San Joaquin Valley Unified Air Pollution 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		

SJVUAPCD	

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

Chapter 6: Demonstration of Federal Requirements 

2015 Plan for the 1997 PM2.5 Standard

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San Joaquin Valley Unified Air Pollution 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 (Subpart 1) and CAA Title 1, 

Part D Subpart 4 (Subpart 4) requires California to submit documentation to EPA that is 

specific to the San Joaquin Valley (Valley) to address the 1997 National Ambient Air 

Quality Standards (NAAQS) for PM2.5. This 2015 Plan for the 1997 PM2.5 Standard

(2015 PM2.5 Plan) fulfills requirements for the Valley as an area classified as a Serious 

nonattainment area under Subpart 4 with an additional request for an extension of the 

attainment deadline. Attainment 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 is also applying for a one-time extension of the attainment 

date for up to five years (see Chapter 4). 

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

requirements: 

1. Fulfillment of commitments from the District’s plan to address the 1997 PM2.5 

standard1

2. Reasonably Available Control Measures (RACM)2

3. Quantitative Milestones which demonstrate Reasonable Further Progress (RFP)3

 

4. Contingency measures4 

5. Transportation Conformity5

6. Serious nonattainment area permitting requirements6

 

6.1 FULFILLMENT OF COMMITMENTS FROM THE DISTRICT’S 2008 PM2.5 

PLAN

The State does not have an adopted air quality attainment plan currently in place that 

addresses Subpart 4 requirements for multiple reasons as discussed in Chapter 1. The 

adopted plan currently in place to address the 1997 PM2.5 standard is the 2008 PM2.5 

Plan,7 approved by EPA in November 2011.8 The District and the California Air 

Resources Board (ARB) each committed to specific actions to address the 1997 

NAAQS. The following write-up demonstrates that the District commitments included in 

the 2008 PM2.5 Plan have been fulfilled. Additionally, ARB has also fulfilled their 

 

1

 Designation of Areas for Air Quality Planning Purposes; California; San Joaquin Valley; Reclassification 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 172(c)(2). PM2.5 Implementation Rule 72 FR 20633-20642. 4

 Federal CAA Subpart 1, Section 172(c)(9). PM2.5 Implementation Rule 72 FR 20642-20645. 5

 Federal CAA Subpart 1, Section 176. Also, Federal transportation conformity regulations are found in 40 CFR Part 

51, subpart T – Conformity to State or Federal Implementation Plans of Transportation Plans, Programs, and Projects 

Developed, Funded or Approved Under Title 23 U.S.C. of the Federal Transit Laws. Part 93, subpart A of this chapter 

was last revised by the EPA in the August 15, 1997 Federal Register. 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_PM25_2008.htm 8

 Approval and Promulgation of Implementation Plans; 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-2011-11-09/pdf/2011-27232.pdf 
San Joaquin Valley Unified Air Pollution 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 documentation for this plan’s adoption by ARB, scheduled 

in May. 

6.1.1 District 2008 PM2.5 Plan Regulatory Commitments 

The District committed to amending and/or adopting 13 emission reducing control 

measures for stationary and area sources within the Valley. The following table 

summarizes these commitments and the completion date of such commitment. 

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 Yes 

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 achieve the total quantity of emission 

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 regulatory commitments, but the commitment can 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 reduction commitments from the 2008 PM2.5 Plan to 

the actual emission reductions achieved through prohibitory rule 

adoption/amendment actions as shown in Table 6-2. In addition to the measures 
San Joaquin Valley Unified Air Pollution 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 amendments to Rule 49019

in 2014 that significantly strengthened the rule requirements. These amendments 

achieved a minimum of 0.5 tpd of directly emitted PM2.5 reductions in 2014 for 

the two months of wintertime implementation at the end of 2014. 

