicles and fuel

tanker trucks. While the Proposed Strategy would be implemented statewide to achieve

regional emission reductions, several strategies are especially beneficial to low-income

and minority communities. These include measures to reduce vapor emissions from the

hoses on gasoline tanker trucks and to increase the number of heavy-duty truck

inspections in communities with high truck traffic. In addition, ARB staff will evaluate

potential environmental justice issues in detail during each individual rulemaking. 

26. How would the Proposed Strategy impact the State’s environment?

We expect that implementation of the State defined measures would significantly

decrease ambient ozone and particulate matter levels, with ancillary benefits that cut

carbon monoxide and air toxics. Some of the proposed measures may have an impact

on water quality, water demand, energy demand, hazardous waste, solid waste, and/or

noise. However, in most cases, regulations are in place to prevent environmental

degradation. As specific strategies are developed, we will evaluate the environmental

impacts of each strategy in detail, and work with the appropriate agencies to

recommend any necessary mitigation. For additional information, refer to Section V.

27. How would the Proposed Strategy impact the State’s economy?

ARB staff worked with the University of California, Berkeley to evaluate the

impact of the Proposed Strategy of the State’s economy. The total annual direct costs

associated with all proposed defined State measures are estimated to be approximately

$770 million in 2010. Accounting for indirect costs, these measures would be expected

to reduce California economic output by about $1.5 billion, personal income by about

$1.3 billion, and employment by less than 1,300 jobs. In the context of the State’s

economy, the economic impacts of the measures are small, and are not expected to

impose a noticeable impact on the California economy. The defined State measures

would also bring about significant health, economic, and social benefits to Californians.

These benefits, which are difficult to express solely in economic terms, are not

quantified in this analysis. Prior analyses have concluded that the benefits of

California’s air quality program exceed the costs by a ratio of about 3 to 1. For

additional information, please refer to Section V.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

EXECUTIVE SUMMARY

ES-14

28. What are the opportunities for public comment on the Proposed Strategy?

We invite public comment on the Proposed Strategy at meetings with staff, in

writing prior to Board consideration, and at the Board meeting now scheduled for

September 24-25, 2003. In addition, as ARB develops each SIP measure, it will go

through the full regulatory development process with extensive opportunities for public

comment before the Board considers adoption at a public hearing.

29. What is the staff recommendation for Board action?

We recommend that the Board adopt the entire Proposed Strategy for use in the

South Coast SIP, anticipated use in the upcoming San Joaquin Valley Ozone SIP, and

reflection in future attainment SIPs for other regions. We further recommend adoption

of the specific State emission reduction commitments and long-term strategy proposed

for the South Coast Ozone SIP. 

For information on SIP development across the State, please see our website

http://arb.ca.gov/planning/sip/sip.htm or contact our Air Quality and Transportation

Planning Branch main line at (916) 322-0285. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

-- REVISED -- 

PROPOSED 

2003 STATE AND FEDERAL STRATEGY FOR 

THE CALIFORNIA STATE IMPLEMENTATION PLAN

SECTION I

OVERVIEW OF COMMITMENTS

Release Date: August 25, 2003

Hearing Date: September 24-25, 2003
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

TABLE OF CONTENTS

CHAPTER A. INTRODUCTION................................................................................ I-1

1. State, Local, and Federal Responsibilities .......................................................... I-1

2. 1994 State Implementation Plan......................................................................... I-4

CHAPTER B. NEW STATE DEFINED MEASURES ................................................ I-6

1. Process for Development ................................................................................... I-6

2. Applicability to Multiple Regions.......................................................................... I-7

3. State Defined Measures ..................................................................................... I-7

4. Post-2010 Benefits of State Defined Measures.................................................. I-9

CHAPTER C. APPROACHES FOR LONG-TERM STRATEGY............................. I-10

1. Possible State Approaches............................................................................... I-10

2. Possible Federal Approaches........................................................................... I-11

CHAPTER D. STATE IMPLEMENTATION PLAN COMMITMENTS...................... I-14

1. 2003 South Coast State Implementation Plan.................................................. I-14

2. 2003 San Joaquin Valley Particulate Matter State Implementation Plan.......... I-22

3. Future State Implementation Plans .................................................................. I-25

CHAPTER E. LEGAL AUTHORITY ....................................................................... I-27

1. Overview of Legal Authority .............................................................................. I-27

2. Legal Authority to Adopt State and Federal SIP Measures............................... I-29

APPENDIX I-1. Letter from the Bureau of Automotive Repair on Improving the

Enhanced Smog Check Program 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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Staff Contact List

General SIP Questions:

Andrew Panson apanson@arb.ca.gov (916) 327-0822

Subject Contact Email Phone

South Coast Ozone SIP

Commitment Joe Calavita jcalavit@arb.ca.gov (916) 327-5783

San Joaquin Valley PM10

SIP Commitment Sylvia Morrow smorrow@arb.ca.gov (916) 324-7163

San Joaquin Valley Ozone

SIP development Ravi Ramalingam rramalin@arb.ca.gov (916) 322-2085
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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INTRODUCTION

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CHAPTER A. INTRODUCTION

The Proposed 2003 State and Federal Strategy (Strategy) for the California State

Implementation Plan (SIP) described in this document is intended to protect all

Californians from the harmful effects of air pollution. To improve air quality and meet

our legal obligations under state and federal law, the Air Resources Board (ARB or

Board) will need to continue developing, adopting, and implementing programs to

reduce emissions from all sources under its control – and to encourage other State,

local and federal agencies to do the same. This document describes the next

installment of new strategies for ARB, the State Bureau of Automotive Repair (BAR),

the State Department of Pesticide Regulation (DPR), U.S. Environmental Protection

Agency (U.S. EPA), and other federal agencies to reduce emissions that contribute to

unhealthful ozone and particulate matter 10 microns in diameter and less (PM10) in

California by 2010. The Strategy targets the precursors reactive organic gases (ROG)

and nitrogen oxides (NOx), as well as direct PM10 emissions.

1. State, Local, and Federal Responsibilities

In California, the primary responsibility for controlling air pollution is shared

between the State ARB, 35 local air pollution control and air quality management

districts (air districts), and U.S. EPA. 

a. State Responsibility

ARB is responsible for improving outdoor air quality by controlling emissions from

mobile sources (except where federal law preempts ARB’s authority) and consumer

products, developing fuel specifications, adopting statewide control measures for air

toxics, establishing gasoline vapor recovery standards and certifying vapor recovery

systems, providing technical support to the districts, and overseeing local district

compliance with State and federal law. 

BAR is responsible for the administration of California’s vehicle inspection and

maintenance program, known as “Smog Check.” These programs are meant to help

ensure that in-use vehicles stay clean as they age. Under federal law, certain

nonattainment areas are required to implement Smog Check programs. In addition,

areas with more severe air quality problems must implement “Enhanced” Smog Check

programs which use a treadmill-like device to allow the measurement of NOx emissions,

in addition to the hydrocarbon and carbon monoxide emissions measured in the “Basic”

Smog Check program. 

DPR is the California agency responsible for regulating pesticides for

commercial/structural and agricultural uses. DPR can establish regulations to reduce

both toxic and criteria pollutant emissions from pesticides using the best practicable

control techniques available. Control measures may be implemented by several
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INTRODUCTION

I-3

methods including regulatory actions, local permit conditions, and product substitution

or cancellation. DPR also works with stakeholders to develop effective voluntary

actions to reduce pesticide emissions.

Between 1990 and 2010, actions already taken by the State to require cleaner

passenger vehicles, trucks and buses will cut emissions of ROG by over 70 percent and

NOx by 60 percent in California. Adopted regulations for off-road equipment, including

boats and personal watercraft, will result in over 40 percent reduction in ROG and 30

percent reduction in NOx over the same time period. ARB’s consumer products

program is cutting volatile emissions by over 20 percent from 1990 to 2005, with

emissions growth projected after 2005 unless further controls are established.

b. Local Responsibility

Local air districts are primarily responsible for controlling emissions from

stationary and areawide sources (with the exception of consumer products) through

rules and permitting programs. Examples of stationary and areawide sources include

industrial sources like factories, refineries, power plants, and smelters; commercial

sources like gas stations, dry cleaners, and paint spray booth operations; and

residential sources like fireplaces, water heaters, and house paints. Districts also

inspect and test fuel vapor recovery systems to check that such systems are operating

as certified. In addition, local transportation agencies are responsible for developing

and implementing transportation control measures aimed at reducing vehicle activity

and emissions.

On a statewide basis, adopted air district regulations will reduce stationary

sources emissions of both ROG and NOx by over 40 percent between 1990 and 2010.

ROG emissions from areawide sources (excluding consumer products under State

control) will decline by just under 10 percent, while NOx emissions from these sources

are projected to increase slightly. On a regional basis, the emission trends may vary

considerably from the statewide numbers depending on the stringency of the local

program.

c. Federal Responsibility

Mobile sources under the legal or practical control of the federal government are

an important contributor to California’s air quality problems. These sources include

vehicles registered outside California that travel within the State, new pre-empted farm

equipment and construction equipment, locomotives, marine vessels and aircraft, as

well as the fuels sold outside California for these engines. The federal Clean Air Act

directs U.S. EPA to continue reducing mobile source emissions that cause or contribute

to air pollution that endangers public health. International organizations develop

standards for aircraft and marine vessels that operate outside the United States.

Federal agencies have the lead role in representing the U.S. in the process of

developing international standards. U.S. EPA also has oversight authority for state air

programs as they relate to the federal Clean Air Act. 
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The emissions sources that only the federal government can effectively regulate

are significant contributors to California’s air pollution problems, which continue to

include ozone and particulate levels above the national air quality standards.

Statewide, in 2010, these federal sources will account for over one-quarter of all NOx

emissions and almost two-thirds of diesel particulate matter, a toxic air contaminant.

These sources will also contribute about 6 percent of statewide ROG emissions in 2010. 

On a regional basis, the relative contribution of each source type differs. For

NOx, in the San Joaquin Valley, farm equipment is the most significant federal

contributor at nine percent, while aircraft contribute the least at one percent. In the

South Coast, construction equipment is the top category at 11 percent, while farm

equipment is the lowest at one percent. For diesel particulate matter, farm equipment is

the largest category in the San Joaquin Valley at 25 percent, and construction

equipment dominates in South Coast at 34 percent. 

