San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard 

# Chapter 6

Demonstration	of	Federal	Requirements

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

Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-1 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard 

### Chapter 6: Demonstration of Federal Requirements

The federal Clean Air Act (CAA) , Title 1, Part D Subpart 1 (Sub part 1) and CAA Title 1, Part D Subpart 4 (Subpart 4) requi res California to submit docu mentation to EPA that is specific to the San Joaquin Va lley (Valley) to address the 1997 National Ambient Air Quality Standards (NAAQ S) for PM2.5. This 2015 Plan for the 1997 PM2.5 Standard ( 2015 PM2.5 Plan) fulfills requirements for the Vall ey as an area classified as a Serious nonattainment area under Subpart 4 with an additional request f or an extension of the attainment deadline. Attainmen t of the 1997 PM2.5 NAAQS by the Serious nonattainment deadline (December 31, 2015) is impracticable and pursuant to Subpart 4 Section (§) 188(e) the District i s also applying for a one-time extension of the attainment date for up to five year s (see Chapter 4).

This chapter demonstrates that this 2015 PM2.5 Plan satisfies the following federal requirements:

1. Fulfillment of commitments fr om the District’s plan to addre ss the 1997 PM2.5 standard 1 2. Reasonably Available C ontrol Measures (RACM) 2 3. Quantitative Milest ones which demonstrat e Reasonable Further Progress (RFP) 3 4. Contingency measures 4 5. Transportation Conformity 5 6. Serious nonattainment a rea permitting requirements 6

6.1 FULFILLMENT OF COMMITMEN TS FROM THE DISTRICT’S 2008 PM2.5 PLAN

The State does not hav e an adopted air qualit y attainment plan currently in place that addresses Subpart 4 requirements for multiple reasons as discus sed in Chapter 1. The adopted plan currently in place to address the 1997 PM2.5 stand ard is the 2008 PM2.5 Plan, 7 approved by EPA in November 2011. 8 The District and the California Air Resources Board (ARB) each commi tted to specific actions to add ress the 1997 NAAQS. The following write-up demonstrates that the District c ommitments included in the 2008 PM2.5 Plan have been fulfilled. Additionally , ARB has also fulfilled the ir

1 Designation of Areas for Air Q uality Planning Purposes; Califo rnia; San Joaquin Valley; Re classification as Serious Nonattainment for the 1997 PM2. 5 Standards. 80 Fed. Reg. 7, pp . 1482-1491. (2015, January 12). http://www.gpo.gov/fdsys/pkg/FR -2015-01-12/pdf/2015-00309.pdf
2 CAA Subpart 1 Section 172(c)(1) . PM2.5 Implementation Rule 72 FR 20609-20633.
3 Federal CAA Subpart 1, Section 17 2(c)(2). PM2.5 Implementatio n Rule 72 FR 20633-20642.
4 Federal CAA Subpart 1, Section 17 2(c)(9). PM2.5 Implementatio n Rule 72 FR 20642-20645.
5 Federal CAA Subpart 1, Section 176. Also, Federal transportati on conformity regulations are found in 40 CFR Part 51, subpart T – Conformity to St ate or Federal Implementation P lans of Transportation Plans, Programs, and Projects Developed, Funded or Approved Un der Title 23 U.S.C. of the Fede ral Transit Laws. Part 93, subpart A of this chapter was last revised by the EPA in the August 15, 1997 Federal Regi ster. 6 Federal CAA Subpart 4, Section 189(b)(3).
7 SJVAPCD. 2008 PM2.5 Plan. http://www.valleyair.org/Air_Quality_Plans/AQ_Final_Adopted_PM2 5_2008.htm
8 Approval and Promulgation of Im plementation Plan s; California; 2008 San Joaquin Valley PM2.5 Plan and 2007 State Strategy; Final Rule, 76 Fed. Reg. 217, pp. 69896-69926. (2011, November 9). (to be codified at 40 CFR Part 50) http://www.gpo.gov/fdsys/pkg/FR-2 011-11-09/pdf/2011-27232.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-2 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard commitments contained in the 2008 PM2.5 Plan, and a detailed description will be included in ARB’s supporting doc umentation for this plan’s adop tion by ARB, scheduled in May.

6.1.1 District 2008 PM2.5 Plan Regulatory Commitments

The District committed to am ending and/or adopting 13 emission reducing control measures for stationary and area sources within the Valley. Th e following table summarizes these commitments and the completion date of such co mmitment.

Table 6-1 2008 PM2.5 Plan Stationary Source Regulatory Commitments

2008 Plan CM# Measure Name Amendment/ Adoption Date Plan Commitment Met? S-AGR-1 Open Burning 05/15/2010 Yes

S-COM-1 Boilers, Steam Generators and Process Heaters (>5 MMBtu/hr) 10/16/2008 Yes

S-COM-2 Boilers, Steam Generators and Process Heaters (2 to 5 MMBtu/hr) 05/19/2011 Yes

S-COM-3 Boilers, Steam Generators and Process Heaters (0.075 to <2 MMBtu/hr) 12/17/2009 Yes
S-COM-5 Stationary Gas Turbines 09/20/2007 Yes S-COM-6 Reciprocating Internal Combustion Engines 08/18/2011 Ye s S-COM-7 Glass Melting Furnaces 05/19/2011 Yes S-COM-9 Residential Water Heaters 03/19/2009 Yes

S-COM-10 Natural Gas-Fired, Fan Type Residential Central Furnace 01/22/2015 Yes

S-COM-14 Wood Burning Fireplaces and Wood Burning Heaters 10/16/2008 Yes
S-IND-9 Commercial Charbroiling 09/17/2009 Yes S-IND-21 Flares 06/18/2009 Yes M-TRAN-1 Employer Based Trip Reduction Programs 06/20/2013 Yes

6.1.2 District 2008 PM2.5 Plan Emission Reduction Commitments

In the 2008 PM2.5 Plan, the District committed to achie ve the total quantity of emissi on reductions identified in Table 6- 2: 8.98 tons NOx/day, 6.7 tons PM2.5/day, and 0.92 tons SOx/day. These emission reductions were to be achieved by the above-mentioned stationary source regul atory commitments, but the commitment ca n be fulfilled with alternative SIP-creditable methods if necessary.

