San Joaquin Valley Unified Air Pollution Control District April 16, 2015

Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard 

# Appendix H

Summary	of	Significant	Comments	and	Responses

2015 Plan for the 1997 PM2.5 Standard SJVUAPCDSan Joaquin Valley Unified Air Pollution Control District April 16, 2015

Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard This page intentionally blank.San Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-1 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard 

### SUMMARY OF SIGNIFICANT COMMENTS MARCH 17, 2015 PROPOSED 2015 PLAN FOR THE 1997 PM2.5

STANDARD

EPA REGION IX COMMENTS:

No comments were received from EPA.

ARB COMMENTS:

No comments were received from ARB.

PUBLIC COMMENTS:

No comments were received from the public.San Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-2 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard 

### SUMMARY OF SIGNIFICANT COMMENTS MARCH 4, 2015 DRAFT 2015 PLAN FOR THE 1997 PM2.5 STANDARD

EPA REGION IX COMMENTS:

No comments were received from EPA.

ARB COMMENTS:

No comments were received from ARB.

PUBLIC COMMENTS: Comments were received from the following:

Agricultural Producer s and Processors (APP) 1

Central California Environment al Justice Network (CCEJN) Central Valley Air Qua lity Coalition (CVAQ) City of Fresno Planning (COF) Dairy Cares (DC) 2

Medical Advocates for Healthy Air (MAHA) Sandra Brock (Brock) Southern California Gas Company (SCGC)

1. COMMENT: Will GAMAQI be updated to refle ct the change in the definitio n of a major source for PM2.5 from 100 t ons per year (tpy) to 70 tpy f or NSR level? (COF)

RESPONSE: The GAMAQI does not refer to any major source definition or

thresholds for NSR. Therefore , revisions to the GAMAQI are not necessary.

1 Agricultural Producers and Proc essers: Comments were submitte d on behalf of the following agricultural agencies, representing agricultural producers and processors throughout the Valley: African Americ an Farmers of California, California Blueberry Association , California Citrus Mutual, Cal ifornia Cotton Ginners Asso ciation, California Cotton Growers Association, Californi a Farm Bureau Federation, Califor nia Fresh Fruit Association, Corcoran Irrigation District, Fresno County Farm Bure au, Kings County Farm Bureau, Kern County Farm Bureau, Milk Producers Council, National Hmong Americ an Farmers, Nisei Farmers League, Stanislaus County Farm Bureau, Tulare County Farm Bureau, Tulare Lake Basin Wa ter Storage District, Tulare L ake Drainage District, Tulare Lake Resource Conservation District, Western Agr icultural Processors Associat ion, Western Growers Association, Delta Lands Reclamation District No. 770, El Rico Reclamation District No. 1618, Homeland Reclamation District No. 780, North

Central Reclamation District No . 2071, South Central Reclamatio n District 2125, Tulare Lak e Reclamation District 749, Peoples Ditch Company, Last Chance Water Ditch Company, Tu lare Lake Canal Company, Southeast Water Company

2 Dairy Cares is a coalition of dairy and milk producer and proc essor organizations and cooperatives including: Western United Dairymen, Calif ornia Dairy Campaign, Milk Produc ers Council, California Farm Bureau Federation,

California Ca ttlemen’s Association, Ca lifornia Dairies, Inc., D airy Farmers of America-Wes tern Area Council, Hilmar Cheese Company, and Land O’Lakes, Inc.San Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-3 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard 2. COMMENT: The District should consider offering incentives to lead agen cies to implement subdivision ordinances that prohibit wood burning of any type and that prohibit the creation of more dirt roads. (Brock)

RESPONSE: The incentive programs operat ed by the District are typically created under specific guidelines t o ensure the emissions reduc tions achieved by these programs are cost-effect ive, enforceable, and quantifiabl e. Incentives for implementing ordinances to prohi bit wood burning or dirt roads would be difficult to quantify and may not be cost-e ffective. Additionally, the D istrict already regulates the installation of w ood burning fireplaces and wood burning heaters through density requirements in R ule 4901, and implements wood burning curtailments during poor air quality episodes through the Check Before You Burn program. Similarly, District R ule 8061 already limits fugitive dust emissions from paved and unpaved roads by implement ing control measures and de sign criteria.