Table 6-2 Summary Comparison of Plan Commitments to Actual Emission 

Reductions (Annual Average 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 address the 1997 PM2.5 Standard, 1 ton of direct 

PM2.5 reductions is equivalent to 9 tons of NOx reductions (1:9 trading ratio).10 In 

addition to the trading ratio developed for the plan to address the 1997 PM2.5 

Standard, extensive modeling conducted for the District’s 2012 PM2.5 Plan

addressing the 2006 federal PM2.5 standard demonstrated that one ton of direct 

PM2.5 reductions is equivalent to 4 tons of SOx reductions (1:4 trading ratio).11 

 

9

 SJVAPCD. Rule 4901 Final Draft Staff Report. 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2014/September/final/07.pdf 10 SJVAPCD. 2008 PM2.5 Plan. Appendix H: Weight of Evidence. (2008, April 30) 

http://www.valleyair.org/Air_Quality_Plans/AQ_Final_Adopted_PM25_2008.htm 11 SJVAPCD. 2012 PM2.5 Plan. Appendix G: Weight of Evidence. (2012, December 20) 

http://www.valleyair.org/Air_Quality_Plans/PM25Plans2012.htm 
San Joaquin Valley Unified Air Pollution 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 estimates 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 District’s adopted control strategies (including 

application of trading ratios for PM2.5 precursors). Overall, the District’s adopted 

control strategies achieve emissions reductions in excess of the PM2.5 emission 

reduction commitment included in the 2008 PM2.5 Plan. 

Table 6-3 Demonstration of Sufficient Emissions Reductions (Annual 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. Furthermore, the District also achieved significant SIPcreditable emissions reductions in 2014 that are not included in the above determination, 

including 1.03 tons NOx/day of emissions reduced through on-site 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 Rule 9610, more information at 

http://www.valleyair.org/MOP/mop9610_idx.htm). 
San Joaquin Valley Unified Air Pollution 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 demonstrate implementation of RACM (reasonably 

available control measures), summarized as the collection of reasonable 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 emissions reductions 

opportunities that are not included as plan commitments must not advance attainment by 

one year. Measures that are not necessary to satisfy Reasonable Further Progress 

(RFP) or expeditious attainment are also not required RACM for the area. 

To advance attainment by at least one year, the collective emissions reductions that 

could be achieved through unused but reasonably available controls would have to 

achieve the 2020 emissions levels by 2019 in the Valley. 

The majority of NOx emissions reductions are occurring as adopted regulations are fully 

implemented through fleet turn-over and normal equipment replacement. As 

demonstrated in Appendix B, 93% of NOx reductions from the 2012 base emission 

inventory to attainment in 2020 come from mobile sources. These reductions cannot be 

expedited through additional stationary and area source regulations, for which the 

District has regulatory authority. 

Based on the difference between 2019 and 2020 emissions levels shown in the following 

table, unused control measures would have to achieve 10.7 tons per day (tpd) of NOx 

reductions to advance attainment by one year. However, as previously discussed, there 

are no unused control measures in this plan because every reasonable control measure 

is used in this plan and the most stringent measures possible are currently in place in the 

Valley. There are no emissions reductions associated with unused regulatory control 

measures. 

Table 6-4 Emissions Reductions Needed 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, reasonable. Although an air quality attainment plan must 

include a thorough analysis of reasonably available measures, reasonability must drive 

the analysis. Any measure that is absurd, unenforceable, impractical, or would cause 

severely disruptive socioeconomic impacts is unreasonable. This analysis must consider 

all agencies’ opportunities together, but the starting point is the separate analyses of 

each agency: 

 District: all reasonable control measures under the District’s jurisdiction are being 

implemented. The District has adopted many of the toughest stationary and area 

sources rules in the nation. There are no reasonable regulatory control measures 
San Joaquin Valley Unified Air Pollution 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 emissions reductions 

associated with unused regulatory control measures. 

