Air Resources Board 

Mary D. Nichols, Chairman 

1001 1 Street P.O. Box 2815 

Linda S. Adams Sacramento, California 9581 2 www.arb.ca.gov Arnold Schwarzenegger 

Secretary for Governor 

Environmental Protection 

September 16, 201 0 

Ms. Deborah Jordan, Director 

Air Division 

U.S. Environmental Protection Agency 

Region 9 

75 Hawthorne Street 

San Francisco, California 941 05 

Dear Ms. Jordan: 

I am writing to underscore the important role that the California Regional Particulate 

Matter Air Quality Study (Study) has played in the development of the 2008 PM2.5 State 

Implementation Plan (SIP) for the San Joaquin Valley. The $27 rr~illion study was a 

landmark example of collaborative environmental management that has provided the 

most advanced scientific understanding available for SIP development. This state-ofthe-science effort significantly advanced our understanding of the nature of PM2.5 in the 

Valley and the control approach needed to provide for attainment of federal standards. 

Data collected at over 100 monitoring sites has resulted in a publicly available database 

containing over 180,000,000 records and a comprehensive website provides study 

documentation and reports. To date, over 60 papers have been published in peerreviewed journals such as Atmospheric Environment, Environmental Science and 

Technology, and the Journal of the Air and Waste Management Association. In 

addition, over 50 presentations have been given at national and international 

conferences. Attachment A provides the extensive Study bibliography. Data and 

findings from the Study provided a rigorous basis for the attainment demonstration 

modeling conducted for the SIP by Air Resources Board staff. This was further 

supplemented by extensive modeling by academic researchers which further 

corroborate the SIP modeling results. 

United States Environmental Protection Agency (U.S. EPA) staff has been active 

participants over the last fifteen years in both the Policy and Technical Corr~mittees 

where frequent updates on study findings have been presented. Results from the Study 

have already been relied upon by U.S. EPA in previous rulemakings for PMIO in the 

San Joaquin Valley. For example, in 2004 (Federal RegisterNol. 69, No. 102 1 

Wednesday, May 26, 2004), U.S. EPA concluded that VOC's were not a significant 

precursor for PMIO ammonium nitrate formation, citing work conducted as part of the 

Study (Attachment B). Additional Study analyses coriducted since that time have 

further refined and continue to support EPA's findings. 

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. 

For a list of simple ways you can reduce demand and cut your energy costs, see our website: 

California Environmental Protection Agency 

Printed on Recycled Paper 
Ms. Deborah Jordan, Director 

September 16,201 0 

Page 2 

We appreciate U.S. EPA's ongoirlg support of this important Study and we wo~~ld be 

happy to provide a briefing for the Regional Administrator on the key findings and how 

they have supported the San Joaquin Valley PM2.5 SIP. If you have any questions, 

please contact Lynn Terry, Deputy Executive Officer at (916) 322-2739, or via email at 

Sincerely, 

James N. ~oldpne 

Executive Offi er 

Attachments 

cc: Ms. Lynn Terry 

Deputy Executive Officer 
ATTACHMENT A 

CALIFORNIA REGIONAL PM101PM2.5 AIR QUALITY STUDY 

PUBLICA1'IONS 

1. Roth, P. M. et al., 1993, "A Proposed PM-10 Program for the San Joaquin Valley", prepared by 

Envair for the San Joaquin Valleywide Air Pollution Study Agency. 

2. Gray, H.A. et al. 1995, "San Joaquin Valley Regional PMIO Study Technical Support Study 5A: 

Characterizing Micrometeorological Phenomena: Mixing and Diffusion in Low Wind 

Speed Stable Conditions", prepared by Systems Applications International for the San 

Joaquin Valleywide Air Pollution Study Agency. 

3. Gillies, J. et al., 1995, "Literature Review Plan for the San Joaquin Valley Regional Particulate 

Study Technical Support Study No. 5: Particle Resuspension", prepared by the Desert 

Research lnstitute for the San Joaquin Valleywide Air Pollution Study Agency. 

4. Gillies, J. et al., 1995, "Resuspension of Particles by the Wind: A Literature Review for the San 

Joaquin Valley Regional Particulate Study Technical Support Study No. 5: Particle 

Resuspension", prepared by the Desert Research lnstitute for the San Joaquin 

Valleywide Air Pollution Study Agency. 