The analysis to determine if the 2008 PM2.5 Plan emission reductions commitments were met included the following steps:

1. Comparison of the emission r eduction commit ments from the 2008 PM2.5 Plan to the actual emission reductions a chieved through prohibitory rul e adoption/amendment actions as s hown in Table 6-2. In addition to the measuresSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-3 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard included in the 2008 PM2.5 Plan the District adopted ame ndments to Rule 4901 9 in 2014 that significantly str engthened the rule requirements. These amendments achieved a minimum of 0.5 tpd of directly emitted PM2.5 reducti ons in 2014 for the two months of wintertime im plementation at t he end of 2014.

Table 6-2 Summary Comparison of Plan Commitments to Actual Emi ssion Reductions (Annual Averag e Emissions (tpd))

2008 Plan CM# Rule # Measure/Rule Name Plan Projected Reductions (tpd) Actual Emission Reductions (tpd) NOx PM2.5 SOx NOx PM2.5 SOx S-AGR-1 4103 Open Burning 2.65 3.49 0.14 1.87 2.91 0.05

S-COM-1 4306 Boilers, Steam Generators and Process Heaters (>5 MMBtu/hr) 1.52 0.24 0.76 3.3 0.24 3.60

S-COM-2 4307 Boilers, Steam Generators and Process Heaters (2 to 5 MMBtu/hr) (Rule 4307) 0 0 0 1.2 0 0

S-COM-3 4308 Boilers, Steam Generators and Process Heaters (0.075 to <2 MMBtu/hr) 0.55 0 0 2.77 0 0

S-COM-5 4703 Stationary Gas Turbines 2.21 0 0 2.20 0 0 S-COM-7 4354 Glass Melting Furnaces 1.58 0 0 1.12 0 0 S-COM-9 4902 Residential Water Heaters 0.40 0 0 0.50 0 0

S-COM-14 4901 Wood Burning Fireplaces and Wood Burning Heaters 0.07 0.69 0.02 0.12 2.40 0.02

n/a 4901 Wood Burning Fireplaces and Wood Burning Heaters (adopted 9/2014) --- --- --- 0 0.5 0

S-IND-9 4692 Commercial Charbroiling 0 2.28 0 0 0.02 0

M-TRAN-1 9410 Employer Based Trip Reduction Programs 0 0 0 0.05 0 0

TOTAL 8.98 6.7 0.92 13.13 6.07 3.67

2. Application of trading ratios for direct PM2.5, NOx, and SOx were applied as shown in Table 6-3. According to the Weight of Evidence (WOE) for the development of the plan to addr ess the 1997 PM2.5 Standard, 1 t on of direct PM2.5 reductions is equivalent to 9 tons of NOx reductions (1:9 trading ratio). 10 In addition to the trading ratio dev eloped for the plan to address the 1997 PM2.5 Standard, extensive modeling c onducted for the District’s 2012 PM2.5 Plan addressing the 2006 federal PM2.5 standard demonstrated that on e ton of direct PM2.5 reductions is equivalent to 4 tons of SOx reductions (1:4 trading ratio). 11

9 SJVAPCD. Rule 4901 F inal Draft Staff Report. http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agend a/2014/September/final/07.pdf
10 SJVAPCD. 2008 PM2.5 Plan. Appendi x H: Weight of Evidence. (2 008, April 30) http://www.valleyair.org/Air_Quality_Plans/AQ_Final_Adopted_PM2 5_2008.htm
11 SJVAPCD. 2012 PM2.5 Plan. A ppendix G: Weight of Evidence. ( 2012, December 20) http://www.valleyair.org/Air_Quality_Plans/PM25Plans2012.htmSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-4 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard These ratios are conservative e stimates summarizing the plan as a whole, not reflecting ratios for New Source Review (NSR).

3. Comparison of the 2008 PM2.5 Plan emission reduction commitment to actual emissions reduced through the Dist rict’s adopted control strate gies (including application of trading ratios for PM 2.5 precursors). Overall, the District’s adopted control strategies achieve emi ssions reductions in excess of th e PM2.5 emission reduction commitment included in the 2008 PM2.5 Plan

.

Table 6-3 Demonstration of Suffi cient Emissions Reductions (An nual Average)

Pollutant Emissions Reductions (tpd) Data reference

PM2.5
A Actual Emissions Reduced 6.1 Table 6-2
B Add PM2.5 reductions, traded from SOx 0.7 1:4 trading ratio
C Add PM2.5 reductions, traded from NOx 0.5 1:9 trading ratio D Total emissions reductions achieved 7.3 (A+B+C)=D
E Emissions Reduction Commitment 6.7 Table 6-2
F Emission Reduction Commitment met? Yes D–E=F

NOx
G Actual Emissions Reduced 13.1 Table 6-2
H Subtract NOx reductions, trade for PM2.5 4.2 1:9 trading ratio I Total emissions reductions achieved 8.9 (G–H)=I
J Emissions Reduction Commitment 8.9 Table 6-2
K Emission Reduction Commitment met? Yes I–J=K

SOx
L Actual Emissions Reduced 3.7 Table 6-2
M Subtract SOx reductions, trade for PM2.5 2.8 1:4 trading ratio N Total emissions reductions achieved 0.9 (L–M)=N
O Emissions Reduction Commitment 0.9 Table 6-2
P Emission Reduction Commitment met? Yes (N–O)=P

As demonstrated in Table 6- 3, the District exceeded its 2008 PM2.5 Plan emissions reductions commitments. Furthe rmore, the District also achieve d significant SIPcreditable emissions reductions i n 2014 that are not included i n the above determination, including 1.03 tons NOx/day o f emissions reduced through on-sit e mitigation measures under the Indirect Source Review rule (District Rule 9510), and 14.72 tons NOx/day and 0.56 tons PM2.5/day of emissions reduced through SIP-creditable incentive programs (as documented through District Rul e 9610, more information at http://www.valleyair.org/MOP/mop9610_idx.htm ).San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-5 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard 6.2 REASONABLY AVAILABLE CONTROL MEASURES (RACM)

A PM2.5 attainment plan must dem onstrate implementation of RACM (reasonably available control measures), su mmarized as the collection of re asonable emissions reductions that, taken as a group , advance attainment of an air quality standard by at least one year. In other words , the total of all potential emi ssions reductions opportunities that are not included as plan commitments mu st not advance attainment by one year. Measures that are not necessary to satisfy Reasonabl e Further Progress (RFP) or expeditious attainment are also not required RACM for the area.