 ARB: all reasonable control measures under ARB’s jurisdiction for mobile sources 

are being implemented. Given the significant emission reductions needed for 

attainment in California, ARB has adopted some of the most stringent control 

measures nationwide for on-road and off-road mobile sources and the fuels that 

power them. There are no reasonable regulatory control measures excluded from 

use in this plan; therefore, there 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 reasonable 

regulatory control measures excluded from use in this plan; therefore, there are 

no emissions reductions associated with unused regulatory control measures. 

6.3 QUANTITATIVE MILESTONES AND REASONABLE FURTHER PROGRESS 

(RFP) 

CAA Subpart 4 §189(c)(1) requires plans submitted to EPA to contain quantitative 

milestones which are to be achieved every three years until the area is re-designated 

attainment and which demonstrate reasonable further progress as defined in §171. CAA 

Subpart 1 §171(1) defines reasonable further progress (RFP) as incremental emission 

reductions leading to the attainment date. EPA’s interpretation of the RFP requirement 

for federal PM2.5 standards is “generally linear progress” from the base year to the 

attainment year, demonstrated at RFP milestone years.12 “Generally linear progress” is 

calculated in an exactly linear fashion. 

Analyses for this plan demonstrate that 2020 is the most expeditious 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 and 2017.13 RFP is 

demonstrated for the nonattainment area as a whole. RFP requirement targets and 

attainment demonstrations are as follows: 

 

12 72 FR 20633, codified at 40 CFR 51 Subpart Z Section 51.1000 (Definitions) 13 U.S. Environmental Protection Agency (2012, March 2). Memorandum from the Office of Air Quality Planning and 

Standards: Implementation Guidance for the 2006 24-Hour Fine Particle (PM2.5) National Ambient Air Quality 

Standards (NAAQS). Page 16. Retrieved from 

http://www.epa.gov/ttn/naaqs/pm/pdfs/20120302_implement_guidance_24-hr_pm2.5_naaqs.pdf
San Joaquin Valley Unified Air Pollution 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 Inventory of the Valley with the Plan control strategy for 

the baseline year, the RFP years, and the attainment year. 

Table 6-5 Emissions Inventory with 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 reductions from the 2012 baseline emission inventory that 

must be achieved to reach attainment. 

Table 6-6 Total Reductions Necessary 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 reductions that are achieved in each RFP milestone year 

(as per EPA guidance regarding demonstrating RFP). The base year of 2012 and 

attainment year of 2020 span 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 emissions levels using reduction fractions. 

Table 6-7 Target Emissions Levels for RFP Milestone Years (tpd) Pollutant 2012 Emissions Inventory Reductions Needed 

2014 2017 

Tons to be 

reduced 

(B x 25.0%) 

RFP target 

emissions 

level 

(A-C) 

Tons to be 

reduced 

(B x 62.5%) 

RFP target 

emissions 

level 

(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 7.9 
San Joaquin Valley Unified Air Pollution 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 level (Table 6-7) to the projected emissions 

inventory (Table 6-5) to determine compliance with RFP targets. 

Table 6-8 RFP Target Demonstration (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 Demonstration – Linear Progress Toward Attainment 

0

50

100

150

200

250

300

350

400

2012 2013 2014 2015 2016 2017 2018 2019 2020

NOx Tons per Day 

NOx Emissions Required to Demonstrate 

Reasonable Further Progress 
San Joaquin Valley Unified Air Pollution 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 into effect without further 

regulatory action. In an attainment plan, the measures must be “extra” in the sense that 

the reductions are not accounted for in RFP or in the attainment demonstration. 

Contingency reductions must start occurring automatically, without any further regulatory 

action, in the following scenarios: 

 RFP contingencies: Used if planned emissions controls fail to reach the 

emissions targets specified in the attainment plan for RFP. The need to 

implement RFP contingencies is based on the emissions inventory in the RFP 

milestone years. 

 Attainment contingencies: Used if a region fails to attain a federal standard by 

the final attainment date. The need to implement attainment contingencies is 

based on ambient air quality data as of the end of the attainment year. If EPA 

finds that an area fails to attain a standard on time, contingency reductions must 

be implemented automatically. An area often must adopt a new attainment plan, 

and sometimes other penalties apply as well, depending on the requirements 

associated with the standard in question. 