5. Gillies, J. et al., 1996, "Resuspension of Particles by the Wind: Research lnitiatives for California 

Regional Particulate Study Technical Support Study No. 5: Particle Resuspension", 

prepared by the Desert Research lnstitute for the San Joaquin Valleywide Air Pollution 

Study Agency. 

6. Gillies, J. et al., 1996, "Resuspension of Particles by the Wind: Modeling, Data Analysis Initiatives 

for California Regional Particulate Study Technical Support Study No. 5: Particle 

Resuspension", prepared by the Desert Research lnstitute for the San Joaquin 

Valleywide Air Pollution Study Agency. 

7. Hagan, C, et al., 1996, "California Regional PMIO Air Quality Study: Emissions Modeling Plan", 

prepared by Envair for the San Joaquin Valleywide Air Pollution Study Agency. 

8. Roth, P. M. et al., 1996, "Revisions to Cost Estimates for the Central California Fine Particle 

Study", prepared by Envair for the San Joaquin Valleywide Air Pollution Study Agency. 

9. Watson, J. et al., 1996, "Data Analysis Activities for the 1995 Integrated Monitoring Study (IMS95) 

of the California Regional Particulate Matter Study (CRPAQS)", prepared by Desert 

Research lnstitute for the San Joaquin Valleywide Air Pollution Study Agency. 

10. Kumar, N, et al., 1996, "User's Guide to the UAM-AERO Model", prepared by Sonoma Technology 

Inc. for the San Joaquin Valleywide Air Pollution Study Agency. 

11. Kumar, N. et al., 1996, "User's Guide to the Speciated Rollback Model for Particulate Matter", 

prepared by Sonoma Technology Inc. for the San Joaquin Valleywide Air Pollution 

Study Agency. 
12. Lurmann, F. et al., 1996, "PMI 0 Air Quality Models for Application in the San Joaquin Valley 

PMIO SIP", prepared by Sonoma Technology, Inc. for the San Joaquin Valleywide Air 

Pollution Study Agency. 

13. Lehrman, D. E. et al., 1996, "SARIVIAP II Design: Analysis of the San Joaquin Valley 

Meteorological Environment During High PMI 0 Loading", prepared by Technical & 

Business Systems, Inc. for the San Joaquin Valleywide Air Pollution Study Agency. 

14. Rogge, W., 1996, "Feasibility of Using Organic Tracers for Tracking the Fate of Primary and 

Secondary Aerosols from Combustion Sources", prepared by Florida lnternational 

University for the San Joaquin Valleywide Air Pollution Study Agency. 

15. Chinkin, L. R. et al., 1996, "Final Workplan for Evaluation and Improvement of Methods for 

Determining Ammonia Emissions in the San Joaquin Valley Technical Support Study 

5", prepared by Sonoma Technology, Inc. for the San Joaquin Valleywide Air Pollution 

Study Agency. 

16. Chinkin, L. R., 1996, "CRPAQS TSSI 5: Task 3, Initial Ammonia Inventory for the San Joaquin 

Valley", prepared by Sonoma Technology, Inc. for the San Joaquin Valleywide Air 

Pollution Study Agency. 

17. Chinkin, L. R. et al., 1996, "Review of Current Methodologies for Estimating Ammonia Emissions", 

prepared by Sonoma Technology, Inc. for the San Joaquin Valleywide Air Pollution 

Study Agency: 

18. Watson, J. G. et al., 1996, "Final Study Plan for: Effectiveness Demonstration of Fugitive Dust 

Control Methods for Public Unpaved Roads and Unpaved Shoulders on Paved Roads", 

prepared by the Desert Research Institute for the San Joaquin Valleywide Air Pollution 

Study Agency. 

19. Watson, J. G. et al., 1996, "Final Report: Effectiveness Demonstration of Fugitive Dust Control 

Methods for Public Unpaved Roads and Unpaved Shoulders on Paved Roads", 

prepared by Desert Research lnstitute for the San Joaquin Valleywide Air Pollution 

Study Agency. 

20. Solomon, P.A. et al., 1996, "1995 lntegrated Monitoring Study: Objectives and Design", presented 

at the 1996 U. S. EPA/A&WMA lnternational Symposium on Measurement of Toxic 

and Related Air Pollutants, Research Triangle Park, NC. 

21. Magliano, K.L. et al., 1996, "1995 lntegrated Monitoring Study: Temporal Variability of Particulate 

Matter - Preliminary Results", presented at the 1996 U.S. EPNA&WMA lnternational 

Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle 

Park, NC. 