U.S. EPA and ARB have partnered effectively, sharing technical resources to

develop new emission standards and other approaches to reduce emissions from

source categories under shared authority. For example, parallel regulations will reduce

emissions from new 2007 heavy-duty trucks by 95 percent compared to 1998 levels,

when fully implemented. The national emission standards for these vehicles are vital to

reducing NOx and particulate emissions to meet health-based air quality standards and

reduce the cancer risk from exposure to diesel PM. These benefits are reflected in the

baseline inventory.

Despite continued population and travel growth, ozone-forming emissions from

most sources are declining over time due to the effectiveness of adopted controls. But,

net emissions from marine and aircraft categories are rising. Between 2000 and 2010

in the South Coast, the total NOx emissions from marine vessels are projected to

increase 25 percent because the effects of activity growth are greater than the benefits

of current controls. In contrast, total NOx emissions will drop by 60 percent for

passenger vehicles and 30 percent for trucks over the same period in that region.

Marine and aircraft emissions continue to grow dramatically by 2020 without new

strategies. As State and local agencies continue to make commitments and adopt new

Aircraft

3%

Out-of-State 

Trucks

5%

Trains

3%

Ships

5%

Farm 

Equipment

4%

Construction 

Equipment

8%

Sources Under Federal Authority Contribute

28% of NOx Emissions in California - 2010

All Other State

and Local Sources

Sources Under Federal Authority Contribute

61% of Diesel PM Emissions in California - 2010

Construction

Equipment

28%

Farm

Equipment

10%

Ships

15%

Trains

4%

Out-of-State

Trucks

4%

All Other

State and

Local

Sources
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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I-5

measures, the relative contribution of emissions (especially NOx and direct PM10) from

sources under federal control will increase even faster. 

Agencies at all levels need to deliver new reductions for sources under their

respective jurisdictions. The magnitude of the additional reductions required to attain air

quality standards necessitates that federal government agencies with authority to

control air pollution share responsibility for reaching attainment targets.

2. 1994 State Implementation Plan 

Under the federal Clean Air Act, all

nonattainment areas must submit SIPs that detail how

they plan to improve air quality to meet federal

ambient air quality standards. The 1994 Ozone SIP

described an ambitious 16-year strategy to

dramatically reduce emissions to attain the one-hour

ozone standard in six regions of the State by the

applicable federal deadline. The State and federal

portion of the SIP contained 16 measures directed at

mobile sources under State and federal control,

3 measures focused on consumer products and

aerosol paints, an enhanced vehicle Smog Check

program and a measure to cut volatile emissions from agricultural and structural

pesticides. 

For the South Coast ozone nonattainment area, the 1994 SIP also described a

long-term strategy – allowed under Section 182(e)(5) of the federal Clean Air Act – to

identify and develop additional control measures needed to attain the federal one-hour

ozone standard by the 2010 deadline.

Since 1994, most of the existing near-term SIP measures have been adopted by

the responsible agency, along with additional controls (that had not been identified in

1994) to reduce emissions. The legal commitments described in the 1994 Ozone SIP

applied only to the six regions explicitly covered by that SIP. But, the regulations

adopted to fulfill the commitments in the 1994 SIP are being implemented throughout

California, leading to statewide reductions and improvements in air quality. 

Table I-1 shows our progress implementing the defined State and federal

measures described in the 1994 SIP. The table also lists additional measures adopted,

but not envisioned in the 1994 SIP.

1994 Ozone SIP Regions

(with current attainment deadline)

South Coast (2010)

Southeast Desert (2007)

Ventura County (2005)

Sacramento Region (2005)

San Joaquin Valley (2005*)

San Diego (1999**)

* District has stated its intent to move

to 2010 via voluntary reclassification

** Has been redesignated attainment
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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Table I-1

State and Federal Measures Adopted Since 1994 SIP

Responsible

Agency Adopted

Defined Measures in 1994 Ozone SIP

M1: Light-duty vehicle scrappage ARB 1998

M2: Low Emission Vehicle II program ARB 1998 

M3: Medium-duty vehicles ARB 1995 

M4: Incentives for clean engines (Moyer Program) ARB 1999 

M5: California heavy-duty diesel vehicle standards ARB 1998 

M6: National heavy-duty diesel vehicle standards U.S. EPA 1998 

M7: Heavy-duty vehicle scrappage ARB Replaced with

M17

M17: In-use reductions from heavy-duty vehicles ARB No

M8: Heavy-duty gasoline vehicle standards ARB 1995 

M9: CA heavy-duty off-road diesel engine standards ARB 2000 

M10: National heavy-duty off-road diesel engine stds U.S. EPA 1998 

M11: CA large off-road gas/LPG engine standards ARB 1998 

M12: National large off-road gas/LPG engine stds U.S. EPA 2002 

M13: Marine vessel standards U.S. EPA 1999 

M14: Locomotive engine standards U.S. EPA 1997 

M15: Aircraft standards U.S. EPA No

M16: Marine pleasurecraft standards U.S. EPA 1996 

CP2: Consumer products mid-term measures ARB 1997/1999

CP3: Aerosol paint standards ARB 1995/1998

Enhanced I/M (Smog Check II) BAR 1995 

DPR-1: Emission reductions from pesticides DPR Voluntary

Adopted measures not originally included in 1994 Ozone SIP

Clean fuels measures ARB Multiple

Marine pleasurecraft (reductions beyond M16) ARB 1998/2001

Motorcycle standards ARB 1998 

Urban transit buses ARB 2000 

Enhanced vapor recovery program ARB 2000 

Medium/heavy-duty gasoline standards (beyond M8) ARB 2000 

2007 heavy-duty diesel truck standards (beyond M5

and M6)

ARB/U.S. EPA 2001 

Small off-road engine standard revisions ARB 1998 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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NEW STATE DEFINED MEASURES

I-7

CHAPTER B. NEW STATE DEFINED MEASURES

This chapter describes ARB staff’s revised proposal to update the State

commitments from the 1994 SIP and develop measures to support upcoming SIP

revisions for the South Coast, San Joaquin Valley, and other regions. After briefly

discussing ARB staff’s development process and how these proposals would apply to

multiple regions of the State, we summarize the specific defined measures. Section I.C.

identifies general concepts for a long-term strategy, including federal actions. Specific

commitments for the South Coast and San Joaquin Valley SIPs are described in

Section I.D. 

1. Process for Development

As the Board neared adoption of all the defined measures in the 1994 SIP, ARB

staff began to outline the next generation of State and federal control measures. In

2001, we initiated a public process to identify new emission reduction strategies for

California. We solicited public input on options for reducing ozone, particulate, toxics,

and greenhouse gas pollution across California. We held two sets of workshops

throughout the State to hear ideas from the public and share our concepts. From those

efforts, the staff compiled an extensive list of potential control measures for sources

under State, federal, and local control. Based on our experience developing and

adopting regulatory controls, we assessed the list for technical feasibility, cost, costeffectiveness, feasibility of implementation, and other factors. We passed the concepts

for further reduction from sources under local authority to the air districts for their use in

plans to meet both federal and State air quality standards. 

In January 2003, ARB staff released a draft of this document focused on the

subset of potential measures for sources under State and federal authority that would

help reduce ozone and PM10 by 2010 (the latest existing SIP deadline). In March and

April, we participated in eleven public workshops with the local air districts in the

South Coast and San Joaquin Valley, as well as an ARB technical workshop in both

those regions plus Sacramento, to discuss the draft State and federal SIP strategy. In

May, we issued the Proposed Strategy document to support district actions on the 2003

San Joaquin Valley PM10 SIP and the 2003 South Coast Ozone SIP. On June 26, the

Board approved a subset of the commitments to develop defined measures on a

statewide basis, with specified emission reductions to support the San Joaquin Valley

PM10 SIP. At that meeting, staff proposed and the Board approved a change to the

defined measures that consolidated two measures for large spark-ignition equipment. 

This revision to the Proposed Strategy: reflects the Board’s actions on June 26

to approve the San Joaquin Valley PM10 SIP and on July 24 to adopt low-sulfur

requirements for on-road and off-road diesel fuel, quantifies the long-term strategy for

the South Coast, and incorporates minor updates to the May version. 
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NEW STATE DEFINED MEASURES

I-8

2. Applicability to Multiple Regions

In September, the Board will consider adopting the entire Strategy on a statewide

basis, with specific emission reductions to support the South Coast. Because we will be

asking the Board to commit to statewide measures, the regional benefits could be

reflected in other SIPs without further action or hearing by the ARB. If the Board

approves the proposals, ARB staff will provide the appropriate commitment language

and benefit estimates for other attainment SIPs that need these defined measures in the

2010 timeframe. We will also work with each region to identify any additional strategies

that are needed based on the unique nature of the problems in each particular region.

Although the ARB measures are intended to apply statewide, ARB could choose

to develop a strategy for particular regions. BAR may distinguish application of its

Smog Check improvements based on the Basic and Enhanced area designations

allowed by State law. Further DPR action may be focused on the region(s) with the

greatest need. Federal rulemaking has traditionally been nationwide, but U.S. EPA

might choose to develop a regional strategy (for example, federal incentives for

agricultural equipment in the San Joaquin Valley or a program to cut emissions from

marine vessels and ports along the entire West Coast of the U.S.). 

3. State Defined Measures

Table I-2 summarizes the proposal for the State’s defined measures to be

reflected in upcoming SIPs upon approval by the Board. The table includes 19

near-term defined measures that ARB would develop, that are described in detail in

Sections II and III of this document. Since the Proposed 2003 State and Federal

Strategy would update and replace our existing SIP commitments, Table I-2 also

reflects the revised version of existing SIP measures that other agencies are still in the

process of implementing. 