The contingency years for this plan are the RFP milestone years (2014 and 2017) and 

the attainment year (2020). The total emissions reductions available from contingency 

measures should be equivalent to about one year of reductions needed for RFP14. This 

is based on the overall level of reductions needed to demonstrate attainment (see Table 

6-6) divided by the number of years between the base year and the attainment year (8 

years). Table 6-9 shows the resulting contingency need for each pollutant. 

Table 6-9 Contingency Emissions 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 used to demonstrate equivalent emissions reductions levels 

between PM2.5 and NOx reductions strategies. The current modeling using Valley-wide 

emissions reductions demonstrates that the greatest benefits are achieved from 

reductions in directly emitted PM2.5, followed by NOx (based on EPA’s relative response 

factor procedures (RRF)). RRF results show that directly emitted 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 Implementation Rule [PM2.5 Implementation 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=1 
San Joaquin Valley Unified Air Pollution 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 fully adopted rules or control measures that are ready to 

be implemented quickly without significant additional action by the state or local agency 

or by EPA15. The plan should contain trigger mechanisms and a schedule for the 

contingency measure implementation. Contingency measures can include measures 

already adopted and scheduled for implementation, as long as these measures are not 

relied on to provide emissions reductions needed to provide for RFP or expeditious 

attainment. 

Based on these general contingency requirements, the District is utilizing two types of 

contingency measures: 

A. Surplus reductions from implementation of traditional regulations 

B. SIP-creditable incentive-based emissions reductions 

6.4.2 Surplus Reductions from Implementation of Traditional Regulations 

Although contingency measures must be surplus to RFP and attainment calculations, 

areas are not required to wait until there is an RFP or attainment failure to implement the 

measures. As shown in the RFP demonstration in this chapter, significant regulatory 

emissions reductions are being achieved by 2014 and 2017 – more than the minimum 

needed to demonstrate RFP in those years. As such, the difference between the RFP 

target emissions level and the actual projected emissions level can serve as contingency 

reductions in 2014 and 2017. Using the data in Table 6-8, Table 6-10 shows amount of 

reductions available in 2014 and 2017. 

Table 6-10 Reductions Surplus to 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 contingency need would not occur until 2021 (since attainment 

would be based on air quality data collected through the end of 2020), the additional 

PM2.5 and NOx reductions occurring between 2020 and 2021 can serve as attainment 

contingencies (Table 6-11). Additionally, the District recently adopted amendments to 

Rule 4901 in September 2014 that significantly strengthened the rule requirements and 

achieve a minimum of 1.1 tons of PM2.5 per day in 2020 (not assuming any transition to 

cleaner wood burning devices under the rule). 

 

15 Clean Air Act Section 172(c)9, 40 CFR 51.1012. 
San Joaquin Valley Unified Air Pollution 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 Contingencies Traditional Regulatory Reductions (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 Tables 6-10 and 6-11 are 

as follows: 

 Adopted stationary and area source measures for NOx and PM2.5 

contingency: The NOx and PM2.5 contingency reductions are from adopted 

District rules: 

o Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters 

o Rule 4306 (Boilers, Steam Generators and Process Heaters (>5 

MMBtu/hr)) 

o Rule 4308 (Boilers, Steam Generators and Process Heaters (0.075 to <2 

MMBtu/hr)) 

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

 Adopted mobile source measures for NOx and PM2.5 contingency: Most of 

the total NOx contingency reductions are from adopted mobile source control 

measures for the following sources: 

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

o Heavy-duty trucks 

o Buses 

o Commercial harbor craft 

o Motor homes 

o Off-road equipment 
San Joaquin Valley Unified Air Pollution 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 Incentive-Based Emissions Reductions 

As discussed in Appendix E of this plan, voluntary incentive programs achieve emissions 

reductions beyond those achieved by regulations alone. Incentive programs accelerate 

the adoption of cleaner technologies and encourage the use of cleaner technologies by 

those not yet subject to air quality regulations. Incentives allow the District to reduce 

emissions from source categories outside of the District’s traditional regulatory authority, 

as well as source categories where financial hardship would otherwise prevent traditional 

control strategies from being implemented. As discussed in Appendix E, the District 

adopted new Rule 9610 (State Implementation Plan Credit for Emission Reductions 

Generated through Incentive Programs) in 2013, providing an administrative mechanism 

for the state to take credit for incentive based emissions reductions in the SIP. 