3. COMMENT: The claim that the Valley is NO x-limited is insufficiently su pported.

The District should revise the 2015 PM2.5 Plan to include ammonia controls because ammonia is a major pre cursor for PM2.5. (CVAQ, MAHA)

RESPONSE: The plan control strategy achie ves the emissions necessary to bring the Valley into attainm ent, primarily through PM2.5 and N Ox emissions

reductions. Most areas of the Vall ey will reach attainment wel l before 2020. The District’s incentive programs , public outreac h, and other innov ative strategies will help expedite air qua lity improvements as t his plan is implemen ted. Although the plan shows expeditious attainm ent and includes a comprehensive control strategy for direct P M2.5 emissions and signi ficant PM2.5 precu rsors, the District and ARB explored the effectivene ss of ammonia reductions in red ucing PM2.5

concentrations.

The review of extensive science on this subject and previous mo deling conducted conclude that reducing ammonia emissions is orders of magnitude less effective in reducing PM2.5 concentrations than reducing d irectly emitted

PM2.5 or NOx emissions. There is a relative abundance of ammon ia compared to nitric acid, and the amount of nitric acid drives the ultima te formation of

ammonium nitrate. Because of th is regional surplus in ammonia, even substantial ammonia emissions r eductions yield a relatively sma ll reduction in

nitrate. Reductions in nitrate concentrations of 30% to 50% we re realized through a 50% reduction in NOx. M odeling a 50% reduction in am monia, while unrealistic and not technologically achievable, would only real ize less than 5%

reductions in nitrate concentrations.

Despite the fact that ammonia is an insignificant PM2.5 precurs or in the Valley, the District evaluated cu rrent ammonia controls in Appe ndix C (BACM

and MSM for Stationar y and Area Sources) of this plan. The ana lyses show that the Valley’s ammonia emissions have been significantly reduced through stringent District regulations and current regulations implemen t BACM and MSMSan Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-4 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard in the Valley. The District has already reduced ammonia emissi ons from CAFs, the largest source of ammonia em issions under its jurisdiction, by over 100 tons per day through adoption of Rule 4570 (Confined Animal Faciliti es), the most stringent rule of its kind in t he nation. The District did not find any additional

feasible measures that could si gnificantly reduce ammonia emiss ions.

4. COMMENT: Why has the District not achie ved the same NOx reductions for this plan from stationary sources as A RB has achieved from mobile so urces? (CCEJN)

RESPONSE: The District has implemented a comprehensive regulatory contr ol strategy for over twenty years. Since 1992, the District has a dopted over 600 rules and amendments to implemen t this aggressive control strat egy. Many

current rules are fourth or fi fth generation, meaning that they have been revised

and emission limits hav e been lowered, as new emission control technology has

become available and cost-effect ive. As a result of these exte nsive efforts and significant investments from Va lley businesses, the emissions i n the Valley from stationary sources have been reduced by 80% or more.

ARB and EPA have regulat ory authority over mobile sources of em issions in the Valley. As demonstrated in Figur es 2-4 and 2-5 (see Chapter 2) the majority of the remaining emissions in the Valley are generated by mobile s ources. In part due to the success of prohibitory r ule efforts implemented by t he District on stationary and area sources; in fact, mobile sources are now re sponsible for 85%

of NOx emissions in the Va lley (see Appendix B).

5. COMMENT: Explain the difference between B est Available Control Measure s (BACM) and Lowest Achievable Emi ssions Rate (LAER), and whether it is possible to implement LAER i nstead of BACM. (CCEJN)

RESPONSE: EPA defines BACM as the ma ximum degree of emissions

reductions achievable from a sour ce or source category, which i s determined on a case-by-case basis consider ing energy, economic, and environm ental impacts. LAER, on the other hand, is the most stringent emissions contro l that is technologically feasib le and does not take into consideration a ny economic impacts or rather the cost effect iveness of a potential control measure.

Within Appendix C of this plan , the District has examined every source category in the Valley for any potential opportunities for additional em issions reductions, which included reviewing LAER l evels of control. However, sinc e EPA’s

definitions for BACM and Most Str ingent Measures (MSM) state th at air districts

should account for the economic feasibility of a ll potential BA CM or MSM, the

District evaluated the cost effe ctiveness (in dollars per year, per ton of emissions reduced per year) of all technolog ically feasible control measu res to determine ifSan Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-5 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard there were additional measures not already implemented in the D istrict that qualify as BACM and/or MSM.