To advance attainment by at l east one year, the collective emis sions reductions that could be achieved through unused but reasonably available contr ols would have to achieve the 2020 emissions lev els by 2019 in the Valley.

The majority of NOx emissions r eductions are occurring as adopt ed regulations are fully implemented through fleet turn-o ver and normal equipment replac ement. As demonstrated in Appendix B, 93% of NOx reductions from the 2012 base emission inventory to attainment in 2020 come from mobile sources. Thes e reductions cannot be expedited through add itional stationary and area source regulat ions, for which the District has regulatory authority.

Based on the difference betw een 2019 and 2020 emissions levels shown in the following table, unused control measures w ould have to achieve 10.7 tons per day (tpd) of NOx reductions to advance attainment by one year. However, as prev iously discussed, there are no unused control m easures in this plan because every reaso nable control measure is used in this plan and the mo st stringent measures possible a re currently in place in the Valley. There are no emissions reductions associated with unus ed regulatory control

measures.

Table 6-4 Emissions Reductions N eeded to Advance Attainment by One year

Pollutant 2019 Emissions (tpd) 2020 Emissions (tpd) Emissions Reductions Needed to Advance Attainment by One Year (tpd) (2019-2020) PM2.5 62.9 62.8 0.1 NOx 217.6 206.9 10.7 SOx 7.8 7.8 0.0

RACM are, by definition, reas onable. Although an air quality a ttainment plan must include a thorough analysis of r easonably available measures, r easonability must drive the analysis. Any measure that i s absurd, unenforceable, impra ctical, or would cause severely disruptive socioeconom ic impacts is unreasonable. Thi s analysis must consider all agencies’ opportunities toget her, but the starting point is the separate analyses of each agency:

 District: all reasonable control measures u nder the District’s jurisdict ion are being implemented. The District has adopted many of the toughest sta tionary and area sources rules in the nation. T here are no reasonable regulator y control measuresSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-6 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard excluded from use in this plan ; therefore, there are no emissio ns reductions associated with unused regulat ory control measures.

 ARB: all reasonable control measures under ARB’s jurisdiction for m obile sources are being implemented. Given t he significant emission reductio ns needed for attainment in California, ARB has adopted some of the most stri ngent control measures nationwide for on-road and off-road mobile sources and the fuels that power them. There are no reasonabl e regulatory control measure s excluded from use in this plan; therefore, t here are no emissions reductions associated with unused regulatory control measures.

 Metropolitan Planning Organizations (MPOs): all reasonable control measures under MPO jurisdiction are being implemented. There are no rea sonable regulatory control measures exc luded from use in this plan; the refore, there are no emissions reductions associat ed with unused r egulatory contr ol measures.

6.3 QUANTITATIVE MILESTONES AND REASONABLE FURTHER PROGRESS (RFP)

CAA Subpart 4 §189(c)(1) require s plans submitted to EPA to con tain quantitative milestones which are to be achiev ed every three years until the area is re-designated attainment and which demonstrat e reasonable further progress as defined in §171. CAA Subpart 1 §171(1) defines reasonabl e further progress (RFP) as incremental emission reductions leading to the attainm ent date. EPA’s interpretatio n of the RFP requirement for federal PM2.5 standards is “ generally linear progress” from the base year to the attainment year, demonstra ted at RFP milestone years. 12 “Generally linear progress” is calculated in an exactly linear fashion.

Analyses for this plan demonstrat e that 2020 is the most expedi tious attainment date practicable for the Valley . The baseline year for this 2015 PM2.5 Plan is 2012. For the 1997 federal PM2.5 standard, the RFP milestone years are 2014 a nd 2017. 13 RFP is demonstrated for the nonattainme nt area as a whole. RFP requir ement targets and attainment demonstrations are as follows:

12 72 FR 20633, codified at 40 CF R 51 Subpart Z Section 51.1000 (Definitions)
13 U.S. Environmental Protection A gency (2012, March 2). Memorand um from the Office of Air Quality Pl anning and Standards: Implementation Guidance for the 2006 24- Hour Fine Pa rticle (PM2.5) Nationa l Ambient Air Quality Standards (NAAQS). Page 16. Retrieved from http://www.epa.gov/ttn/naaqs/pm/ pdfs/20120302_imp lement_guidanc e_24-hr_pm2.5_naaqs.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-7 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard 1. Determine the Emissions Invent ory of the Valley with the Pla n control strategy for the baseline year, the RFP year s, and the attainment year.

Table 6-5 Emissions Inventory w ith Plan Control Strategy (tpd)

Pollutant 2012 2014 2017 2020
Direct PM2.5 (Table B-1) 66.0 63.3 62.5 62.8

NOx (Table B-2) 332.2 284.2 235.7 206.9

SOx (Table B-3) 8.1 7.4 7.6 7.8

2. Determine the total reducti ons from the 2012 baseline emissi on inventory that must be achieved to reach attainment.

Table 6-6 Total Reductions N ecessary to Reach Attainment (tpd)

Pollutant 2012 Baseline Emissions Inventory Attainment Emissions Level Reductions Needed

Direct PM2.5 66.0 62.8 3.2
NOx 332.2 206.9 125.3
SOx 8.1 7.8 0.3

3. Determine the fraction of reduc tions that are achieved in ea ch RFP milestone year (as per EPA guidance regarding dem onstrating RFP). The base yea r of 2012 and attainment year of 2020 s pan an 8-year period.

 2014 occurs at year two of eight (2/8), so 25.0% of the needed emissions reductions should occur by 2014.