6.4.4 Sufficient Contingency Reductions 

Areas like the Valley that have significant nonattainment challenges have developed 

several generations of aggressive and far-reaching emission reduction measures to 

meet various Clean Air Act requirements. The result of this “no stone left unturned” 

policy is that when viable emission reductions are identified, they are implemented to 

contribute to expeditious attainment. Reductions are not usually held in reserve to be 

used only if an area fails to meet a milestone. As a result, contingency measure 

demonstrations in the Valley have been a challenge, historically. Towards that end, this 

chapter has outlined two types of contingency measures that could be used to meet the 

contingency reductions required for this plan: 

 Surplus from traditional regulations 

 SIP-creditable incentives 

Table 6-12 shows how this approach generates enough emissions reductions to meet 

the contingency reductions required for this plan. The below demonstration focuses on 

direct PM2.5 and NOx since contingencies are only required for these pollutants (see 

Table 6-9). 
San Joaquin Valley Unified Air Pollution 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 Sufficient 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 estimates 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 transportation conformity 

requirements which are intended to ensure that transportation activities do not interfere 

with air quality progress. The CAA requires that transportation plans, programs, and 

projects that obtain federal funds or approvals conform to applicable state 

implementation plans (SIP) before being approved by a Metropolitan Planning 

Organization (MPO). Conformity to a SIP means that proposed activities must not: 

(1) Cause or contribute to any new violation of any standard, 

(2) Increase the frequency or severity of any existing violation of any standard in 

any area, or 

(3) Delay timely attainment of any standard or any required interim emission 

reductions or other milestones in any area. 

A SIP analyzes the region’s total emissions inventory from all sources for purposes of 

demonstrating RFP, attainment, or maintenance. The portion of the total emissions 

inventory from on-road highway and transit vehicles in these analyses becomes the 

“motor vehicle emissions budget.” 16 Motor vehicle emissions budgets are the 

mechanism for ensuring that transportation planning activities conform to the SIP. 

 

16 Federal transportation conformity regulations are found in 40 CFR Part 51, subpart T – Conformity to State or Federal 

Implementation Plans of Transportation Plans, Programs, and Projects Developed, Funded or Approved Under Title 23 U.S.C. of the 

Federal Transit Laws. Part 93, subpart A of this chapter was revised by the EPA in the August 15, 1997 Federal Register. 
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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 attainment year. Subsequent transportation plans and programs 

produced by transportation planning agencies are required to conform to the SIP by 

demonstrating that the emissions from the proposed plan, program, or project do not 

exceed the budget levels established in the applicable SIP. 

6.5.1 PM2.5 Requirements for Conformity 

On April 25, 2007 EPA published in the Federal Register the Clean Air Fine Particle 

Implementation Rule (Final Rule) implementing the 1997 PM2.5 NAAQS (see 72 FR 

20586). The Final Rule addresses the types of motor vehicle emissions that must be 

addressed when setting transportation conformity budgets. In the Final Rule, EPA notes 

that: “RFP plans, attainment demonstrations, and maintenance plans 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 vehicle emissions from 

tailpipe, brake wear, and tire wear. States should also consider whether re-entrained 

road dust or highway and transit construction dust are significant 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 mobile sources may be 

found an insignificant contributor to the air quality problem and NAAQS.’ 