BAR is improving the Enhanced Smog Check program, including bringing in

heavier vehicles and requiring evaporative emission testing. The Enhanced Smog

Check program in place today, combined with the remaining improvements in Measure

LT/MED-DUTY-2 below, would alter and replace the prior SIP commitment for the

program. For pesticides, we show the emission reduction target in DPR’s existing SIP

measure carried over intact to the new strategy. In the 1994 SIP, DPR committed to

reduce volatile emissions from pesticides in certain areas of the State to 20 percent

below 1990 levels by 2005. The benefits were expected to be achieved through a shift

in the application practices and types of pesticides used. The reductions achieved so

far are incorporated in the baseline inventory for each regional SIP. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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I-9

Table I-2

Proposed State Defined Measures

Strategy

(Agency) Name

LT/MED-DUTY-1

(ARB) 

Replace or Upgrade Emission Control Systems on Existing Passenger Vehicles –

Pilot Program

LT/MED-DUTY-2

(BAR)

Improve Smog Check to Reduce Emissions from Existing Passenger & Cargo

Vehicles

ON-RD HVY DUTY-1

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

ON-RD HVY DUTY-2

(ARB) Capture and Control Vapors from Gasoline Cargo Tankers

ON-RD HVY DUTY-3

(ARB)

Pursue Approaches to Clean Up the Existing and New Truck/Bus Fleet – PM In-Use

Emission Control, Engine Software Upgrade, On-Board Diagnostics, Manufacturers'

In-Use Compliance, Reduced Idling

OFF-RD CI-1

(ARB)

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

(Compression Ignition Engines) – Retrofit Controls

OFF-RD CI-2

(ARB)

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

Detect Excess Emissions (Compression Ignition Engines)

OFF-RD LSI-1

(ARB)

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

Engines 25 hp and Greater)

OFF-RD LSI-2*

(ARB)

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

Emission Standards (Spark-Ignition Engines 25 hp and Greater)

SMALL OFF-RD-1

(ARB)

Set Lower Emission Standards for New Handheld Small Engines and Equipment

(Spark Ignited Engines Under 25 hp such as Weed Trimmers, Leaf Blowers, and

Chainsaws) 

SMALL OFF-RD-2

(ARB)

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

Equipment (Spark Ignited Engines Under 25 hp such as Lawnmowers)

MARINE-1

(ARB)

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

and Fuels

MARINE-2

(ARB)

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

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

Controls

FUEL-1

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

FUEL-2

(ARB) 

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

and Stationary Engines

CONS-1

(ARB) Set New Consumer Products Limits for 2006

CONS-2

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

FVR-1

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

FVR-2

(ARB) Recover Fuel Vapors from Gasoline Dispensing at Marinas

FVR-3

(ARB) Reduce Fuel Permeation Through Gasoline Dispenser Hoses

PEST-1

(DPR) Implement Existing Pesticide Strategy

*Consolidated OFF-RD LSI-2 and OFF-RD LSI-3 from May document. See measure discussion (in

Section II) for additional information.
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I-10

3. Post-2010 Benefits of State Defined Measures

Some of the defined State measures have relatively modest emission reductions

projected for 2010 – the one-hour federal ozone attainment deadline for the

South Coast and the anticipated ozone and PM10 attainment dates for the San Joaquin

Valley. In many cases, particularly for mobile source strategies, the benefits of the

measures increase substantially after 2010 as older engines are replaced with cleaner

models. 

It is critical that local, State, and federal agencies continue to pursue every

available emission reduction, even if some of those benefits will not be fully realized

until post-2010. Urban areas in California will need additional reductions to attain the

next health goals each region is striving to achieve. 

In 1997, U.S. EPA promulgated tighter new federal air quality standards for

eight-hour ozone and PM2.5. Almost half of the counties in California are anticipated to

be nonattainment for the eight-hour ozone standard. Based on preliminary air quality

monitoring data, the South Coast, San Joaquin Valley, and some other urban areas are

also likely to be nonattainment for the federal PM2.5 standards. In addition, virtually all

areas of California do not meet ARB’s health-based ambient air quality standards.

Because a large proportion of the emissions contributing to California’s ozone and fine

particulate problems are from sources under State and federal authority, additional

measures to reduce the impact of cars, trucks and equipment will be critical to meeting

the new federal standards in the post-2010 timeframe. Achieving the more protective

standards will require substantial emission reductions beyond those needed to meet the

one-hour federal ozone standard. 

As the population of California continues to grow, more people will increase the

number of cars, trucks, lawnmowers, heavy equipment, consumer products and other

emission sources being used in the State. Even after areas attain all health-based

standards, ARB and the local districts must continue to push for new emission

reductions simply to offset growth and maintain healthful air. 

For informational purposes only, Sections II and III include the projected benefits

from some defined State measures for 2015 and 2020.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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APPROACHES FOR LONG-TERM STRATEGY

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CHAPTER C. APPROACHES FOR LONG-TERM STRATEGY

The defined State measures will provide sizeable benefits, but not enough to

meet existing SIP attainment needs in the South Coast and San Joaquin Valley. Both

of these areas, and perhaps others, will need significant additional emission reductions

beyond those we will realize through even the maximum potential benefits of the

defined State measures. To meet our current legal obligations under federal law, we

must secure significant emission reductions from long-term measures by 2010.

As part of the public process to develop new emission reduction strategies, ARB

staff also identified approaches that, although promising, face barriers to successful

implementation. Examples include strategies that could not be successful without

significant technological advances, improvements to reduce cost or increase costeffectiveness, or the securing of a dependable stream of financial incentives. 

ARB has a long-standing history of successfully adopting and implementing both

technology-advancing strategies and innovative emission control techniques. By

working closely with the regulated industry and research scientists, ARB staff have been

able to craft regulations that are stringent enough to compel technology development,

yet flexible enough to encourage industry innovations. Since 1998, the State has also

provided over $200 million in funding for innovative incentive programs to speed the

conversion to cleaner trucks, off-road equipment, agricultural irrigation pumps, and

harborcraft; another $50 million (from Proposition 40 funds) is earmarked for the next

two years. These types of programs can reduce NOx and PM10 emissions.

We have included these more speculative long-term approaches because we

know that California will need additional emission reductions to meet our public health

goals. In addition, the federal Clean Air Act allows extreme ozone nonattainment areas,

such as the South Coast, to take credit for long-term technology measures. When the

San Joaquin Valley acts on its intended request for reclassification as an extreme ozone

area, it will also be eligible for these long-term technology provisions. 

Specific information about the SIP commitment for long-term measures in the

South Coast can be found in Section I.D.

1. Possible State Approaches

Table I-3 contains an initial list of possible approaches that ARB staff will pursue

to identify suitable long-term measures. ARB intends to provide opportunities for the

public to offer additional input on this list – and also as we develop the measures.

Further discussion about the long-term strategy for each source category can be found

in Sections II and III, as well as summarized in Section IV. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

APPROACHES FOR LONG-TERM STRATEGY

I-12

Table I-3

Possible State Approaches for Long-Term Measures

In-Use

Light/Medium

Duty Vehicles

■ Provide incentives for voluntary passenger vehicle retirement

Smog Check Explore program expansion to increase benefits, including:

■ Expanded enhanced smog check

■ Opt-in to test-only program 

■ Replace rolling 30-year exemption with exemption of pre1975 vehicles

On-Road Heavy

Duty Vehicles

■ Provide incentives for cleaner trucks and buses, including

school buses 

Off-Road Engines ■ Provide incentives for cleaner off-road vehicles and

equipment

Airports ■ Pursue approaches to reduce emissions from vehicles

traveling to and from airports

Locomotives ■ Pursue approaches to reduce emissions from in-use

locomotives

Diesel Engines ■ Set toxics standard for existing stationary diesel fueled

engines

■ Set toxics standard for existing portable diesel engines

■ Set toxics standard for diesel-fueled refrigeration units

Fuels ■ Set sulfur/ash content limits for diesel engine lubricating oils

■ Support infrastructure for zero emission vehicles – electric,

fuel cell, hydrogen

Consumer

Products

■ Consider future consumer products regulations

Public Education

Programs and

Outreach 

■ Establish clean air labeling program

■ Continue Statewide energy conservation program

■ Consider Statewide public education campaign for air quality

Pesticides ■ Explore approaches to further reduce volatile emissions from

pesticides based on regional need

2. Possible Federal Approaches

Like State and local agencies, the federal government has a responsibility to

further control emissions in response to the contribution from sources under its

jurisdiction. Federal government action is essential to reach the attainment targets

which will require reducing emissions across all sources contributing to the problem.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

APPROACHES FOR LONG-TERM STRATEGY

I-13

U.S. EPA and ARB are continuing to coordinate on future rulemaking, including

three on-going efforts described below. First, U.S. EPA is developing more stringent

emission standards for new off-road diesel equipment based on the transfer of emission

control technology for on-road engines. These benefits will be critical in the post-2010

timeframe to both offset growth and make progress toward the new, more stringent

federal standards. Second, U.S. EPA has proposed to phase in the use of lower sulfur

diesel fuel in off-road applications nationwide. Diesel fuel with a 15 parts per million

sulfur level would support the use of more sophisticated control technology for all types

of off-road diesel engines. Third, U.S. EPA is working in parallel with California to

develop on-board diagnostics and to strengthen manufacturers’ in-use testing to ensure

that new heavy trucks and buses maintain expected emission levels throughout their

useful lives.

We expect that U.S. EPA and other federal agencies will secure further

reductions, and that the federal government may consider a mix of regulatory programs,

incentives or other agreements to achieve reductions. 

As part of the evaluation of long-term strategies under our authority, we also

identified possible federal emission reduction approaches. Accordingly, ARB staff is

including concepts in this document that the federal government could consider. Longterm strategies for new engines in locomotives, ocean-going ships, harbor craft, and

commercial and non-tactical military aircraft are a feasible and effective means to cut

emissions and will be critical to make progress toward all of the national air quality

standards. Because of the extended life of these engines, we believe the long-term

strategy will need to rely heavily on programs to replace existing engines with cleaner

models or to add emission control equipment. Given the volume of equipment in

operation and the public health impact of the emissions, it is important that U.S. EPA

and its federal partners take early action in this regard. 