 2017 occurs at year five of eight (5/8), so 62.5% of the needed emissions reductions should occur by 2017.

4. Determine the RFP target emi ssions levels using reduction fr actions.

Table 6-7 Target Emissions Level s for RFP Milestone Years (tpd )Pollutant2012 EmissionsInventoryReductionsNeeded 2014 2017Tons to bereduced(B x 25.0%)RFP targetemissionslevel(A-C)Tons to bereduced(B x 62.5%)RFP targetemissionslevel(A-E)

A B C D E F

Direct PM2.5 66.0 3.2 0.8 65.2 2.0 64.0

NOx 332.2 125.3 31.3 300.9 78.3 253.9

SOx 8.1 0.3 0.1 8.0 0.2 7.9San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-8 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard 5. Compare RFP target emissions l evel (Table 6-7) to the projec ted emissions inventory (Table 6-5) to determi ne compliance with RFP targets.

Table 6-8 RFP Target Dem onstration (2014 and 2017)

2014 2017
RFP target emissions level Projected emissions inventory RFP target met? RFP target emissions level Projected emissions inventory RFP target met?

Direct PM2.5 65.2 63.3 Yes 64.0 62.5 Yes

NOx 300.9 284.2 Yes 253.9 235.7 Yes

SOx 8.0 7.4 Yes 7.9 7.6 Yes

Figure 6-1 NOx RFP Demonstrati on – Linear Progress Toward Atta inment

0 50 100 150 200 250 300 350 400

2012 2013 2014 2015 20 16 2017 2018 2019 2020NOx Tons per Day 

## NOx Emissions Required to Demonstrate Reasonable Further ProgressSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-9 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard 6.4 CONTINGENCY MEASURES

Contingency measures are extra emissions reductions that go int o effect without further regulatory action. In an attainm ent plan, the measures must be “extra” in the sense that the reductions are not accounted fo r in RFP or in the attainmen t demonstration. Contingency reductions must sta rt occurring automatically, with out any further regulatory action, in the following scenarios:

 RFP contingencies: Used if planned emissions controls fail to reach the emissions targets specified in th e attainment plan for RFP. Th e need to implement RFP contingencies is bas ed on the emissions inventory in the RFP milestone years.

 Attainment contingencies: Used if a region fails to att ain a federal standard by the final attainment date. The need to implement attainment co ntingencies is based on ambient air quality data as of the end of the attainme nt year. If EPA finds that an area fails to att ain a standard on time, continge ncy reductions must be implemented aut omatically. An area often must adopt a new a ttainment plan, and sometimes other penalties appl y as well, depending on the r equirements associated with the standard in question.

The contingency years for this p lan are the RFP milestone years (2014 and 2017) and the attainment year (2020). The total emissions reductions ava ilable from contingency measures should be equivalent to about one year of reductions n eeded for RFP 14 . This is based on the overall level of reductions needed to demonstra te attainment (see Table 6-6) divided by the number of yea rs between the base year and t he attainment year (8 years). Table 6-9 shows the re sulting contingency need for eac h pollutant.

Table 6-9 Contingency Emissi ons Reductions Target (tpd)

Contingency Need = “One year’s worth of RFP”
Direct PM2.5 0.4
NOx 15.7
SOx 0.0

Interpollutant trading can be us ed to demonstrate equivalent em issions reductions levels between PM2.5 and NOx reductions strategies. The current model ing using Valley-wide emissions reductions demonstrat es that the great est benefits ar e achieved from reductions in directly emitted PM 2.5, followed by NOx (based on EPA’s relative response factor procedures (RRF)). RRF r esults show that directly emitt ed PM2.5 emission reductions are approximately nine times more effective than NOx reductions. Refer to Appendix A for the complete analysis and discussion.

14 Clean Air Fine Particle Implem entation Rule [PM2.5 Implementat ion Rule]. 72 Fed. Reg. 79, pp. 20586–20667. At 20642-43. (2007, April 25). Retrieved from http://www.gpo.gov/fdsys/pkg/FR -2007-04-25/pdf/E7-6347.pdf#page =1San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-10 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard 6.4.1 What Qualifies as a Contingency Measure?

Contingency measures must be fu lly adopted rules or control mea sures that are ready to be implemented quickly without si gnificant additional action by the state or local agency or by EPA 15 . The plan should contain tri gger mechanisms and a schedule fo r the contingency measure im plementation. Contingency measures can i nclude measures already adopted and scheduled for implementation, as long as th ese measures are not relied on to provide emissions r eductions needed to provide for RFP or expeditious attainment.

Based on these general contingen cy requirements, the District i s utilizing two types of contingency measures:

A. Surplus reductions from imple mentation of traditional regula tions B. SIP-creditable incentiv e-based emissions reductions

6.4.2 Surplus Reductions from Im plementation of Traditional Reg ulations

Although contingency measures mus t be surplus to RFP and attain ment calculations, areas are not required to wait unt il there is an RFP or attainm ent failure to implement the measures. As shown in the RFP demonstration in this chapter, s ignificant regulatory emissions reductions are being achieved by 2014 and 2017 – more than the minimum needed to demonstrate RFP in those years. As such, the differe nce between the RFP target emissions level and the ac tual projected emissions level can serve as contingency reductions in 2014 and 2017. Using the data in Table 6-8, Tabl e 6-10 shows amount of reductions availabl e in 2014 and 2017.

Table 6-10 Reductions Surplus t o RFP for Contingency (tpd)

Year 2014 2017 RFP target emissions level Projected emissions inventory Contingency RFP target emissions level Projected emissions inventory Contingency

PM2.5 65.2 63.3 1.9 64.0 62.5 1.5
NOx 300.9 284.2 16.7 253.9 235.7 18.2

As the 2020 attainment contingen cy need would not occur until 2 021 (since attainment would be based on air quality dat a collected through the end of 2020), the additional PM2.5 and NOx reductions occurri ng between 2020 and 2021 can se rve as attainment contingencies (Table 6-11). A dditionally, the District recentl y adopted amendments to Rule 4901 in September 2014 tha t significantly strengthened the rule requirements and achieve a minimum of 1.1 tons o f PM2.5 per day in 2020 (not ass uming any transition to cleaner wood burning devic es under the rule).