The conformity rule applies for particles with aerodynamic diameter 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 the conformity rule also identifies Volatile Organic 

Compounds (VOC), SOx, and/or ammonia as PM2.5 precursor pollutants that must also 

have a motor vehicle emissions budget if that precursor is deemed significant. In 

addition, Section 93.102(b)(3) identifies re-entrained road dust from paved and unpaved 

roads as PM2.5 emissions that must also have a motor vehicle emissions budget if 

deemed significant. While the applicability section of the rule does not address fugitive 

dust from road construction specifically, the rule does indicate that the interagency 

consultation process should be used during the development of PM2.5 SIPs to determine 

when construction emissions are a significant contributor. 

6.5.2 Factors for Determining Significance 

The conformity rule states that the following factors will be considered in making 

significance or insignificance findings for PM2.5 precursors: the contribution of on-road 

emissions of the precursor to the total 2012 baseline SIP inventory; the current state of 

air quality for the area; the results of speciation monitoring for the area; the likelihood 

that future motor vehicle control measures will be implemented for a given precursor; 

and projections of future on-road emissions of the precursor. 

Significance findings for re-entrained road dust emissions will be based on a review of 

the following factors: the contribution of road dust to current and future PM2.5

nonattainment; an area’s current design value for the PM2.5 standard; whether control of 
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2015 Plan for the 1997 PM2.5 Standard 

road dust appears necessary to reach attainment; and whether increases in re-entrained 

dust emissions may interfere with attainment. Such a review would include 

consideration of local air quality data, air quality modeling results, or emissions modeling 

results. 

6.5.3 Assessment of Significance 

This plan establishes motor vehicle emission budgets for primary emissions of PM2.5 

from vehicle exhaust, tire and brake wear, and the precursor NOx. Other precursors are 

not considered significant for the reasons discussed in the following sections. 

VOC: On-road mobile emissions account for approximately 10 percent of the Valley’s 

total VOC emissions in the budget years. Air quality modeling for this plan indicates that 

control of VOC is generally ineffective in the control of PM2.5 and in some cases may 

actually result in increases in PM2.5 levels. Therefore, on road VOC emissions are 

considered insignificant and this plan does not establish VOC motor 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 industrial sources, which contribute almost 80 percent of 

the total inventory. Therefore, on road SOx emissions are considered insignificant and 

this plan does not establish SOx motor vehicle emissions budgets for conformity 

purposes. 

Paved Road Dust: Paved road dust PM2.5 emissions account for approximately 10 

percent of the Valley’s total direct PM2.5 emissions in the budget years. As noted in 

Chapter 3 and Appendix A, all geologic and construction source categories combined 

represent no more than 9 percent of the peak PM2.5 concentrations measured in the 

Valley. While there are no additional fugitive dust controls included in the attainment 

demonstration for this plan, paved road dust is controlled via the PM10 Plan and is 

evaluated as part of PM10 conformity determinations. Therefore, paved road dust 

emissions are considered insignificant and this plan does not establish 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 inventory in the budget years. Local roads are one of seven 

subcategories of unpaved road dust, and therefore considered insignificant. While there 

are no additional fugitive dust controls 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 determinations. 

Therefore unpaved road dust emissions are considered insignificant, and this plan does 

not establish unpaved road dust emission budgets for conformity purposes. 

Construction Dust: Total construction and demolition dust is less than 5 percent of the 

Valley’s total direct PM2.5 emissions inventory in the budget years. Road construction is 

one of five subcategories of construction dust and is therefore considered insignificant. 
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6-16 Chapter 6: Demonstration of Federal Requirements 

2015 Plan for the 1997 PM2.5 Standard 

While there are no additional fugitive dust controls included in the plan, road construction 

dust is controlled extensively via the PM10 Plan and is evaluated as part of PM10 

conformity determinations. Therefore, construction dust emissions are considered 

insignificant, and this plan does not establish construction dust emission budgets for 

conformity purposes. 