Table I-4 lists some possible concepts that we urge the federal government to

pursue. This list reflects ARB staff’s assessment of current technology. As technology

advances, this list could be expanded. In addition, the federal government could

provide economic incentives to accelerate clean up of diesel engines, especially those

used in school buses and farm operations. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

APPROACHES FOR LONG-TERM STRATEGY

I-14

Table I-4

Concepts for Federal Action

On-Board Diagnostics for New Truck/Bus Fleet and In-Use Testing for Existing

Truck/Bus Fleet

Lower Emission Standards for New Off-Road Compression Ignition Engines

Low-Sulfur Standards for Diesel Fuel for Off-Road Equipment, Locomotives, and

Marine Vessels

More Stringent Emission Standards for New Harbor Craft and Ocean-Going Ships

Clean Up the Existing Ocean-Going Ship Fleet through Approaches such as Cleaner

Fuels, Incentives for Cleaner Ships, Smoke (Opacity) Limits

Reduce Emissions from Jet Aircraft through Approaches such as More Stringent

Engine Standards, Retrofit Controls, Cleaner Fuel, and Applying Standards to NonTactical Military Aircraft

More Stringent Emission Standards for New and Remanufactured Locomotive

Engines

Incentives to Accelerate Clean Up of Existing Diesel Engines
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

STATE IMPLEMENTATION PLAN COMMITMENTS

I-15

CHAPTER D. STATE IMPLEMENTATION PLAN COMMITMENTS

Under the federal Clean Air Act, regions with air quality that does not meet the

national ambient air quality standards must submit plans describing how they intend to

reduce emissions to improve air quality and meet the health-based standards. 

Based on forecasted inventories of emissions and air quality modeling, local

districts and ARB develop estimates of the maximum amount of emissions a region can

hold without violating ambient air quality standards (referred to as the “carrying

capacity”). Local and State air quality planners compare the carrying capacity with the

expected emission levels in the attainment year with the existing control program (the

baseline inventory) to determine whether additional reductions are necessary to meet

the attainment target. If more reductions are needed, ARB and the air districts must

work with their regulatory partners to identify ways to achieve them. The commitments

to reduce emissions from new measures become part of the SIP, which must be

approved at the local and State level before submittal to U.S. EPA. Once U.S. EPA

approves a SIP, the commitments in that SIP become federally-enforceable.

This Proposed Strategy would update and entirely replace the comprehensive

statewide control strategy contained in the existing 1994 ozone SIP (as modified in

1999 for South Coast). For areas of the State that have not yet achieved the full

amount of emission reductions committed to in the existing SIP, this Proposed Strategy

would retain the existing statewide commitments to achieve all of these emission

reductions. However, the specific statewide measures identified in the existing SIP

would be entirely replaced by the new proposed measures and control strategy to

achieve these emission reductions. For those areas, we will reflect the new Strategy in

the region’s next SIP revision.

This remainder of this section describes specific SIP commitments for two areas

– the South Coast and the San Joaquin Valley. On August 1, the South Coast District

approved a SIP revision that relies on additional emission reductions from State and

federal sources. On June 26, the Air Resources Board approved both State

commitments to obtain additional emission reductions to aid the San Joaquin Valley in

meeting the federal PM10 standard by 2010 and the Valley’s PM10 SIP. This section

also discusses how we intend to handle future SIPs that need new reductions from

emission sources under State and federal control.

1. 2003 South Coast Ozone State Implementation Plan 

For the South Coast, ARB proposes to entirely replace the existing State control

measures in the approved South Coast SIP with the updated and expanded strategy

described here for mobile sources, fuels and fueling infrastructure, consumer products,

and pesticides. This updated strategy would also replace the submitted SIP measure

M17 (In-Use Reductions from Heavy-Duty Vehicles), which U.S. EPA has not approved.

The goals of M17 are included in proposed measure ON-RD HVY-DUTY-3. We have
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

STATE IMPLEMENTATION PLAN COMMITMENTS

I-16

also updated the description of our expectations of federal strategies that should be

pursued.

a. Existing South Coast SIP

Most of the existing near-term SIP measures have been adopted by the

responsible agency, along with additional controls to reduce emissions. The baseline

emission inventory in this document reflects the benefits of State and federal measures

adopted since the 1994 ozone SIP. We track progress on SIP commitments in the

inventory currency of the approved SIP that contained them to provide a consistent

benchmark. Table I-5 shows the rulemaking and emission reduction progress in the

currency of the existing ozone SIP for the South Coast. Since we have also made

many inventory improvements in the intervening years, our current estimates of the

benefits of the adopted measures may differ substantially from those shown in the table

because of changes to the baseline emissions. 

Table I-5

State and Federal Measures Adopted Since 1994 SIP

(tons per day in 2010 based on South Coast inventory from 1997/1999 SIP)

ROG Reductions NOx Reductions

Near-Term Measures Agency Adopted CommitmentAchieved

in 2010

CommitmentAchieved

in 2010

M1: Light-duty vehicle scrappage ARB 1998 0 0

M2: Low Emission Vehicle II program ARB 1998

19

4

17

43

M3: Medium-duty vehicles ARB 1995 Baseline1 - Baseline1 -

M4: Incentives for clean engines (Moyer Program) ARB 1999 0 3

M5: California heavy-duty diesel vehicle standards ARB 1998 5 44

M6: National heavy-duty diesel vehicle standards USEPA 1998 1 11

M7: Heavy-duty vehicle scrappage ARB Replaced

with M17

NA NA

M17: In-use reductions from heavy-duty vehicles ARB No

9

0

62

0

M8: Heavy-duty gasoline vehicle standards ARB 1995 Baseline1 - Baseline1 -

M9: CA heavy-duty off-road diesel engine standards ARB 2000 4 18

M10: National heavy-duty off-road diesel engine stds USEPA 1998

4

6

47

25

M11: CA large off-road gas/LPG engine standards ARB 1998 16 5

M12: National large off-road gas/LPG engine stds USEPA 2002

32

14

17

5

M13: Marine vessel standards USEPA 1999 0 0 15 2

M14: Locomotive engine standards USEPA 1997 0 0 17 17

M15: Aircraft standards USEPA No 3 0 6 0

M16: Marine pleasurecraft standards USEPA 1996 21 17 0 0

CP2: Consumer products mid-term measures ARB 1997/1999 34 15 0 0

CP3: Aerosol paint standards ARB 1995/1998 Baseline1 - - -

Enhanced I/M (Smog Check II) BAR 1995 Baseline1 (6) Baseline1 -

DPR-1: Emission reductions from pesticides DPR Voluntary 1 1 0 0
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

STATE IMPLEMENTATION PLAN COMMITMENTS

I-17

Adopted measures not originally included in SIP

Clean fuels measures ARB Multiple 13 12

Marine pleasurecraft (reductions beyond M16) ARB 1998/2001 7 0

Motorcycle Standards ARB 1998 1 0

Urban transit buses ARB 2000 0 1

Enhanced vapor recovery program ARB 2000 6 0

Medium/heavy-duty gasoline standards (beyond M8) ARB 2000 0 1

2007 heavy-duty diesel truck standards (beyond M5

and M6)

ARB/

USEPA

2001 1 16

Small off-road engine standard revisions ARB 1998 (1) 0

NEAR-TERM TOTAL 125 105 181 203

Long-Term Measures (Section 182(e)(5))

Advanced technology on-road mobile "Black Box" ARB No 37 0 6 -

2

Advanced technology off-road mobile "Black Box" ARB No 18 0 3 -

2

CP4: Long-term measure for consumer products ARB No 43 0 0 0

LONG-TERM TOTAL 98 0 9 -

2

GRAND TOTAL (near-term + long-term) 223 105 190 203

Emission reductions from individual measures may not add to total due to rounding. 

( ) = Emission increase relative to baseline.

1

 Measures M3, M8, CP3, and the Smog Check II program from the 1994 SIP had already been adopted when the SIP

was revised in 1997. The reductions from these measures are included in the 1997 SIP baseline. Although the

Smog Check II program is achieving significant benefits, the emission reductions are less than anticipated in the 1997

SIP as indicated by the negative number under reductions achieved.

2

 The NOx reductions anticipated from the long-term mobile source "Black Box" commitment have already been

achieved from adopted measures.

b. New State Strategy

The proposed State element of the South Coast 2003 SIP has three

components: an annual adoption schedule for emission reductions, defined control

measures, and a long-term strategy commitment. 

The total emission reductions in Table I-6 and the obligation to propose specific

measures in Table I-7 for Board consideration would become enforceable upon

approval by U.S. EPA of the comprehensive control strategy and revised attainment

demonstration in the 2003 South Coast SIP. The commitments for emission reductions

are calculated using ARB’s summer planning inventory for the 2003 South Coast SIP;

progress will be tracked in the same inventory currency to assess compliance. 

i. Commitment to Reduce Emissions via Adoption Schedule

ARB will commit to adopt and implement near-term measures to achieve, at a

minimum, the ROG and NOx emission reductions in tons per day in the South Coast Air

Basin in 2010 shown in Table I-6. Reductions in excess of the minimum commitment

for a given period may be applied to the commitment for subsequent years. ARB may

meet this commitment by adopting one or more of the control measures in Table I-8, by

adopting one or more alternative control measures, or by implementing incentive
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

STATE IMPLEMENTATION PLAN COMMITMENTS

I-18

program(s), so long as the aggregate emission reductions therefrom comply with the

schedule for adoption. 

Table I-6

Proposed State Annual Adoption Commitments for Near-Term Measures

2003 South Coast SIP

 (emission reductions in tons per day in 2010, summer planning inventory)

2003 2004 2005 2006 Total State Reductions from

Near-Term Measures

ROG 10 4 21 14 49

NOx 11 5 21 0 37

ii. Commitment to Propose Defined Control Measures

In addition to the commitment to reduce emissions via an annual adoption

schedule through 2006, the ARB staff also commits to submit to the Board and propose

for adoption the ARB control measures set forth in Table I-7. The staff proposal for

each control measure shall, at a minimum, achieve the estimated emission reductions

set forth in Table I-7 based on the ARB’s summer planning inventory for the 2003 South

Coast SIP. Where a range of estimated emission reductions is set forth for a measure

in Table I-7, the staff proposal shall, at a minimum, achieve the bottom end of the range

of reductions. The Board shall take action thereon on or before the action dates set

forth in Table I-7. Such action by the Board may include any action within its discretion. 

Since the control strategy in this element would replace the approved SIP

strategy in its entirety, we must reflect any existing SIP measures that other State

agencies are still in the process of implementing. Further improvements to the

enhanced vehicle inspection and maintenance program, or Smog Check II, will provide

emission reductions as shown in Table I-7. (Appendix I-1 includes evidence of BAR’s

commitment to finish implementing the Enhanced Smog Check improvements

described in LT/MED-DUTY-2.) This implementation may require additional regulatory

action. Anticipated ROG reductions from pesticide emissions in the South Coast have

been achieved and incorporated into the baseline inventory. The concepts described in

the submitted SIP measure M17 (In-Use Reductions from Heavy-Duty Vehicles) – and

the estimated benefits – have been incorporated into new measure

ON-RD HVY-DUTY-3.