22. Solomon, P.A. et al., 1996, "1 995 lntegrated Monitoring Study: Spatial and Temporal Variability of 

PMIO During the Fall Saturation Study - Preliminary Results", presented at the 1996 

U. S. EPNA&WMA International Symposium on Measurement of Toxic and Related Air 

Pollutants, Research Triangle Park, NC. 

23. Coe, D. et al., 1996, "Emission Activity Measurement During the Fall andd Winter IMS95 

Components - Preliminary Results", presented at the 1996 U.S. EPA/A&WMA 
lnternational Symposium on Measurement of Toxic and Related Air Pollutants, 

Research Triangle Park, NC. 

24. Bush, D.H. et al., 1996, "IMS95 Winter Study - Quality Assurance", presented at the 1996 U.S. 

EPA,A&WMA lnternational Symposium on Measurement of Toxic and Related Air 

Pollutants, Research Triangle Park, NC. 

25. Collett, J. et al., 1996, "1995 lntegrated Monitoring Study: Fog Measurements in the Southern 

Valley - Preliminary Results", presented at the 1996 U.S. EPA/A&WMA lnternational 

Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle 

Park, NC. 

26. Collett, J. et al., 1996, "1995 lntegrated Monitoring Study: Fog Measurements in the Northern 

Valley - Preliminary Results", .presented at the 1996 U.S. EPA/A&WMA lnternational 

Symposium on Measurement of Toxic and Related Air Pollutants, Research Triangle 

Park, NC. 

27. Gray, H.A., 1996, "1995 lntegrated Monitoring Study: Low Wind Speed Study - Preliminary 

Results", presented at the 1996 U.S. EPA/A&WMA lnternational Symposium on 

Measurement of Toxic and Related Air Pollutants, Research Triangle Park, NC. 

28. Lindsey, C. et al., 1996, "Data Collected by a Network of Radar Profilers, Rawinsonde Sounding 

Stations, and Surface Meteorological Monitoring Sites During IMS95", prepared by 

Sonoma Technology Inc. for the San Joaquin Valleywide Air Pollution Study Agency. 

29. Barnett, A. et al., 1996, "lntegrated Measurements Study - 1995 Audit Program Final Report", 

prepared by Aerovironment Environmental Services Inc. for the San Joaquin 

Valleywide Air Pollution Study Agency. 

30. Bush, D. et al., 1996, "IMS95 Winter Study Meteorological Measurements Audits", prepared by 

Aerovironment Environmental Services, Inc. for the San Joaquin Valleywide Air 

Pollution Study Agency. 

31. Ashbaugh, L. A. et al., 1996, "Road Silt Loadings in the San Joaquin Valley During IMS-95", 

prepared by U.C. Davis for the San Joaquin Valleywide Air Pollution Study Agency. 

32. Wilson, M., 1996, "Traffic Counts in Support of the 1995 lntegrated Monitoring Study", prepared by 

WILTEC for the San Joaquin Valleywide Air Pollution Study Agency. 

33. Wilson, M., 1996, "Traffic Counts in Support of the 1995 lntegrated Monitoring Study -Axle 

Classification Counts", prepared by WILTEC. 

34. Coe, D. et al., 1996, "IMS95 Daily Activity Surveys", prepared by Sonoma Technology Inc. for the 

San Joaquin Valleywide Air Pollution Study Agency. 

35. Roberts, P. et al., 1996, "Collection of Continuous Gas-Phase Data at Two Sites During IMS95", 

prepared by Sonoma Technology Inc. for the San Joaquin Valleywide Air Pollution 

Study Agency. 

36. Westerinin, A. et at., 1996, "Final Audit Results for the lntegrated Monitoring Study1', prepared by 

the Air Resources Board for the San Joaquin Valleywide Air Pollution Study Agency. 
37. Watson, J. G. et al., 1997, "The Fugitive Dust Characterization Study (FDCS): Potential Methods 

and Research Needs for Receptor Methods to Distinguish Among Fugitive Dust 

Sources", prepared by Desert Research lnstitute for the San Joaquin Valleywide Air 

Pollution Study Agency. 

38. Watson, J. G. et al., 1997, "Analysis of Historical PM10 and PM2.5 Measurements in Central 

California", prepared by Desert Research lnstitute for the San Joaquin Valleywide Air 

Pollution Study Agency. 