Ammonia: The contribution of ammonia from on-road motor vehicles is approximately 1 

percent of the total valley-wide ammonia inventory and is therefore considered 

insignificant. This plan also establishes ammonia is not a limiting precursor in the 

formation of PM2.5. Therefore, ammonia on road emissions budgets are not established 

by this plan. 

6.5.4 Conformity Budgets 

This plan includes reasonable further progress demonstrations for 2014 and 2017, and 

an attainment demonstration for 2020. Annual average daily emissions are used in the 

plan consistent with the way the standard is measured. Consequently, 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 conformity rule states that nonattainment areas with 

more than one MPO may establish motor vehicle emission budgets for each MPO in the 

non-attainment area. This plan establishes county-level emission budgets for each MPO 

in the Valley. 

The transportation conformity budgets developed for this plan include more recent travel 

activity projections provided by the Valley MPOs. This travel activity is consistent with 

the 2015 Federal Transportation Improvement Plan (2015 FTIP) for each of the eight 

Valley MPOs. The emissions 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 emissions results to get a Valleywide total 

2) Round the Valley-wide totals up to: 

a. NOx- the nearest whole ton 

b. PM2.5 – the nearest tenth of a ton 

3) Disaggregate the rounded 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) using conventional rounding. 

This plan establishes subarea county 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 more detailed calculations. 
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2015 Plan for the 1997 PM2.5 Standard 

Table 6-13 San Joaquin Valley Transportation Conformity Budgets (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 conformity 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 mechanism, which was approved by EPA effective January 

9, 2012, to be used for analysis years after 2014. This SIP allows trading from the motor 

vehicle emissions budget for the PM2.5 precursor NOx to the motor vehicle emissions 

budget for primary PM2.5 using a 9 to 1 ratio (the modeling document that discusses this 

ratio will be included in the staff report taken to the ARB Governing Board for adoption 

and included in the full 2015 PM2.5 Plan package that will be submitted to EPA). 

The NOx emissions reductions available for trading are only those 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 transportation conformity 

shall clearly document the calculations used in the trading, along with any additional 

reductions of NOx or PM2.5 emissions in the conformity analysis. 
San Joaquin Valley Unified Air Pollution Control District 

6-18 Chapter 6: Demonstration of 

2015 Plan for th

Draft San Joaquin Valley Annual PM2.5 Motor Vehicle Emissions Budgets2015 FSTIP MPO activity data 

(tons per annual average day)

2014 Motor Vehicle Emissions Budgets

County

PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 

Baseline EMFAC2014 V1.0.2 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 Total 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 Air Basin Total Disaggregated 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 Budget* 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 

2017 Motor Vehicle Emissions Budgets

County

PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 

Baseline EMFAC2014 V1.0.2 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 Total 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 Air Basin Total Disaggregated 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 Budget* 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 

2020 Motor Vehicle Emissions Budgets

County

PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 NOx PM2.5 

Baseline EMFAC2014 V1.0.2 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 Total 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 Air Basin Total Disaggregated 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 Budget* 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 

* Established by conventional rounding. 

Madera Merced San Joaquin Stanislaus Tulare 

Fresno Kern Kings

San Joaquin Stanislaus TulareSan Joaquin Stanislaus Tulare

Fresno Kern Kings Madera MercedFresno Kern Kings Madera Merced
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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 currently being 

implemented by the Valley MPOs as part of the adopted Congestion Mitigation and Air 

Quality (CMAQ) cost effectiveness policy and in the development of each Regional 

Transportation Plan (RTP). In addition, new transportation legislation (MAP-21) includes 

enhanced emphasis on funding PM2.5 projects. 

Valley MPOs continue to implement the adopted San Joaquin Valley CMAQ Policy, 

which was included in the District’s 2007 Ozone Plan and 2008 PM2.5 Plan. The CMAQ 

policy includes a standardized process for distributing 20 percent of the CMAQ funds to 

projects that meet a minimum cost effectiveness beginning in fiscal year 2011. This 

policy focuses on achieving the most cost effective emissions reductions, while 

maintaining flexibility to meet local needs. The policy feasibility and minimum cost 

effectiveness standard was revisited in 2013 as part of the 2013 Federal Transportation 

Improvement Program (FTIP) development; the minimum cost effectiveness standard 

was also revisited in 2015 as part of the 2015 FTIP development. 