Aside from this plann ing process, the District also evaluates L AER through the new source review (NSR) process , per District Rule 2201 (New an d Modified Stationary Source Review Rule) . Anytime there is a new or modi fied stationary source of air pollution, the res pective source is required to i mplement Best Available Control Technology (BA CT) levels of control for their new or modified equipment. To determine what qua lifies as BACT, the District e xamines all

LAER controls and then evaluates the cost effectiveness of the potential measure to see if it qualifies as BACT for that particular sour ce.

Given the high cost effectivene ss of BACT/BACM controls, most a ir districts only enforce such stringent and costly requirements on new sources. However, due to the District’s unique air qua lity challenges, the District h as enforced

BACT/BACM levels of emissions c ontrols on numerous retrofitted sources for years through these stringent pe rmitting provisions and multi-g enerational rules.

6. COMMENT: Provide more detail on the co mposition of ammonium, sodium, nitrate, etc., specifically for confined animal facilities (CAF s). Also, there are incentives for agricultural equi pment, but when are agricultura l equipment rules coming? (CVAQ)

RESPONSE: Information on the general compos ition of PM2.5 in the San Joaquin Valley can be found in Chapter 3 of the 2015 Plan for the 1997 PM2.5

Standard . Figure 3-2 (page 3-12) of the plan shows the average annual compositions of PM2.5 in Fresno and Bakersfield. Recently, res earch has been

undertaken to better characteri ze PM emissions from CAFs. The research

available has indicated that the majority of directly emitted P M from CAFs is larger than PM2.5. In addition , most of directly emitted PM fr om CAFs is expected to occur in the dry su mmer months, rather than the win ter months when the San Joaquin Valley has the highest concentrations of PM2.5.

As discussed in the plan, ammonium nitrate and ammonium sulfate are not directly emitted, but rather a re formed through secondary atmos pheric reactions between precursors. As discuss ed in Chapter 2, Section 2.6 of the plan, because the formation of secondary ammonia particulate is limit ed by other precursors, ammonia is not a si gnificant precursor to PM2.5 val ues in the San Joaquin Valley. Although ammonia is not a significant precurso r to PM2.5 values in the Valley, the District has adopted stringent regulations t hat have reduced ammonia emissions (e.g. Rule 4565 - Biosolids, Animal Manure, a nd Poultry Litter Operations, Rule 4566 - Or ganic Material Composting, and Rule 4570 - and

Confined Animal Facilities - Rule 4570). The District has alre ady reduced ammonia emissions from CAFs, t he largest source of ammonia emis sions under its jurisdiction, by over 100 tons per day through adoption of Rule 4570 (Confined Animal Facilities), the most str ingent rule of its kind in the nation. PleaseSan Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-6 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard reference Section C.41 (Ammonia Controls) in Appendix C of this plan for

additional information.

Lastly, ARB is currently undertaki ng a rule making process to r egulate agricultural equipment, and the Dis trict is supportive of that effort.

7. COMMENT: CNG engines are available th at achieve greater emission

reductions than the 2010 truck standards. The District should consider requiring greater reductions than those required in the 2010 truck standa rds by requiring or incentivizing the use of natural gas trucks. (SCG)

RESPONSE: The District is actively encour aging the continued developmen t

and certification of cleaner nat ural gas engines. Through the Technology Advancement Program, the Distr ict is partneri ng with an engine manufacturer for demonstration and durability test ing of an advanced natural gas engine to be certified to an optional NOx standard which is 90% cleaner than the current engine standard. Additionally, the program is demonstrating na tural gas/electric hybrid projects in both class 4 and class 7 trucks, highlightin g the benefit of natural gas in those categorie s. The District is also consider ing additional

methods to incentivize and encour age natural gas vehicles in th e Valley.

8. COMMENT: How do wildfires and controlled burns affect PM2.5 levels and

attainment of the federal standar ds? Also, what is the Distric t’s involvement with agencies such as Bureaus of Land M anagement for large controlle d burning?