15 Clean Air Act Section 1 72(c)9, 40 CF R 51.1012.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-11 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard Table 6-11 Attainment Contingenc ies Traditional Regulatory Red uctions (tpd)

Emission 2020 emissions 2021 emissions Attainment Contingency

PM2.5 Adopted Measures 62.8 62.3 0.5 Additional Surplus Reductions from September 2014 Amendments to Rule 4901 1.1

Total 1.6

NOx Adopted Measures 206.9 194.9 12.0

The control measures achieving the contingency reductions in Ta bles 6-10 and 6-11 are as follows:

 Adopted stationary and area sour ce measures for NOx and PM2.5 contingency : The NOx and PM2.5 contingency reductions are from adopted District rules:

o Rule 4901 (Wood Burning Fireplac es and Wood Burning Heaters

o Rule 4306 (Boilers, Steam Gener ators and Proce ss Heaters (>5 MMBtu/hr))

o Rule 4308 (Boilers, Steam Generat ors and Process Heaters (0.07 5 to <2 MMBtu/hr))

o Rule 4905 (Natural Gas-Fired , Fan-Type Central Furnaces)

 Adopted mobile source measures fo r NOx and PM2. 5 contingency: Most of the total NOx contingency reduc tions are from adopted mobile so urce control measures for the following sources:

o Passenger cars, light-duty vehi cles, and medium-duty vehicles

o Heavy-duty trucks

o Buses

o Commercial harbor craft

o Motor homes

o Off-road equipmentSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-12 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard 6.4.3 SIP-Creditable Incenti ve-Based Emissions Reductions

As discussed in Appendix E of this plan, voluntary incentive pr ograms achieve emissions reductions beyond those achieved by regulations alone. Incenti ve programs accelerate the adoption of cleaner technolog ies and encourage the use of c leaner technologies by those not yet subject to air qua lity regulations. Incentives a llow the District to reduce emissions from source categories outside of the District’s trad itional regulator y authority, as well as source categories wher e financial hardship would oth erwise prevent traditional control strategies from being im plemented. As discussed in App endix E, the District adopted new Rule 9610 (State Impl ementation Plan Credit for Emi ssion Reductions Generated through Incentive Progra ms) in 2013, providing an adm inistrative mechanism for the state to take credit for incentive based emissions redu ctions in the SIP.

6.4.4 Sufficient Cont ingency Reductions

Areas like the Valley that have significant nonattainment chall enges have developed several generations of aggressi ve and far-reaching emission red uction measures to meet various Clean Air Act requi rements. The result of this “n o stone left unturned” policy is that when viable emissi on reductions are identified, they are implemented to contribute to expeditious atta inment. Reductions are not usual ly held in reserve to be used only if an area fails to m eet a milestone. As a result, c ontingency measure demonstrations in the Valley have been a challenge, historicall y. Towards that end, this chapter has outlined two types o f contingency measures that cou ld be used to meet the contingency reductions requi red for this plan:

 Surplus from traditional regulations

 SIP-creditable incentives

Table 6-12 shows how this appr oach generates enough emissions r eductions to meet the contingency reductions requir ed for this plan. The below d emonstration focuses on direct PM2.5 and NOx since cont ingencies are only required for these pollutants (see Table 6-9).San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-13 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard Table 6-12 Demonstration of Su fficient Contingency Reductions

2014 2017 2020 Data reference
PM2.5 Surplus from traditional regulations 1.9 1.5 1.6 Tables 6-10, 6-11 Subtract PM2.5 reductions, trade for NOx 0.0 0.0 -1.2 1:9 trading ratio* Total contingency reductions achieved 1.9 1.5 0.4 Contingency reductions required 0.4 Table 6-9 Contingency need met? Yes Yes Yes

NOx Surplus from traditional regulations 16.7 18.2 12.0 Tables 6-10, 6-11

Substitute PM2.5 reductions 0.0 0.0 +10.8 Above, with 1:9 trading ratio* Total contingency reductions achieved 16.7 18.2 22.8 Contingency reductions required 15.7 Table 6-9 Contingency need met? Yes Yes Yes * 1 ton of direct PM2.5 emissions reductions is equivalent to 9 tons of NOx reductions as demonstated in the WOE. These ratios are conservative estimate s summarizing the plan as a whole, not reflecting ratios appropriate for New Source Review (NSR)

6.5 TRANSPORTATION CONFORMITY

Section 176(c) of the Federal Clean Air Act (CAA) establishes t ransportation conformity requirements which are intended to ensure that transportation a ctivities do not interfere with air quality progr ess. The CAA requires that transportatio n plans, programs, and projects that obtain f ederal funds or approvals conform to applicable state implementation plans ( SIP) before being appr oved by a Metropoli tan Planning Organization (MPO). Conformity to a SIP means that proposed ac tivities must not:

(1) Cause or contribute to any new violation of any standard, (2) Increase the frequency or sever ity of any existing violatio n of any standard in
any area, or (3) Delay timely attainment of any standard or any required int erim emission reductions or other milestones in any area.

A SIP analyzes the region’s tota l emissions inventory from all sources for purposes of demonstrating RFP, attainment, o r maintenance. The portion of the total emissions inventory from on-road highway a nd transit vehicles in these an alyses becomes the “motor vehicle emissions budget.” 16 Motor vehicle emissions budgets are the mechanism for ensuring that tr ansportation planning activities conform to the SIP.

16 Federal transportation conformi ty regulations are found in 40 CFR Part 51, subpart T – Conformity to State or Federal Implementation Plans of Transport ation Plans, Programs, and Pro jects Developed, Funded or Approved Under Title 23 U.S.C. of th e Federal Transit Laws. Part 93 , subpart A of this chapter was re vised by the EPA in the August 15, 1997 Federal Register.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-14 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard Budgets are set for each criteria pollutant or its precursors, and it is set for each RFP milestone year and the attain ment year. Subsequent transportat ion plans and programs produced by transportation planni ng agencies are required to co nform to the SIP by demonstrating that the emissions from the proposed plan, progra m, or project do not exceed the budget levels estab lished in the appl icable SIP.