For more information about individual measures, please refer to the descriptions

in Sections II and III.

iii. Commitment to Reduce Emissions via Long-Term Strategy

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

such as the South Coast, must rely on evolving technologies to meet attainment goals. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

STATE IMPLEMENTATION PLAN COMMITMENTS

I-19

Consistent with section 182(e)(5) of the Act, prior SIPs for South Coast have included a

long-term commitment to achieve the last increment of emission reductions, with the

remaining measures to be defined by 2007. 

The approved 1999 South Coast SIP included commitments for long-term State

and federal measures approved under sction 182(e)(5). ARB adopted its defined longterm measures, including the Low Emission Vehicles II and Heavy-Duty Diesel

Off-Road standards earlier than anticipated in the SIP. ARB has already satisfied its

existing long-term commitment to reduce NOx, but not ROG. 

The new SIP shows a need for much greater emission reductions than the 1999

SIP for two reasons: (1) improved mobile estimates raise the emissions starting point in

the 1997 baseline and (2) the Plan uses a more severe modeling episode that lowers

the ROG target by 100 TPD. 

After accounting for the anticipated benefits of both adopted and new near-term

defined State and local measures, the 2003 SIP demonstrates a need for another

265 tpd ROG reductions and 181 tpd NOx reductions from long-term measures. This

represents 30 percent of the total reductions needed by 2010. We believe that this gap

can be bridged through a cooperative effort by the local, State and federal agencies

responsible for specific emission sources. This effort should focus on how to most

effectively achieve the additional reductions, considering the availability and cost of

potential controls. As the State agency charged with ensuring California’s SIP

compliance, ARB is ultimately responsible for ensuring the necessary measures are

identified by 2007 and the emission reductions achieved by 2010.

We propose that ARB lead a multi-agency (State, federal, local) effort with the

public to assess potential control concepts for every type of emission source and

develop the full scope of strategies needed to achieve these reductions. In this report,

we identify potential concepts to explore for the long-term measures. We have also

received suggestions from others. In early 2004, ARB staff plans to initiate a public

process to solicit further ideas for development of the long-term measures. 

The South Coast Air Quality Management District (District) assigned

responsibility for long-term emission reductions by agency. The District committed to

31 tpd ROG reductions from long-term measures and assigned the remaining 234 tons

of ROG and all 181 tons of NOx reductions to be achieved by ARB and U.S. EPA. We

view this as a placeholder between now and 2007, when the long-term measures must

be defined. Until that process is complete, the relative long-term emission reduction

split among agencies can’t realistically be defined. Nonetheless, it’s clear that ARB,

U.S. EPA, the District and local government need to obtain additional reductions and we

acknowledge ARB’s responsibility to ensure that measures to achieve those reductions

are ultimately identified and implemented.

We believe that all agencies must actively seek to identify additional costeffective control strategies to achieve the maximum feasible reductions from all source
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

STATE IMPLEMENTATION PLAN COMMITMENTS

I-20

categories. Part of this evaluation will include a discussion of which agency or agencies

can most effectively obtain the emission reductions in practice. We expect that the

appropriate agency will begin development as soon as practicable. Once all of the

specific long-term measures are identified, the resulting reductions to be achieved by

each agency may be different than envisioned by the District. 

To reconcile the District’s adopted strategy with ARB staff’s recommendations,

we propose that: (1) the Board approve the local air district commitment for 31 tpd

ROG reductions and the targets for the federal government of 18 tpd ROG and 68 tpd

NOx reductions, and (2) the State assume overall responsibility to assure that measures

are identified by 2007 and implemented by 2010 to achieve the remaining 216 tpd ROG

and 113 tpd NOx reductions needed for ozone attainment in the South Coast. 

If U.S. EPA does not agree to carry out its legal responsibility for new emission

reductions, the District adopted a backstop approach to relax the region’s NOx control

target by a corresponding 68 tpd. Because stringent NOx control is essential for

addressing the health threat from fine particulate pollution, ARB staff is proposing that

the Board allow the federal reductions of 18 tpd ROG and 68 tpd NOx to be added to

the overall State long-term commitment if needed, with no modifications to the control

target at this time. As part of the process of developing the long-term measures, we

continue to use every possible means to press our federal counterparts to act where the

State and local air agencies cannot. Table I-7 shows the resulting range of reductions

that would be addressed by the proposed State long-term strategy.

By 2007, the District and ARB will prepare a revision to the Ozone SIP that

(1) reflects any modifications to the 2010 emission reduction target based on updated

science, and (2) identifies the additional strategies, including the implementing

agencies, needed to achieve the necessary emissions reductions by 2010. If the

specific measures developed to satisfy the long-term obligation affect on-road motor

vehicle emissions, we will work with the District and SCAG to revise the transportation

conformity budgets accordingly. 

c. Summary of New State and Federal SIP Element

Table I-7 summarizes the proposed near-term and long-term State commitment

for the South Coast Ozone SIP. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

STATE IMPLEMENTATION PLAN COMMITMENTS

I-21

Table I-7 

Proposed State Strategy

2003 South Coast Ozone SIP

(tons per day in 2010)

Expected Reductions

(South Coast 2010)* Strategy

(Agency) Name FinalAction Date

Implementation

Date ROG NOx

DEFINED STATE MEASURES TO BE DEVELOPED AND PROPOSED

LT/MEDDUTY-1

(ARB)

Replace or Upgrade Emission Control

Systems on Existing Passenger Vehicles

– Pilot Program

2005 2007-2008 0-19 0-18

LT/MEDDUTY-2

(BAR)

Improve Smog Check to Reduce

Emissions from Existing Passenger and

Cargo Vehicles

2002-2005 2002-2006 5.6-5.8 8.0-8.4

ON-RD 

HVY-DUTY-1

(ARB)

Augment Truck and Bus Highway

Inspections with Community-Based

Inspections

2003 2005 0-0.1 0

ON-RD 

HVY-DUTY-2

(ARB)

Capture and Control Vapors from

Gasoline Cargo Tankers 2005 2006-2007 4-5 0

ON-RD 

HVY-DUTY-3

(ARB)

Pursue Approaches to Clean Up the

Existing and New Truck/Bus Fleet 2003-2006 2004-2010 1.4-4.5 8-11

OFF-RD CI-1

(ARB)

Pursue Approaches to Clean Up the

Existing Heavy-Duty Off-Road Equipment

Fleet (Compression Ignition Engines) –

Retrofit Controls

2004-2008 2006-2010 2.3-7.8 NQ

OFF-RD CI-2

(ARB)

Implement Registration and Inspection

Program for Existing Heavy-Duty OffRoad Equipment to Detect Excess

Emissions (Compression Ignition

Engines) 

2006-2009 2010 NQ NQ

OFF-RD 

LSI-1

(ARB)

Set Lower Emission Standards for New

Off-Road Gas Engines (Spark Ignited

Engines 25 hp and Greater)

2004-2005 2007 0 0.8

OFF-RD 

LSI-2**

(ARB)

Clean Up Off-Road Gas Equipment

Through Retrofit Controls and New

Emission Standards (Spark-Ignition

Engines 25 hp and Greater)

2004 2006-2012 0.8-2.0 2-4

SMALL 

OFF-RD-1

(ARB)

Set Lower Emission Standards for New

Handheld Small Engines and Equipment

(Spark Ignited Engines Under 25 hp such

as Weed Trimmers, Leaf Blowers, and

Chainsaws) 

2003 2005 1.9 0.2

SMALL

OFF-RD-2

(ARB)

Set Lower Emission Standards for New

Non-Handheld Small Engines and

Equipment (Spark Ignited Engines Under

25 hp such as Lawnmowers)

2003 2007 6.3-7.4 0.6-1.9

MARINE-1

(ARB)

Pursue Approaches to Clean Up the

Existing Harbor Craft Fleet – Cleaner

Engines and Fuels

2003-2005 2005 0.1 2.7
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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STATE IMPLEMENTATION PLAN COMMITMENTS

I-22

Expected Reductions

(South Coast 2010)* Strategy

(Agency) Name FinalAction Date

Implementation

Date ROG NOx

MARINE-2

(ARB)

Pursue Approaches to Reduce LandBased Port Emissions – Alternative

Fuels, Cleaner Engines, Retrofit Controls,

Electrification, Education Programs,

Operational Controls

2003-2005 2003-2010 0.1 0.1

FUEL-1

(ARB)

Set Additives Standards for Diesel Fuel to

Control Engine Deposits 2006-2009 2006-2010 NQ NQ

FUEL-2

(ARB)

Set Low-Sulfur Standards for Diesel Fuel

for Trucks/Buses, Off-Road Equipment,

and Stationary Engines

2003 2006 Enabling Enabling

CONS-1

(ARB)

Set New Consumer Products Limits for

2006 2003-2004 2006 2.3 0

CONS-2

(ARB)

Set New Consumer Products Limits for

2008-2010 2006-2008 2008-2010 8.5-15 0

FVR-1

(ARB)

Increase Recovery of Fuel Vapors from

Aboveground Storage Tanks 2003 2007 0-0.1 0

FVR-2

(ARB)

Recover Fuel Vapors from Gasoline

Dispensing at Marinas 2006-2009 2006-2010 0-0.1 0

FVR-3

(ARB)

Reduce Fuel Permeation Through

Gasoline Dispenser Hoses 2004 2007 0-0.7 0

PEST-1

(DPR) Implement Existing Pesticide Strategy --- 1996-2010 Baseline N/A

Potential Range for Defined Near-Term State Measures 33.3-71.9 22.4-47.1

Minimum Commitment via Adoption 2003-2006 49 37

PROCESS FOR LONG-TERM STRATEGY

LONG-TERM

STRATEGY

(ARB)

Lead Multi-Agency Effort (State, federal

and local) and Public Process Beginning

in 2004 to Identify and Adopt Long-Term

Measures 

2007-2009 2010 216-234 113-181

* Based on ARB’s summer planning emission inventory for the 2003 South Coast SIP.