The District should do more outreac h to rural areas for control led burns. (COF)

RESPONSE: With the Valley being surroun ded by mountain ranges, wildfire s have the potential to have a sign ificant impact on PM2.5 levels and subsequently affect the region’s ability to r each attainment of the federal PM2.5 standards. However, wildfires are consider ed “Exceptional Events” by EPA a nd outside of

the control of the District. The recorded PM2.5 levels affecte d by these

emissions can be removed from t he regulatory data set used to d etermine compliance with the PM 2.5 standards. This exceptional event pr ocess requires

that extensive documentation be provided to EPA to support the event’s impact on the recorded values, showing t hat the high values would not have occurred

“but for” the added emissions from the wildfire event.

The emissions from controlled burn s constitute a significantly smaller PM2.5 fraction compared to wildfires , and usually have minimal and te mporary impact on any nearby air quality monito rs, if any. Controlled burns a lso play a critical role in reducing the fuel loadi ng within these mountain ranges and help prevent catastrophic wildfires from pot entially occurring. Controlled burning activities are regulated by the District under R ule 4106 (Prescribed Burning a nd Hazard Reduction Burning).San Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-7 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard The District works in close coor dination with t he National Fore st Service, the National Park Service, and other Land Management Agencies (LMAs ) to strategically approve controll ed burns only on days when air qu ality and atmospheric dispersion condition s are favorable. The District and LMAs also work together to minimize the pot ential smoke impacts to nearby communities from these burning activities. T hrough partnership with the Di strict, the LMAs ensure that nearby communities a re aware when a controlled burn is being planned for the area through the posting of information in publ ic spaces, local publications, town hall meetings, electronic media, etc. The i nformation shared assists the residents to plan appr opriately while considering t he potential temporary air quality impacts i n the area. The District will c ontinue to work closely with the LMAs in maki ng sure that the public is made aw are of future controlled burn projects in adv ance of their planned ignition.

9. COMMENT: We support the District’s priori tization of control strategie s that will result in the greatest human health benefits. We appreciate th e District’s willingness to consider incentives for conservation tillage. W e also support more natural gas trucks, especially if running on renewable natural gas such as can be generated with dairy manure. (DC)

RESPONSE: The District appreciates the co mments above and will continue to evaluate potential control stra tegies under the District’s Heal th Risk Reduction Strategy.

The District also supports effo rts to reduce emissions through innovative approaches through its technology advancement program and throu gh on-going

research efforts.

10. COMMENT: Rule 9510 (Indirect Source Rev iew) was last updated in 2005;

additional emissions could be redu ced by expanding the rule’s a pplicability. The

District should also eliminate t he option for businesses to pay fees in lieu of mitigation measures and should require them to meet a minimum e missions level before paying fees. In additi on, the District should increase the emissions reductions required for projects and add PM2.5 em issions limits . (CVAQ)

RESPONSE: Rule 9510 does not allow all pr oject proponents to pay fees i n lieu of mitigation requirements. The rule recognizes that while pro ject design and CEQA mitigation requ irements are land-use decisions that are ou tside the scope of the District’s direct regulator y authority, it is possible t hrough the use of increased fees to encourage better project design, leading to l ower emissions.

In regards to the emissions reduc tions required for projects, R ule 9510 currently requires that all emissions above certain thresholds be mitigat ed through the

District’s emission reduction in centive grant pr ograms via the payment of fees to

the District. Those fees are est ablished at levels that the Di strict demonstrates,San Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-8 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard on an annual basis, to be sufficien t to mitigate the full targe ted emissions for projects subject to the rule.

Lastly, adding a specific PM2.5 component to the rule would not result in reduced

PM2.5 emissions because the rule already targets PM10 emissions . PM2.5 is a subset of PM10, and for combusti on sources, PM10 is nearly 100% PM2.5. In fact, the sources of emissions reductions obtained through the District’s incentive programs are nearly 100% combustion sources, including both mob ile and stationary sources. Therefore, b y targeting PM10 sources, Rule 9510 also effectively addresses PM2.5 emissions.