6.5.1 PM2.5 Requireme nts for Conformity

On April 25, 2007 EPA published in the Federal Register the Clean Air Fine Particle Implementation Rule (Final Rule) implementing t he 1997 PM2.5 NAAQS (see 72 FR 20586). The Final Rule addresses t he types of motor vehicle em issions that must be addressed when setting transporta tion conformity budgets. In t he Final Rule, EPA notes that: “RFP plans, attainment demonstrations, and maintenance p lans must include a budget for direct PM2.5 emissions , except for certain cases as described below. All PM2.5 SIP budgets would include directly emitted PM2.5 motor ve hicle emissions from tailpipe, brake wear, and tire w ear. States should also consid er whether re-entrained road dust or highway and transit c onstruction dust are signific ant contributors and should be included in the PM2.5 budget.” (72 FR 20645) The rule goes on to state that: ‘Under certain circumstances, directly emitted PM2.5 from on-road mobi le sources may be found an insignificant contributor to the air quality problem a nd NAAQS.’

The conformity rule applies fo r particles with aerodynamic diam eter less than or equal to a nominal 2.5 micrometers (PM2. 5). NOx must also be addressed as a precursor unless there is a finding of insignificance.

Section 93.102(b)(2)(iv and v) of t he conformity rule also iden tifies Volatile Organic Compounds (VOC), SOx, and/or ammoni a as PM2.5 precursor polluta nts that must also have a motor vehicle emissions budget if that precursor is deem ed significant. In addition, Section 93.102(b)(3) i dentifies re-entrained road dus t from paved and unpaved roads as PM2.5 emissions that mus t also have a motor vehicle em issions budget if deemed significant. While the app licability section of the rul e does not address fugitive dust from road construction specif ically, the rule does indicat e that the interagency consultation process should be used during the development of P M2.5 SIPs to determine when construction emissions are a significant contributor.

6.5.2 Factors for De termining Significance

The conformity rule states t hat the following factors will be c onsidered in making significance or insignificance findings for PM2.5 precursors: t he contribution of on-road emissions of the precursor to t he total 2012 baseline SIP inven tory; the current state of air quality for the area; the re sults of speciation monitoring for the area; the likelihood that future motor vehicle contro l measures wil l be implemented for a given precursor; and projections of future on-road emissions of the precursor.

Significance findings for re-ent rained road dust emissions will be based on a review of the following factors: the cont ribution of road dust to current and future PM2.5 nonattainment; an area’s current design value for the PM2.5 standard; whether control ofSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-15 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard road dust appears necessary to reac h attainment; and whether in creases in re-entrained dust emissions may interfere with attainment. Such a review wo uld include consideration of local air qua lity data, air quality modeling r esults, or emissions modeling results.

6.5.3 Assessment of Significance

This plan establishes motor vehi cle emission budgets for primar y emissions of PM2.5 from vehicle exhaust, tire and br ake wear, and the precursor NO x. Other precursors are not considered significant for t he reasons discussed in the fol lowing sections.

VOC: On-road mobile emissions accoun t for approximately 10 percent of the Valley’s total VOC emissions in the budge t years. Air quality modeling for this plan indicates that control of VOC is generally ineffe ctive in the control of PM2.5 and in some cases may actually result in increases in PM2.5 levels. Therefore, on ro ad VOC emissions are considered insignificant and th is plan does not establish VOC m otor vehicle emissions budgets for conformity purposes.

SOx: On road mobile exhaust estimates are less than 1 ton per day Valley-wide in the budget years which equates to less than 10 percent of the total SOx emissions inventory. SOx controls are focused on indu strial sources, which contribut e almost 80 percent of the total inventory. Therefore , on road SOx emissions are cons idered insignificant and this plan does not establish SO x motor vehicle emissions budget s for conformity
purposes.

Paved Road Dust: Paved road dust PM2.5 emissions account for approximately 10 percent of the Valley’s total dir ect PM2.5 emissions in the bud get years. As noted in Chapter 3 and Appendix A, all geol ogic and construction source categories combined represent no more than 9 percen t of the peak PM2.5 concentratio ns measured in the Valley. While there are no addi tional fugitive dust controls i ncluded in the attainment demonstration for this plan, paved road dust is controlled via the PM10 Plan and is evaluated as part of PM 10 conformity determinations. Therefore , paved road dust emissions are considered insignif icant and this plan does not e stablish paved road dust motor vehicle emissions budgets for conformity purposes.

Unpaved Road Dust: Total unpaved road dust is less than 10 percent of the Valley ’s total direct PM2.5 emissions i nventory in the budget years. Lo cal roads are one of seven subcategories of unpaved road dus t, and therefore considered in significant. While there are no additional fugitive dust cont rols included in the plan, unpaved road dust is controlled via the PM10 Plan, ( including the prohibition of any new local unpaved roads), and unpaved road dust is evaluated as part of PM10 conformity d eterminations. Therefore unpaved road dust emissions are considered insignific ant, and this plan does not establish unpaved road dust emi ssion budgets for conformity purposes.

Construction Dust: Total construction and demo lition dust is less than 5 percent of the Valley’s total direct PM2.5 emi ssions inventory in the budget y ears. Road construction is one of five subcategories of construction dust and is therefore considered insignificant.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-16 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard While there are no additional fugi tive dust controls included i n the plan, road construction dust is controlled extensively vi a the PM10 Plan and is evaluat ed as part of PM10 conformity determinations. Therefore, construction dust emissi ons are considered insignificant, and this plan does not establish construction du st emission budgets for conformity purposes.

Ammonia: The contribution of ammonia from on-road motor vehicles is ap proximately 1 percent of the total valley-wide ammonia invent ory and is there fore considered insignificant. This plan also es tablishes ammonia is not a lim iting precursor in the formation of PM2.5. T herefore, ammonia on road emissions budge ts are not established by this plan.