** Reflects consolidation of the former OFF-RD LSI-2 and OFF-RD LSI-3 measures published on May 12, 2003. 

Table I-8 shows the resulting 2010 inventory for sources under State and federal

jurisdiction, with implementation of the near-term State measures. The source

categories in this table correspond with the chapters in Sections II and III of this

document, which describe the emissions, existing control program, proposed new nearterm measures, and concepts for long-term strategies.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

STATE IMPLEMENTATION PLAN COMMITMENTS

I-23

Table I-8

Summary of Emissions for Sources Under State and Federal Jurisdiction

2003 South Coast Ozone SIP

(tons per day)

2010 Emissions with

Existing Control

Program

2010 Emissions with

Proposed Near-Term

State Measures Source Category

ROG NOx ROG NOx

Light and Medium-Duty Vehicles1,2 170 164 145-165 138-156

On-Road Heavy-Duty Vehicles2 23 241 18-21 230-233

Off-Road Diesel Engines 14 116 6-12 115

Off-Road Large Spark-Ignition Engines 4 15 1-3 8-10

Small Off-Road Engines 56 7 47-48 5-6

Recreational Vehicles 41 16 41 16

Commercial Marine Vessels 5 58 5 55

Aircraft 5 32 5 32

Locomotives 2 18 2 18

Consumer Products 108 0 91-97 0

Fueling and Vapor Recovery 22 0 16-18 0

Pesticides 2 0 2 0

Total State and Federal Sources 453 668 381-419 618-643

1

Includes on-road motorcycles

2

Emission reductions from SCAG’s Regional Transportation Plan (RTP) are reflected in

the 2010 Emissions with Existing Control Program.

d. Process for State Action

The Air Resources Board will hold a public hearing on September 24-25, 2003 to

consider adoption of ARB staff’s proposal for new State commitments, as well as the

local elements of the South Coast SIP. If adopted by the Board, ARB will submit these

elements to the U.S. EPA for approval as revisions to the California SIP. 

2. 2003 San Joaquin Valley Particulate Matter State Implementation Plan

This section describes the State commitments to achieve further emission

reductions in PM10 and its precursors to help attain the federal PM10 standards in the

San Joaquin Valley (Valley) by 2010. On June 26, 2003, the Air Resources Board held

a public hearing in Fresno and approved a portion of the proposed new State

commitments, as well as the local elements of the San Joaquin Valley PM10 SIP. ARB

has submitted these commitments and the San Joaquin Valley PM10 SIP to the

U.S. EPA for approval as a revision to the California SIP. 

The motor vehicles and equipment under State and federal jurisdiction are

responsible for the majority of Valley air pollution, but are also contributing the majority
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of the emission reductions needed for attainment. Adopted State and federal

regulations for cleaner engines and fuels are driving Valley NOx emissions down by

over 140 tpd, or nearly 40 percent between 1999 and 2010. Emissions of direct

particulate matter from these sources will drop by over 10 percent and ROG by well

over 40 percent in the same timeframe. 

 

To supplement the existing program, ARB staff identified a series of new

measures that will be developed over the next several years to provide additional NOx

and PM10 reductions, consistent with the attainment demonstration needs established

in this SIP. These measures are a subset of the larger strategy ARB staff has proposed

to cut emissions of ROG, NOx, and particulate matter statewide. ARB began

developing the strategy in 2001 with workshops around the State, including the Valley,

to solicit ideas from the public and to share initial concepts for emission reduction

measures. 

The State commitment for this plan has two parts – achieving specific emission

reductions and developing the defined measures for Air Resources Board

consideration.

a. State Commitment for Further Emission Reductions

Table I-9 shows the State commitment to adopt new measures between 2002

and 2008 that reduce emissions by an additional 10 tpd NOx and 0.5 tpd direct PM10 in

the San Joaquin Valley in 2010. ARB may meet this commitment by adopting one or

more of the control measures in Table I-10, by adopting one or more alternative

measures, or by implementing incentive program(s), so long as the total new emission

reductions are achieved. While the legal commitment is to adopt and implement

strategies that achieve the emission reductions by the attainment date, ARB staff is

already working on several of the measures for near-term consideration. 

The new reductions also include the benefits of planned improvements to the

enhanced vehicle inspection and maintenance program, or Smog Check. This

implementation may require additional regulatory action by BAR. 

Table I-9

State Commitment for New Emission Reductions

2003 San Joaquin Valley PM10 SIP

(tons per day in 2010)

State

Commitment

NOx 10

PM10 0.5
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b. State Commitment to Propose Defined Control Measures

In addition to the enforceable commitment to reduce emissions, the ARB staff

also commits to submit to the Board and propose for adoption the ARB control

measures set forth in Table I-10. For LT/MED-DUTY-1, ARB commits to complete the

pilot program and propose a control measure if the approach described proves to be

feasible and effective. 

The specific regulatory proposal for each potential measure will be developed in

an extensive public process that considers the technical feasibility, effectiveness, cost,

and other impacts of the strategy. The Board shall take action on or before the dates

set forth in Table I-10. Such action by the Board may include any action within its

discretion. For informational purposes, Table I-10 shows the benefits that would be

expected from implementation of each defined measure, although the enforceable

commitment is for the total new reductions. 

The defined State measures are described in detail in Section II of this

document. Appendix I-1 includes evidence of BAR’s commitment to finish

implementing the Enhanced Smog Check improvements described in LT/MED-DUTY-2. 
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Table I-10

New State Measures

2003 San Joaquin Valley PM10 SIP

(tons per day in 2010) 

Expected

Reductions*, tpd Strategy

(Agency) Name

ROG PM10 NOx

Action

Dates

Implementation

Dates

LT/MEDDUTY-1

(ARB)

Replace or Upgrade Emission

Control Systems on Existing

Passenger Vehicles – Pilot Program

0-2.4 -- 0-2.7 2005 2007-2008

LT/MEDDUTY-2

(BAR)

Smog Check Improvements 1.5 -- 3 2002-2005 2002-2006

ON-RD 

HVY-DUTY-3

(ARB)

Pursue Approaches to Clean Up the

Existing and New Truck/Bus Fleet – 

PM In-Use Emission Control, Engine

Software Upgrade, On-Board

Diagnostics, Manufacturers' In-Use

Compliance, Reduced Idling

1.5 0.1 4 2003-2006 2004-2010

OFF-RD CI-1

(ARB)

Pursue Approaches to Clean Up the

Existing Heavy-Duty Off-Road

Equipment Fleet (Compression

Ignition Engines) – Retrofit Controls

1.0 0.4 0 2004-2008 2010

OFF-RD 

LSI-2

(ARB)**

Clean Up Off-Road Gas Equipment

Through Retrofit Controls and New

Emission Standards (Spark-Ignition

Engines 25 hp and Greater)

0.2 -- 0.3 2004 2006-2012

Total Emission Reduction Commitment from

New State Measures 0 0.5 10 2002-2008

* Expected reductions from individual defined measures are shown for information only. The State is

proposing commitments for total new reductions in NOx and PM10 emissions only, consistent with the

PM10 attainment demonstration. Commitments for further reductions will be considered in the context

of the upcoming Valley Ozone SIP. 

** Reflects staff’s proposal and Board approval at the June 26, 2003 hearing to consolidate the former

OFF-RD LSI-2 and OFF-RD LSI-3 measures published in the May 12, 2003 Proposed State and

Federal Strategy for the California State Implementation Plan. See Section II for the text of the

consolidated measure.

3. Future State Implementation Plans

As other regions of California develop attainment SIPs that demonstrate a need

for these measures in the proposed implementation timeframe, ARB will provide the

appropriate commitment language and benefit estimates. Because this Proposed

Strategy would update and entirely replace the comprehensive statewide control

strategy contained in the existing 1994 ozone SIP, for areas of the State that have not

yet achieved the full amount of emission reductions committed to in the existing SIP, we

will reflect the new Strategy in the region’s next SIP revision. 

For those areas, this Proposed Strategy would retain the existing statewide

commitments to achieve all of these emission reductions. However, the specific
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statewide measures identified in the existing SIP would be entirely replaced by the new

proposed measures and control strategy to achieve these emission reductions. 

As part of this process, ARB will also work with each region to identify any

additional strategies that are needed based on the nature of the problems in a particular

region. 

We anticipate that the San Joaquin Valley will require new emission reduction

measures to achieve further ROG and NOx reductions from State and federal sources

to attain the federal one-hour ozone standard. Commitments beyond those in the

San Joaquin Valley’s PM10 SIP will be considered as part of the San Joaquin Valley’s

Ozone SIP.
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CHAPTER E. LEGAL AUTHORITY TO ADOPT SIP MEASURES 

1. Overview of Legal Authority

 This chapter discusses the legal authority to adopt the regulations and other

measures that comprise the Proposed 2003 State and Federal Strategy for the

California SIP. This chapter also discusses the appropriate reliance on commitments in

the SIP to pursue measures based on advanced technology. 

Legal authority to regulate sources of air pollution in California is found in both

federal and state law. At the federal level, the Clean Air Act (“the Act” or “CAA”) calls

for a two or three partner endeavor involving federal, state and, where permitted by

state law, local authorities. The Act directs the U.S. EPA to undertake a national effort

to improve air quality. To carry out this directive, U.S. EPA is directed to establish

national ambient air quality standards to protect the public health and welfare (CAA

§109).

The primary tool to be used in the effort to attain national standards is a SIP to be

developed by each state with one or more nonattainment areas. The SIP must provide for

implementation, maintenance, and enforcement of the national standards (CAA

§110(a)(1)). CAA § 110(a)(2)(A) broadly authorizes and directs states to include in their

SIPs: 

"...enforceable emission limitations and other control measures, means, or

techniques (including economic incentives such as fees, marketable permits,

and auctions of emissions rights), as well as schedules and timetables for

compliance, as may be necessary or appropriate to meet the applicable

requirements of the Act."

While the Act requires states to develop SIPs, and clearly intends that they bear

primary responsibility for attaining the national standards (CAA §101(a)(3)), it also

provides U.S. EPA with two significant roles in this process. As a partner in the effort to

attain and maintain the standards, U.S. EPA is authorized and directed to adopt measures

to control emissions from various sources, such as consumer products, motor vehicles,

nonroad engines and vehicles, and aircraft (CAA §§183(e)(3), 202, 213 and 231).

Additionally, U.S. EPA has ultimate authority and responsibility to intervene with direct

federal action if the SIP is inadequate, incomplete or not properly implemented by the state

(CAA §§ 110(c)(1) and 113).