11. COMMENT: The District should revise Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters) to elimi nate wood burning when the Valley is expected to

exceed the 2006 PM2.5 NAAQS of 35 μg/m 3 . (CVAQ)

RESPONSE: Based on the latest amendments (September 2014), Rule 4901 is the most stringent wood burning curtailment rule in the nation. Residential woodburning with unregistered devices are no longer allowed when an area’s

forecasted PM2.5 concentration is expected to be greater than o r equal to 20 μg/m 3 which comprise over 95% of wood burning emissions. This thres hold is lower compared to past years when it was set at 30 μg/m 3 . As such, this

threshold is much lower than the 2006 and 2012 federal 24-hour average PM2.5 standard of 35 μg/m 3 . Allowing the cleanest wood burning heaters to be used between 20 and 65 μg/m 3 provides significant motivat ion to Valley residents for transitioning away from older h igher polluting devices to the c leanest wood burning heaters. A re gistered wood burning heater pollutes at least twenty times less than a wood burning fireplac e; therefore, encouraging this transition reduces emissions beyond those that could be accomplished by only reduc ing the curtailment threshold to 20 μg/m 3 . The latest amendments to Rule 4901 will

achieve an estimated reduction o f 5.1 tons per day of PM2.5 emi ssions.

12. COMMENT: The District should implement fl eet rules for publicly-owned vehicles in the Valley. The Dis trict’s current fleet rule appl ies to school buses, but the SCAQMD fleet rules apply to buses, light-, medium-, and heavy-duty public fleet vehicles, airport gr ound transportation such as ta xis and shuttles, and street sweepers. (CVAQ)

RESPONSE: Advancing the turnover of flee ts is a critical component of r educing emissions. ARB has adopted flee t rules that have greatly reduc ed emissions from public fleet vehicles, and hav e superseded efforts at loca l levels to reduce emissions from those same fleets. The District also operates s ome of the most effective and robust vehicle gran t programs in the nation, incl uding a first of its kind rule to quantify emissions reductions from incentive progr ams for SIP creditability. The District will continue to look into opportu nities for new fleetSan Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-9 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard rules, but at this time the Distr ict advances the turnover of f leets through the use

of incentive funds.

13. COMMENT: ARB should develop enforceable agricultural equipment regulat ions as soon as possible to accelera te attainment of the 1997 PM2.5 NAAQS in the Valley. (CVAQ)

RESPONSE: The District recognizes the need for additional emissions reductions from mobile agricultu ral equipment to address not on ly the 1997 PM2.5 NAAQS, but the newer, mor e stringent federal 2006 PM2.5 N AAQS and 2012 PM2.5 NAAQS. As such, the Dis trict will continue to work with ARB and the agricultural industry to dev elop regulations for mobile agr icultural equipment (under ARB’s regulatory authority) to increase the use of the c leanest technologies as they become avai lable in the San Joaquin Valley

.

14. COMMENT: The District Conservation Managemen t Practices rule (Rule 455 0) should be updated to reflect current practices, practices that overlap with other agency regulations should not be elective or be used to evidenc e rule compliance. Menu items regarding surface control in all agricu ltural operations

should be uniform and consolidated into a single section applic able to all operations regardless of category (crops, cows, and poultry). The number of options a regulated entity can choose to show compliance must b e increased significantly. Many of these pr actices are BACM and should no longer be available as options. (CVAQ)

RESPONSE: The District evaluates the e ffectiveness of Control Managemen t Practices (CMPs) on a regular basis, as illustrated on the Dist rict’s web page under Requirements for Agricultur al Operations. While Rule 455 0 has been successful in reducing both PM10 and PM2.5 emissions, recent st udies have

indicated that the PM2.5 fracti on of emissions makes up a small portion of the total particulate emissions from a gricultural operations. Addi tionally, particulate emissions from agricultural operat ions are geologic in nature. These geologic particulate emissions make up a relatively small portion of the overall PM2.5 concentrations during the winte r season and have relatively low toxicity when compared to the organic carbon fr action of PM2.5 and to re-susp ended road dust. Given the relatively low c ontribution that emissions fro m this category make to the Valley’s PM2.5 conc entrations and current stringent requirements under Rule 4550, the District has not identified any additional rule amendment opportunities for further emissi on reductions from source categ ories subject to CMP requirements to include in this plan. As demonstrated abov e, Rule 4550 currently has in place the mos t stringent measures feasible to implement in the Valley and therefore meets or exceeds bot h BACM and MSM require ments for this source category.San Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-10 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard However, the District is leavi ng no stone unturned and is commi tting to

reevaluate Rule 4550 for all f easible opportunities for additio nal emissions reductions, if any, in the contex t of the upcoming PM2.5 plans in 2016/2017.