6.5.4 Conformity Budgets

This plan includes reasonable furt her progress demonstrations for 2014 and 2017, and an attainment demonstration fo r 2020. Annual average daily emi ssions are used in the plan consistent with the way the standard is m easured. Consequ ently, conformity budgets have been set with EMFAC 2014 for annual average daily emissions in the analysis years 2014, 2017, and 2020.

Section 93.124(e) of the federal c onformity rule states that no nattainment areas with more than one MPO may establish mo tor vehicle emission budgets for each MPO in the non-attainment area. This plan establishes county-level emissi on budgets for each MPO in the Valley.

The transportation conformity b udgets developed for this plan i nclude more recent travel activity projections provided by the Valley MPOs. This travel activity is consistent with the 2015 Federal Transportation Improvement Plan (2015 FTIP) fo r each of the eight Valley MPOs. The emi ssions impact of this more recent activity data is reflected in the attainment demonstration.

The budgets have been constructed to be consistent with the on- road emissions inventory using the following method:

1) Sum the county-by-county emissi ons results to get a Valleywi de total 2) Round the Valley-wide totals up to: a. NOx- the nearest whole ton b. PM2.5 – the near est tenth of a ton 3) Disaggregate the r ounded values proportional to each county’ s emissions 4) Calculate the budget by rounding each county’s values to the nearest tenth ton (for both NOx and PM2.5) u sing conventional rounding.

This plan establishes subarea co unty emission budgets for PM2.5 and NOx for the horizon years 2014, 2017, and 2020 and are summarized in Table 6-12. The attachment on the following page provides m ore detailed calculations.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-17 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard Table 6-13 San Joaquin Valley Tr ansportation Conformity Budget s (tpd, annual average)

County 2014 2017 2020 PM2.5 NOx PM2.5 NOx PM2.5 NOx Fresno 1.2 41.2 1.0 31.2 0.9 25.3 Kern (SJV) 1.0 36.5 0.8 28.0 0.8 23.3 Kings 0.2 7.6 0.2 5.7 0.1 4.8 Madera 0.2 7.8 0.2 5.8 0.2 4.7 Merced 0.4 13.9 0.3 10.7 0.3 8.9 San Joaquin 0.7 19.6 0.6 14.9 0.6 11.9 Stanislaus 0.5 15.6 0.4 11.9 0.4 9.6 Tulare 0.5 14.9 0.4 10.8 0.3 8.4

6.5.5 Emissions Trading Mechanism

Section 93.124(b) of the federal c onformity rule allows for the SIP to establish emissions trading mechanisms between budgets for pollutants or precursors , or among budgets allocated to mobile and other sources. The 2008 PM2.5 Plan (as revised in 2011) included a emissions trading mec hanism, which was approved by E PA effective January 9, 2012, to be used for analysis years after 2014. This SIP al lows trading from the motor vehicle emissions budget for the PM2.5 precursor NOx to the mot or vehicle emissions budget for primary PM2.5 using a 9 to 1 ratio (the modeling doc ument that discusses this ratio will be included in the staff report taken to the ARB Gov erning Board for adoption and included in the full 2015 PM2.5 Plan package that will be s ubmitted to EPA).

The NOx emissions reductions ava ilable for trading are only tho se remaining after the NOx budget is met. For example , for a proposed plan that has a total of 7 tons of NOx, and a NOx budget of 10 tons, there are 3 tons of NOx available to meet the PM2.5 emissions budget. Each agency responsible for demonstrating tr ansportation conformity shall clearly document the calcul ations used in the trading, al ong with any additional reductions of NOx or PM2.5 emissi ons in the conformity analysis

.San Joaquin Valley Unified Air Pollution Control District April 16, 20156-18Chapter 6: Demonstration of Federal Requirements2015 Plan for the 1997 PM2.5 StandardDraft San Joaquin Valley Annual PM2.5 Motor Vehicle Emissions Budgets2015 FSTIP MPO activity data(tons per annual average day)2014 Motor VehicleEmissions BudgetsCountyPM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOxBaseline EMFAC2014 V1.0.2 1.23 40.93 1.04 36.25 0.20 7.53 0.23 7.73 0.3813.86 0.70 19.49 0.49 15.47 0.48 14.81Total 1.23 40.93 1.04 36.25 0.20 7.53 0.23 7.73 0.38 13.86 0.70 19.49 0.49 15.47 0.48 14.81 4.75 156.07Air Basin Total4.8 157Disaggregated County Totals 1.244 41.172 1.047 36.464 0.203 7.579 0.233 7.780 0.382 13.942 0.711 19.606 0.496 15.559 0.485 14.897Budget*1.2 41.2 1.0 36.5 0.2 7.6 0.2 7.8 0.4 13.9 0.7 19.6 0.5 15.6 0.5 14.9 4.8 157.02017 Motor VehicleEmissions BudgetsCountyPM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOxBaseline EMFAC2014 V1.0.2 0.94 31.14 0.80 27.97 0.15 5.72 0.18 5.79 0.2910.68 0.60 14.88 0.39 11.88 0.37 10.79Total 0.94 31.14 0.80 27.97 0.15 5.72 0.18 5.79 0.29 10.68 0.60 14.88 0.39 11.88 0.37 10.79 3.71 118.84Air Basin Total3.8 119Disaggregated County Totals 0.961 31.186 0.814 28.002 0.151 5.723 0.185 5.795 0.292 10.695 0.618 14.895 0.403 11.899 0.376 10.805Budget*1.0 31.2 0.8 28.0 0.2 5.7 0.2 5.8 0.3 10.7 0.6 14.9 0.4 11.9 0.4 10.8 3.8 119.02020 Motor VehicleEmissions BudgetsCountyPM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOxBaseline EMFAC2014 V1.0.2 0.84 25.26 0.73 23.26 0.14 4.82 0.17 4.65 0.268.85 0.58 11.89 0.36 9.57 0.33 8.41Total 0.84 25.26 0.73 23.26 0.14 4.82 0.17 4.65 0.26 8.85 0.58 11.89 0.36 9.57 0.33 8.41 3.42 96.72Air Basin Total3.5 97Disaggregated County Totals 0.860 25.297 0.752 23.292 0.142 4.831 0.173 4.652 0.269 8.866 0.593 11.909 0.370 9.580 0.341 8.419Budget*0.9 25.3 0.8 23.3 0.1 4.8 0.2 4.7 0.3 8.9 0.6 11.9 0.4 9.6 0.3 8.4 3.5 96.8* Established by conventional rounding.Stanislaus TulareMadera Merced San JoaquinSan Joaquin ValleyAir BasinFresno Kern KingsSan Joaquin ValleyAir BasinSan Joaquin ValleySan Joaquin Stanislaus TulareAir BasinSan Joaquin Stanislaus TulareFresno Kern Kings Madera MercedFresno Kern Kings Madera MercedSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-19 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard 6.5.6 Local Transportation Control Measures