Figure 6-2 provides an illustration of funding allocated valley-wide in the 2015 FTIPs for 

a sample of TCM categories: improved transit; high occupancy vehicle lanes; traffic flow 

improvements; park and ride lots; ridesharing/trip reduction programs; bicycle/pedestrian 

facilities. These tables demonstrate the eight SJV MPOs’ commitment to the 

implementation of TCMs throughout the Valley. As the Valley MPOs implement TCMs 

through the current policies, all reasonable transportation control measures are being 

implemented. 

 
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6-20 Chapter 6: Demonstration of Federal Requirements 

2015 Plan for the 1997 PM2.5 Standard 

Figure 6-2 Illustration of Valley MPO Funding for Sample TCM Categories

Each Valley MPO is required to update its RTP every four years. The RTP is a longterm regional transportation plan that provides a vision for transportation investments 

throughout the Valley. The 2014 RTPs integrate land use and transportation planning to 

achieve, where feasible, regional greenhouse gas (GHG) targets set by ARB pursuant to 

Senate Bill 375 (SB-375). 

To further illustrate the eight SJV MPOs commitment to the implementation of TCMs 

throughout the Valley, the RTPs contains a host of improvements to every component of 

the regional multimodal transportation system including: 

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

 Transportation demand management (TDM) 

 Transportation system management (TSM) 

 Transit 

 Passenger rail 

 Goods movement 

 Aviation and airport ground access 

 Highways 

 Arterials 

 Operations and maintenance 
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2015 Plan for the 1997 PM2.5 Standard 

Included within these transportation system improvements are TCM projects that reduce 

vehicle use or change traffic flow or congestion conditions. TCMs include the following 

categories of transportation improvement projects and programs: 

 Improved Transit 

 High Occupancy Vehicle Lanes 

 Traffic Flow Improvements 

 Park and Ride Lots 

 Ridesharing/Trip Reduction Programs 

 Bicycle/Pedestrian Facilities 

6.5.7 SB-375 

The Sustainable Communities and Climate Protection Act of 2008 (Sustainable 

Communities, SB-375) enhances California’s strategy to reduce GHG emissions through 

the coordination of transportation and land-use to reduce vehicle miles traveled per 

person through the development of a Sustainable Community Strategy. SB-375 

identifies specific reduction goals for each of California’s MPOs in 2020 and 2035 which 

the Sustainable Community Strategy must meet, if feasible. For the Valley, the SB-375 

target reductions are a 5% per capita GHG emissions reductions from 2005 by 2020 and 

a 10% per capita GHG emissions reductions from 2005 by 2035. The strategies 

contained in the RTP/SCS produce benefits for the region far beyond simply reducing 

GHG emissions. The SCS integrates the transportation network and related strategies 

with an overall land use pattern that responds to projected growth, housing needs, 

changing demographics, and transportation demands. As a result, Sustainable 

Community Strategy development is 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 revision to the 

nonattainment new source review (NSR) program to lower the applicable “major 

stationary source” thresholds from 100 tons per year (tpy) to 70 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 NAAQS, EPA proposes to require that NSR 

amendments to lower the PM2.5 major source threshold from 100 to 70 tpy shall be 

submitted within twelve months of EPA’s final action on the reclassification. 

The District’s New and Modified Stationary Source Review Rule (Rule 2201) identifies 

the major source emission thresholds for each pollutant. Currently, through Rule 2201, 

the District already identifies the major source emission threshold for volatile organic 

materials (VOCs) and NOx major sources at 10 tpy and PM10 and SOx at 70 tpy. The 

major source emissions threshold for PM2.5 is currently set at 100 tpy. Consistent with 

CAA requirements, the District will amend Rule 2201 to lower the 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. 
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