15. COMMENT: Emission reductions that the Dis trict intends to use from inc entive programs under Rule 9610 are no t SIP-creditable. (CVAQ)

RESPONSE: Incentive programs are an int egral part of the emission reduc tion

efforts of the District. These programs have invested over $1 billion in public/private funding towards in centive-based emission reducti on projects that have reduced over 100,000 tons o f NOx, VOC, and PM2.5 emissions since 1992. District incentive programs hav e been modeled on effective stat e incentive programs like the Carl Moyer Pro gram. Enforceability has alread y been built into the District incentive programs through requirements that inclu de pre and post project equipment inspections, m onitoring, and reporting. Rule 9610 provides

the mechanism for the District to ta ke credit for these surplus , quantifiable, and

enforceable emissions reducti ons. EPA approved Rule 9610 on Fe bruary 26, 2015, finding that incentive-based emissions reductions are ful ly SIP-creditable.

16. COMMENT: The District should improve its public outreach process. (CV AQ)

RESPONSE: The District appreciates the re commendations for further outr each opportunities. The 2015 PM2.5 Plan was prepared through an involved public process that provided multiple opportunities for the general pu blic and interested stakeholders to offer suggestions and comments for improving an d strengthening the plan. The District has worke d closely with these various s takeholders, including its partner agencies ARB and EPA, envir onmental and c ommunity advocacy groups, and business repr esentatives to share informat ion regarding the plan, and to receive comments and suggestions.

Numerous opportunities were pr ovided for public input during Di strict Governing Board public hearings, Citizen’s Ad visory Committee public meet ings and

Environmental Justice Adviso ry Group public meetings. The Dist rict also met with interested advocacy and indu stry representatives throughou t the plan development process to address s pecific questions and comments, and solicit further suggestions for control strategies. The District held a public workshop for this plan on March 4, 2015 at t he District’s offices in Modesto , Fresno, and Bakersfield and by webcast, with many participants attending an d providing feedback. The District also posted the Proposed 2015 PM2.5 Plan on the District’s webpage on March 17, 2015 for a 30-day public notici ng period.

17. COMMENT: PM2.5 geologic emi ssions from agricultural operations are insignificant and attempts to cont rol these emissions are unwar ranted. There continues to be artificially hi gh emissions of PM2.5 attributed to “farmingSan Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-11 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard operations”. There has been signif icant research on PM2.5 emis sions from agricultural sources, includi ng studies conducted in the Valley , which should be incorporated wherever and whenev er possible. Results of the mu lti-year study of cotton gin emissions under the US DA indicate only 2.4% of total suspended particulate are PM2.5. Emissi ons from almond harvesting operat ions report PM2.5 emissions to be in a range o f 1.1% to 1.6%. Additionally , ARB determined in 1995 that “geologica l material” made up less than 1% of the total source contributions. (APP, DC)

RESPONSE: As described further in Appendix C of this plan, under Rule 455 0 (Conservation Management Practices ), the PM2.5 fraction of emis sions makes up a small portion of the total particulate emissions from agri cultural operations. Additionally, particulate emission s from agricultural operation s are geologic in nature, make up a relatively sma ll portion of the overall PM2.5 concentrations during the winter season, and have relatively low toxicity rela tive to the organic

carbon fraction of PM2.5 and to re-suspended road dust. 3 Accordingly, particulate emissions from agricul tural sources do not play a s ignificant role with regard to attainment of the PM 2.5 standards addressed by this p lan, and Rule 4550 is primarily a PM10 reduction strategy.

Given the relatively low contri bution that emissions from this category make to the Valley’s PM2.5 concentrati ons and current stringent require ments under Rule 4550, the District has not identifi ed any additional rule amend ment opportunities

for further emission reductions fr om source categories subject to CMP requirements to include in this plan. It is also questionable that further opportunities for reducing PM 2.5 emissions exist.

However, in developing plans fo r the new and ex isting National Ambient Air Quality Standards, the Distric t will leave no stone unturned to evaluate and identify further opportunities to advance attainment of the eve r-tightening National Ambient Air Quality Standards. Any opportunities iden tified to reduce emissions towards meeting thes e tougher standards may also help expedite

attainment with the 1997 PM2.5 standard addressed by this plan. In developing these plans, the Distric t will reevaluate all of its existing r egulations and will explore all potential measures fo r all source categories. As s uch, the District

commits to evaluate all feasible opportunities for additional e missions reductions from Rule 4550, if any.