Similarly, California law generally divides responsibility for meeting the

requirements of the Clean Air Act (as well as separate, comprehensive state requirements

related to air quality) between ARB and local air pollution control or air quality

management districts (districts). However, other state or local agencies also have the

authority under state law to regulate certain pollutant-emitting sources or activities. For

example, the State's motor vehicle inspection and maintenance program is primarily the
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responsibility of BAR in the Department of Consumer Affairs, and DPR has primary

authority to regulate the pesticidal use of pesticides. Legal authority for state, district, and

local efforts to improve air quality is contained primarily in Division 26 of the California

Health and Safety Code, although authority for some programs is located elsewhere in the

state codes.2

Pursuant to these codes, the ARB is charged with coordinating state, regional and

local efforts to attain and maintain both state and national ambient air quality standards.

The direct statutory link between the ARB and the mandates of the CAA is found in

§39602 of the Health and Safety Code, which states:

"The state board is designated the air pollution control agency for all

purposes set forth in federal law.

The state board is designated as the state agency responsible for the

preparation of the state implementation plan required by the Clean Air Act

(42 U.S.C., Sec. 7401, et seq.) and, to this end, shall coordinate the

activities of all districts necessary to comply with that act. 

Notwithstanding any other provision of this division, the state

implementation plan shall only include those provisions necessary to meet

the requirements of the Clean Air Act."

In directing the California approach to improving air quality, state law divides control

activities into vehicular and nonvehicular sectors (§§39002 and 40000). The control of

vehicular sources is the responsibility of the ARB, while primary responsibility for

nonvehicular controls falls to the local air districts (§§ 39002, 40000-40002, 40702, 40717;

see also §§ 40400-40540 for provisions specific to the SCAQMD). These authorities have

been used by the local districts to adopt and enforce numerous rules to control air

pollution. In addition, the ARB has comprehensive oversight authority over the districts to

undertake nonvehicular source control activities if any districts fails to perform satisfactorily

(§§39002, 41500, 41502, 41503, 41504, 41505 and 41652).

The Clean Air Act requires that SIP provisions be legally enforceable. A tiered

system of authority for enforcement exists which parallels the authority to develop and

implement the SIP. The ARB has authority to enforce vehicular controls. (See, e.g.,

§§41510, 41511 and 41513, 43012, 43016 and 43017, 43100, 43105, 43106, 43204-

43212 and Vehicle Code §§27156, 38390 and 38391.) Primary responsibility for

nonvehicular enforcement is vested in the local air districts. (See, e.g., §§41510, 41511

and 41513, and 42300 et seq.) However, if the ARB finds that a district is not taking

reasonable action to enforce applicable air pollution control statutes, rules and regulations,

the ARB may, after a public hearing, assume the district's enforcement powers and

enforce these laws (§41505). U.S. EPA has similar authority to assume enforcement

jurisdiction if a state fails to enforce SIP provisions (CAA §113).

 

 

 2 All section references in this chapter are to the Health and Safety Code unless otherwise specified. 
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Within the framework of state and local shared responsibility for air pollution

control, with ultimate air district accountability to the ARB, the ARB has the necessary

statutory authority to assure compliance with the requirements of the Clean Air Act

relating to the attainment of national standards and the rate-of-progress demonstrations.

2. Legal Authority to Adopt State and Federal SIP Measures

State components of this comprehensive SIP revision target mobile sources,

fuels, consumer products, vapor recovery, and pesticides. The legal authority for

implementing the measures in each of these components is described below.

a. Mobile Sources

Motor vehicles and other mobile sources comprise the most significant source of

ozone precursor emissions in the State. The ARB's mobile source section of California's

SIP includes numerous measures to reduce mobile source emissions at the state level

and is a central component of this SIP revision. The measures include reductions to be

realized from actions taken or to be taken at both the federal and state level.

i. Federal Responsibility for National Mobile Source Measures 

If all areas of the State are to demonstrate attainment by the specified deadlines, a

critical part of the overall strategy to reduce mobile source emissions in California must be

U.S. EPA's fulfillment of the Act's promise for regulation of national sources pursuant to

§§202(a)(2)(B), 213 and 231. While U.S. EPA has not yet provided complete information

regarding what regulatory actions will be undertaken pursuant to these authorities, the

ARB anticipates adoption by U.S. EPA of national standards for sources states are

preempted from regulating (i.e., new locomotives and aircraft, and nonroad engines used

in farm and construction equipment under 175 horsepower); and sources the ARB cannot

regulate as effectively as a practical matter (i.e., new heavy-duty diesel trucks registered in

other states, marine vessels, and fuels sold outside of California). As discussed in Section

I.A.1.c of this SIP revision, the projected 2010 emissions from sources under federal

jurisdiction are very significant, and these emissions are expected to grow dramatically by

2020 without new strategies. Under these circumstances, U.S. EPA has an obligation

under the Clean Air Act to promulgate standards for these unregulated or underregulated

national sources. Such measures should be fully creditable in the SIP.

Certainly, U.S. EPA has the authority to adopt standards for national sources in

order to assist states in achieving the national ambient air quality standards (NAAQS).

U.S. EPA's authority derives from a number of provisions of the Clean Air Act which

authorize or require the promulgation of various types of control measures. The scope of

U.S. EPA's authority under many of these provisions is broadly defined. For example,

§202 directs the Administrator of the U.S. EPA to establish emission standards for new

motor vehicles and §231 directs the Administrator to establish aircraft emission standards.

Both of these sections direct the Administrator to promulgate regulations in order to control

emissions:
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"which, in [her] judgement, cause or contribute to air pollution which may

reasonably be anticipated to endanger public health and welfare ..." (CAA

§§202(a) and 231(a)(2)).

Under §213, the Administrator is required to determine whether ozone precursor or

carbon monoxide emissions from nonroad engines or vehicles (other than locomotives)

"cause, or significantly contribute to, air pollution which may reasonably be anticipated to

endanger public health or welfare" and to regulate the sources that in her judgment

"cause, or contribute to, such air pollution." That section also directs the Administrator, by

1995, to adopt emission standards for new locomotives that

 "achieve the greatest degree of emission reduction achievable through the

application of technology which the Administrator determines will be

available for the locomotives or engines to which such standards apply,

giving appropriate consideration to the cost of applying such technology

within the period of time available to manufacturers and to noise, energy and

safety factors associated with the application of such technology." (CAA

§213(a)(5).)

Federal law preempts individual states from adopting emission standards for most

of these sources (§§209 and 233). California has concurrent authority to regulate some

nonroad engines or vehicles including marine vessels, and California can obtain a waiver

of federal preemption to adopt emission standards for other national source categories

(e.g. heavy-duty trucks). However, as a practical matter adoption of separate, Californiaonly standards for national transportation sources (e.g., heavy-duty trucks or marine

vessels) is not a fully effective means of controlling emissions from these sources. 

If California is to adequately protect public health, the essential emission reductions

necessary from these sources must be fully realized through timely promulgation of all

feasible standards for national sources by U.S. EPA under the authorities provided in the

Act. Without such federal control of preempted and national transportation sources,

California simply cannot adequately protect public health because it is not possible to

obtain sufficient emission reductions solely from sources under local and state jurisdiction

to offset uncontrolled or undercontrolled emissions contributed by national sources subject

to federal control. 

National standards for these sources are feasible. These measures are

described in Section I.C.2 and under each source category in Section II of this

submittal. Furthermore, while California may present the worst case and, therefore,

have the greatest need for such standards, there are many other long-term ozone,

PM10, and PM2.5 nonattainment areas in other states that will benefit from the adoption

of such standards. It is not even subject to debate that Congress intended U.S. EPA to

participate in states' efforts to attain national air quality standards by regulating these

sources.
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The very broad language of the Clean Air Act authorizes and directs the

Administrator to establish appropriate standards for national sources in order to

effectively address emissions from these sources in California and other states. Such

standards are necessary and technologically feasible; therefore, U.S. EPA has an

obligation to promulgate these standards without delay. The agency's failure to fully

exercise its national standard-setting authority fully places burdens on California never

envisioned by Congress, and the lack of these emission reductions cannot be made up

by additional state measures because the state and local air districts already must

extract the maximum emission reductions possible from all source categories under

their control.

ii. State Authority for Mobile Source Measures

The ARB has broad authority under State law to regulate motor vehicles and other

mobile sources. These authorities empower the Board to adopt the mobile source

regulations and other control measures identified in Section II of this SIP revision. Health

and Safety Code §43013(a) provides that: 

"The state board may adopt and implement motor vehicle emission

standards, in-use performance standards, and motor vehicle fuel

specifications for the control of air [pollutants] and sources of air

pollution which the state board has found to be necessary, costeffective, and technologically feasible to carry out the purposes of this

division, unless preempted by federal law."

In addition, Health and Safety Code §43018 provides:

"The state board shall endeavor to achieve the maximum degree of

emission reduction possible from vehicular and other mobile sources

in order to accomplish the attainment of the state standards at the

earliest practical date." 

To carry out these directives, the Board is directed to: 

"... adopt and implement emission standards for new motor vehicles

[or new motor vehicle engines] for the control of emissions therefrom,

which standards the state board has found to be necessary and

technologically feasible to carry out the purposes of this division.

Prior to adopting such standards, the state board shall consider the

impact of such standards on the economy of the state, including, but

not limited to, their effect on motor vehicle fuel efficiency." (§43101.)

The Board is also directed by §43013(b) to regulate other categories of mobile

sources: 
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“The state board shall ... adopt standards and regulations for ... off-road or

nonvehicle engine categories, including, but not limited to, off-highway motorcycles,

off-highway vehicles, construction equipment, farm equipment, utility engines,

locomotives, and, to the extent permitted by federal law, marine vessels.”

Each of these sections must be read in the context of Health and Safety Code

39600, which provides that: "The state board shall do such acts as may be necessary for

the proper execution of the powers and duties granted to, and imposed upon, the state

board by this division and by any other provision of law."

Pursuant to these authorities the ARB has adopted the world's most stringent

standards for passenger cars, light-duty trucks and medium-duty vehicles, including the

Low Emission Vehicle/Clean Fuels. (13 Cal. Code Regs. §1960.1.) The ARB has also

adopted regulations establishing standards for heavy-duty vehicles that are at least as

protective as the comparable federal standards applicable elsewhere in the nation. (13

Cal. Code Regs. §1956.8.) In addition, the ARB has adopted regulations establishing

standards for off-road vehicles and engines, including small off-road engines and

equipment (e.g., lawn and garden, small utility engines), off-road recreational vehicles

(e.g., dirt bikes, all-terrain vehicles, golf carts), off-road diesel engines and equipment

(e.g., certain farm and construction equipment, portable generators), off-road gasoline and

LPG engines and equipment (e.g., forklifts, airport ground support equipment), and marine

pleasure craft (e.g., jet skies, recreational boats).