Transportation Control Measures (TCMs) in CAA §108(f) are curre ntly being implemented by the Valley MPOs as part of the adopted Congestio n Mitigation and Air Quality (CMAQ) cost effectivene ss policy and in the development of each Regional Transportation Plan (RTP). In addition, new transportation leg islation (MAP-21) includes enhanced emphasis on fundi ng PM2.5 projects.

Valley MPOs continue to imple ment the adopted San Joaquin Valle y CMAQ Policy, which was included in the District’s 2007 Ozone Plan and 2008 PM2.5 Plan . The CMAQ policy includes a standardized pr ocess for distributing 20 perc ent of the CMAQ funds to projects that meet a minimum c ost effectiveness beginning in fi scal year 2011. This policy focuses on achieving the most cost effective emissions r eductions, while maintaining flexibility to m eet local needs. The policy feasib ility and minimum cost effectiveness standard was revisi ted in 2013 as part of the 201 3 Federal Transportation Improvement Program (FTIP) dev elopment; the minimum cost effect iveness standard was also revisited in 2015 as part of the 2015 FTIP development

. Figure 6-2 provides an illustra tion of funding allocated valley -wide in the 2015 FTIPs for a sample of TCM categories: imp roved transit; high occupancy ve hicle lanes; traffic flow improvements; park a nd ride lots; ridesharing/trip reduction pr ograms; bicycle/pedestrian facilities. These tables demonstr ate the eight SJV MPOs’ commi tment to the implementation of TCMs throughou t the Valley. As the Valley MP Os implement TCMs through the current policies, a ll reasonable transportation con trol measures are being implemented.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-20 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard Figure 6-2 Illustration of Valle y MPO Funding for Sample TCM C ategories

Each Valley MPO is required to update its RTP every four years. The RTP is a longterm regional transportation plan t hat provides a vision for tr ansportation investments throughout the Valley. The 2014 RTPs integrate land use and tr ansportation planning to achieve, where feasible, regi onal greenhouse gas (GHG) targets set by ARB pursuant to Senate Bill 375 (SB-375).

To further illustrate the eight S JV MPOs commitm ent to the impl ementation of TCMs throughout the Valley, the RTPs contains a host of improvements to every component of the regional multim odal transportation system including:

 Active transportation (non-motorized transportation, such as b iking and walking)

 Transportation deman d management (TDM)

 Transportation system management (TSM)

 Transit

 Passenger rail

 Goods movement

 Aviation and airport ground access

 Highways

 Arterials

 Operations and maintenanceSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

6-21 Chapter 6: Demonstration of Federal Requirements 2015 Plan for the 1997 PM2.5 Standard Included within these transportati on system improvements are TC M projects that reduce vehicle use or change traffic fl ow or congestion conditions. TC Ms include the following categories of transportation impr ovement projects and programs:

 Improved Transit

 High Occupancy Vehicle Lanes

 Traffic Flow Improvements

 Park and Ride Lots

 Ridesharing/Trip R eduction Programs

 Bicycle/Pedestrian Facilities

6.5.7 SB-375

The Sustainable Communities and Climate Protection Act of 2008 (Sustainable Communities, SB-375) enhances Calif ornia’s strategy to reduce G HG emissions through the coordination of transportati on and land-use to reduce vehic le miles traveled per person through the development of a Sustainable Community Strat egy. SB-375 identifies specific r eduction goals for each of California’s MP Os in 2020 and 2035 which the Sustainable Comm unity Strategy must meet, if feasible. For the Valley, the SB-375 target reductions are a 5% per c apita GHG emissions reductions from 2005 by 2020 and a 10% per capita GHG emissions reductions from 2005 by 2035. T he strategies contained in the RTP/SCS produce benefits for the region far be yond simply reducing GHG emissions. The SCS integrates the transportation network an d related strategies with an overall land use pattern that responds to projected gro wth, housing needs, changing demographics, and transpor tation demands. As a result , Sustainable Community Strategy development i s anticipated to complement the reduction strategies outlined in the 2015 PM2.5 Plan

.

6.6 FULFILLMENT OF SERIOUS AREA PERMITTING REQUIREMENTS

Pursuant to Subpart 4 §189(b)(3) the District must provide a re vision to the nonattainment new source review (NSR) program to lower the appl icable “major stationary source” thresholds fr om 100 tons per year (tpy) to 7 0 tpy. In EPA’s proposed approval of the District adopted 2012 PM2.5 Plan and reclassification of the Valley to Serious Nonattainment for the 2006 PM2.5 NAAQ S, EPA proposes to require that NSR amendments to lower the PM2.5 majo r source threshold from 100 t o 70 tpy shall be submitted within twelve months o f EPA’s final action on the rec lassification.

The District’s New and Modified St ationary Source Review Rule ( Rule 2201) identifies the major source emission thre sholds for each pollutant. Curre ntly, through Rule 2201, the District already identifies the major source emission thres hold for volatile organic materials (VOCs) and NOx major sources at 10 tpy and PM10 and S Ox at 70 tpy. The major source emissions threshold for PM2.5 is currently set at 100 tpy. Consistent with CAA requirements, the Distric t will amend Rule 2201 to lower th e major source emission limit threshold from 100 to 70 tpy within twelve months of EPA’ s final action to reclassify the Valley as a Serious nonattainment area.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

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