18. COMMENT: Windblown dust is not an issue fo r the Valley, especially for PM2.5. According to USDA documents, w ind erosion occurs when wind spee d reaches 13 mph, which rarely occurs i n the Valley and when it does occu r, it does not

lead to exceedances of the federal standard. It has been found that only a fraction of suspendable particles are transportable particles a nd in the absence

3 Rogge, W. F., Hildemann, L. M., Maz urek, M. A., C ass, G. R. an d Simoneit, B. R. T. Sources of Fine Organic Aerosol—3. Road Dust, Tire Debris, and Organometallic Brake Lining Dust—Roads as Sources and Sinks

. Environmental Science & Technology 27(9), 1892-1904. 1993.San Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-12 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard of violent winds there is littl e, if any, residual or continuin g source of energy to

sustain vertical motion and tr ansport of these emissions. The District must not require additional cont rol measures of agricultural sources loc ated in rural areas. (APP)

RESPONSE: The Valley experiences wind-blow n dust events from time to time typically during the spring and fall seasons when weather distu rbances are most

common. These events are less likely to occur during the long stagnation periods of the summer and winter. When soil conditions are dry , strong wind events often entrain coarse parti culate matter into the atmosph ere, carrying the pollution long distances acro ss the Valley. This phenomenon ha s the potential to create higher concentrations of P M10 in its path of impact.

Although these events primarily cause higher PM10 concentration s, there are

rare instances where PM2.5 conc entrations become elevated. In addition to the rarity of elevated PM2.5 concent rations, the PM2.5 values recor ded during the strong stagnation periods of the winter season are usually much higher than those recorded during wind events. Because of this, the Valley ’s PM2.5 design values are driven primarily by high winter-time concentrations, mostly due to organic carbon and the secondary fo rmation of ammonium nitrate. Comparatively, the geologic com ponent of the Valley’s peak PM2. 5 concentrations is only a fracti on of the mass fo rmed through se condary processes and other sources. As a result, the wind events expe rienced in the Valley are not a significant c ontributor to the PM2.5 attainmen t challenges for the region, and placing further cont rols on this source would not m ake a substantial

difference in the District’ s PM2.5 design values.

19. COMMENT: We appreciate the District’s incl usion of incentive programs as a viable emissions reduction strate gy for NOx and PM2.5. We ask the District to include specific references to the USDA-NRCS and their Californ ia Air Quality
EQIP Fund Pool for Particulate Ma tter Reduction for their incen tives to reduce PM emissions. We support additional funding for agricultural t rucks for early adoption and we commit to worki ng with the District to seek out additional funds and help promote an inc entive based program for agricultural tr ucks. (APP)

RESPONSE: The District appreciates the va st economic resources dedicate d
from USDA-NRCS and EQIP to incent ivize zero and near-zero emitt ing technologies in the Valley. Chapt er 7 (Attainment Strategy) in cludes a

discussion of the collaboration between EPA, ARB, USDA-NRCS, an d the District to adopt Rule 9610 (State Implementation Credit for Em ission Reductions Generated Through Incentive Pr ograms) on June 20, 2013 and effe ctively

establish the administrative me chanism through which the Distri ct and ARB can

take SIP credit for emissions redu ced through these types of in centives previously provided by USDA-NRCS.San Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-13 Appendix H: Summary of Significant Comments and Responses

2015 Plan for the 1997 PM2.5 Standard In addition, the District supports additional funding to help i ncentivize the replacement of agricultural trucks in the Valley. The District has included a commitment to fund $10 million dolla rs for the replacement of h eavy duty trucks in the Valley between 2016 and 2 020, and ARB has also committed to do their part by committing to p rovide additional reductions in emission s for sources

under their control. ARB staff will propose a commitment on ac tions for key truck sectors in the Valley to better ensure benefits from the Truck and Bus regulation and pursue opportunities for the r eplacement of tr ucks certifie d to the State’s optional low-NOx st andard. The District will continue to work closely with ARB

on this issue.San Joaquin Valley Unified Air Pollution Control District April 16, 2015

H-14 Appendix H: Summary of Significant Comments and Responses

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