In addition to the emission reductions to be achieved from implementation of

existing ARB mobile source measures, Section II of this SIP revision contains a detailed

description of the new mobile source measures proposed for adoption. This SIP revision

also includes advance technology measures that rely on new or evolving technology.

These measures will be adopted pursuant to CAA 182(e)(5).

b. Smog Check Program

California’s vehicle inspection and maintenance program (commonly referred to

as the “smog check program”) is administered by BAR, which has the sole and

exclusive authority within the State for developing and implementing the program.

(Health and Safety Code § 44002) The overall structure of California’s current smog

check program was established by legislation enacted in 1994 in response to the

requirements of the federal Clean Air Act and U.S. EPA regulations. The laws

governing the implementation and enforcement of the program are found in Health and

Safety Code §44000 et seq. A description of the smog check program and the

proposed improvements to the program can be found in Section II.A of this SIP revision. 

c. Fuels

The ARB has the authority to regulate the content of motor vehicle fuels. This was

recognized by the California Supreme Court in a 1975 decision, Western Oil & Gas Assn.
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v. Orange County Air Pollution Control District (1975), 14 Cal. 3d 411, 418-420, which held

that the authority of the ARB to adopt and implement motor vehicle emission standards

includes the authority to set standards for motor vehicle fuels. 

The ARB’s authority over fuels was reaffirmed and clarified in the California Clean

Air Act of 1988, which added §43018 to the Health and Safety Code and substantially

amended §43013. These sections provide that the ARB has the authority to establish

motor vehicle fuel regulations, and that before adopting and amending such regulations

the ARB must make take certain specified actions and make specified determinations.

Pursuant to §§43013 and 43018, the ARB has adopted a number of fuels regulations. A

description of the existing fuels regulations and the two proposed SIP measures for diesel

fuel are set forth in Section II, Chapter I of this SIP revision. 

One of the two proposed measures for diesel fuel, FUEL-2, would set low-sulfur

standards for diesel fuel used in trucks, buses, off-road equipment, and stationary engines.

Health and Safety Codes §§43013 and 43018 provide the legal authority for the ARB to

regulate motor vehicle fuels, but they do not address the regulation of nonvehicular fuels.

While these sections can therefore be relied upon as legal authority for the FUEL-2

provisions that apply to motor vehicle fuels, they cannot be relied upon for the FUEL-2

provisions that apply to fuel produced for nonvehicular sources. The legal authority to

adopt the nonvehicular provisions of FUEL-2 is instead provided by the California’s toxic

air contaminant control law, the Tanner Act (Health and Safety Code §39650 et seq.). For

substances that have been identified as toxic air contaminants (TACs), the Tanner Act

directs the ARB to adopt air toxic control measures to control TAC emissions from

nonvehicular sources (§§36658 and 39666). “Particulate emissions from diesel-fueled

engines” has been identified by the ARB as a TAC (17 Cal. Code Regs. § 93000). The

Tanner Act thus provides the ARB with the authority to adopt the nonvehicular provisions

of FUEL-2 as an air toxic control measure. 

d. Consumer Products 

The ARB has broad authority under California law to regulate consumer products.

Specifically, Health and Safety Code §41712(b) provides that:

"The state board shall adopt regulations to achieve the maximum feasible

reduction in volatile organic compounds [VOC] emitted by consumer

products, if the state board determines that adequate data exists to establish

both of the following:

(1) The regulations are necessary to attain state and federal ambient

air quality standards. 

(2) The regulations are commercially and technologically feasible and

necessary.” 

(See also Health & Safety Code §39600.)

Pursuant to this authority the ARB has already adopted standards for numerous

categories of consumer products and has achieved significant emission reductions from
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these products. The ARB will continue to develop and adopt measures that limit the VOC

emissions from consumer products. A description of the existing regulations and the

proposed consumer products measures are set forth in Section III, Chapter A of this SIP

revision. 

e. Vapor Recovery 

Health and Safety Code §41954 requires the ARB to adopt procedures and

performance standards for controlling gasoline vapor emissions from gasoline marketing

operations, including transfer and storage operations, to achieve and maintain ambient air

quality standards. This section also authorizes the ARB, in cooperation with districts, to

certify vapor recovery systems that meet the performance standards. Health and Safety

Code 39607(d) requires the ARB to adopt test procedures to determine compliance with

ARB and districts non-vehicular standards. State law (§41954) further requires districts to

use ARB test procedures for determining compliance with performance standards and

specifications established by ARB. 

To comply with these provisions of State law, the ARB has adopted the gasoline

vapor recovery certification and test procedures found in 17 Cal. Code Regs., §§94010 to

94015 and 94101 to 94165. These regulations reference procedures for certifying vapor

recovery systems and test procedures for verifying compliance with performance

standards and specifications.

f. Pesticides 

DPR has broad authorities under state law to control the use of pesticides for the

purposes of protecting human health and the environment, including improving air quality.

(Food & Agriculture Code §§14102, also §§12781, 12824-12828, 12976-12977, 12991-

12995, 12996-12999, 13101 and 13102.) Pursuant to these authorities, in 1994 the DPR

approved a plan to institute and monitor a voluntary VOC reduction program, together with

a commitment to adopt regulations to require reductions in VOC emissions from pesticide

use if the voluntary program does not produce specified reductions in accordance with a

schedule approved as part of the pesticide element of the plan. This plan was submitted

as a SIP revision in 1994 and approved by the U.S. EPA on January 8, 1997. (62 FR

1150, 1169-1170; January 8, 1997). DPR’s approved SIP commitment to control pesticide

emissions is described in Section III.C, of this SIP revision.

g. New Technology Measures for ARB’s Long-Term Strategy

 Like the 1994 and 1999 SIPs for the South Coast Air Basin, this SIP revision

contains a special class of new technology measures necessary to contribute to

attainment in the South Coast. CAA §182 sets out requirements for marginal, moderate,

serious, severe and extreme ozone nonattainment areas, with the requirements for each

level building on the preceding. As the only extreme area in the nation at this time, the

South Coast must meet the most strenuous requirements applicable to areas with less

intense ozone problems, plus all of the requirements of §182(e)(1) through (3). Under
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181(a) of the Act, extreme areas have until 2010 to attain the national ozone standard.

Other regions may choose to voluntarily request reclassification to extreme. The San

Joaquin Valley has stated its intention to do so in parallel with a SIP revision to show

attainment of the federal one-hour ozone standard by 2010. The following discussion

applies to any California nonattainment area classified as extreme. 

To address attainment planning for extreme ozone nonattainment areas,

Congress enacted §182(e)(5) as part of the 1990 CAA amendments. Specifically,

§182(e)(5) provides:

"The Administrator may, in accordance with section 110, approve provisions

of an implementation plan for an Extreme Area which anticipate

development of new control techniques or improvement of existing control

technologies, and an attainment demonstration based on such provisions, if

the State demonstrates to the satisfaction of the Administrator that--

(A) such provisions are not necessary to achieve the incremental

emission reductions required during the first 10 years after the date of the

enactment of the Clean Air Act Amendments of 1990; and 

(B) the State has submitted enforceable commitments to develop and

adopt contingency measures to be implemented as set forth herein if the

anticipated technologies do not achieve planned reductions.

Such contingency measures shall be submitted to the Administrator no later

than 3 years before proposed implementation of the plan provisions and approved

or disapproved by the Administrator in accordance with section 110. The

contingency measures shall be adequate to produce emission reductions sufficient,

in conjunction with other approved plan provisions, to achieve the periodic emission

reductions required by subsection (b)(1) and (c)(2) and attainment by the applicable

dates. If the Administrator determines that an Extreme Area has failed to achieve

an emission reduction requirement set forth in subsection (b)(1) or (c)(2), and that

failure is due in whole or part to an inability to fully implement provisions approved

pursuant to this subsection, the Administrator shall require the State to implement

the contingency measures to the extent necessary to assure compliance with

subsections (b)(1) and (c)(2)."

U.S. EPA approved the new technology measures set forth in the 1994 and 1999

Ozone SIPS (60 FR 43379, 4381 (August 21, 1995); 65 FR 6091, 6093 (February 8,

2000), and further explained its interpretation of §182(e)(5):

“ The 1990 Amendments to the Act added section 182(e)(5), which applies

exclusively to “Extreme ozone areas. This provision authorizes the State to use

conceptual, as yet unadopted measures for its ozone attainment demonstration and

rate-of-progress after the year 2000, if these measures anticipate new or improved

technology or control techniques and are not need to meet the progress

requirements of the first 10 years . . . These measures necessarily are preliminary,

and as such lack both regulations and technical support or even decisions

regarding specific directions and approaches. Complete SIP rule elements are
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

LEGAL AUTHORITY

I-37

dependent upon future years of research projects, analyses of technologies and

associated commercial feasibility, public workshops, and public decisionmaking.”

(60 FR 43381)

California's SIP revisions for extreme areas are expected to rely on §182(e)(5)

measures for substantial emission reductions beyond the year 2009. This reliance was

intended by the Act and affects both the completeness review and the approval process

for this SIP revision. 

Long-term measures that rely on new or evolving technology (including measures

requiring complex analyses and decision-making and coordination among numerous

government agencies) fall within the coverage of §182(e)(5) (57 Fed.Reg. 13498, 13524)

and are approvable as SIP revisions although not in final rule form. Because §182(e)(5)

contemplates the use of yet-to-be-developed technologies or yet-to-be-completed

analyses and decision-making, the rules implementing these measures have not yet been

developed or adopted. For purposes of U.S. EPA's review under §110(k), these

measures should be treated in the same way as fully adopted rules because they are

fully developed in the manner contemplated by the Act at this point in time.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION I – OVERVIEW OF COMMITMENTS

APPENDIX I-1

LETTER FROM THE BUREAU OF AUTOMOTIVE REPAIR ON

IMPROVING THE ENHANCED SMOG CHECK PROGRAM