39. Ondov, J., 1997, "Technical Support Study No. 13: Feasibility of Using Rare Earth Isotope and 

Activatable Tracers for Tracking the Fate of Primary and Secondary Aerosols from 

Combustion Sources", prepared by John Ondov for the San Joaquin Valleywide Air 

Pollution Study Agency. 

40. Pankratz, D., 1997, "Quality Assurance Project Plan for Evaluation and Improvement of Methods 

for Determining Ammonia Emissions in the San Joaquin Valley", prepared by 

Aerovironment for the San Joaquin Valleywide Air Pollution Study Agency. 

41. Richards, L. W., 1997, "Technical Support Study 11 : lnvestigating the Dynamics and Chemistry of 

Fog Formation and Dissipation - Literature Review", prepared by Sonoma Technology 

Inc. for the San Joaquin Valleywide Air Pollution Study Agency. 

42. Collett, J. et al., 1997, "Technical Support Study 11: lnvestigating the Dynamics and Chemistry of 

Fog Formation and Dissipation - San Joaquin Valley Fog Measurements During the 

1995 lntegrated Monitoring Study", prepared by Colorado State University for the San 

Joaquin Valleywide Air Pollution Study Agency. 

43. Pankratz, D. et al., 1997, "Measurements Report for High Resolution Meteorological Monitoring in 

the San Joaquin Valley1', prepared by Aerovironment Environmental Service Inc. for the 

San Joaquin Valleywide Air Pollution Study Agency. 

44. Pandis, S. et al., 1997, "Technical Support Study 11: lnvestigating the Dynamics and Chemistry of 

Fog Formation and Dissipation Paper Copies of References Cited in the Review of 

Literature on Fogs", prepared by Carnegie Mellon University for the San Joaquin 

Valleywide Air Pollution Study Agency. 

45. Richards, L. W, et al., 1997, "Technical Support Study 11: lnvestigating the Dynamics and 

Chemistry of Fog Formation and Dissipation Phase II Report Measurement at the 

Candalabra Tower", prepared by Sonoma Technology Inc. for the San Joaquin 

Valleywide Air Pollution Study Agency. 

46. Pandis, S. et al., 1997, "Technical Support Study 11: lnvestigating the Dynamics and Chemistry of 

Fog Formation and Dissipation Fog Modeling", prepared by Carnegie Mellon University 

for the San Joaquin Valleywide Air Pollution Study Agency. 

47. Chow, J. C. et al., 1997, "San Joaquin Valley 1995 lntegrated Monitoring Study: Documentation, 

Evaluation, and Descriptive Data Analysis of PMI 0, PM2.5 and Precursor Gas 

Measurements Technical Support Studies No. 4 and 8", prepared by the Desert 

Research lnstitute for the San Joaquin Valleywide Air Pollution Study Agency. 
48. Chow, J. C. et al., 1997, "Size-resolved Particle and Light Extinction Measurements During 

IMS95", presented at the A&WMA Visual Air Quality - Aerosols and Global Radiation 

Balance Conference, Bartlett, N H. 

49. Solomon, P. A. et al., 1997. "Operational Field Monitoring Plan for the 199511 996 lntegrated 

Monitoring Study (IMS95) of the California Regional PMIO Air Quality Study 

(CRPAQS), Post Field Version, Draft Report", prepared by Pacific Gas & Electric 

Company for the San Joaquin Valleywide Air Pollution Study Agency. 

50. Solomon, P. A. et al., 1997, "Site Description Report for the 1995 lntegrated Monitoring Study 

(IMS95) of the California Regional PMIO Air Quality Study (CRPAQS), Post Field 

Version, Final Report", prepared by Pacific Gas & Electric Company for the San 

Joaquin Valleywide Air Pollution Study Agency. 

51. Fitz, D., 1997, "Evaluation and Improvement of Methods for Determining Ammonia Emissions in 

the San Joaquin Valley Field Data Report", prepared by University of California, 

Riverside CE-CERT for the San Joaquin Valleywide Air Pollution Study Agency. 

52. McDade, C., 1997, "lms95 Data Analysis Draft Work Plan for Work Elements 7.3, 7.4, 7.5", 

prepared by ENSR Consulting & Engineering for the San Joaquin Valleywide Air 

Pollution Study Agency. 

53. Magliano, K. L., 1997, "Work Plan for Chemical Mass Balance Modeling of IMS95 Data", prepared 

by the California Air Resources Board for the San Joaquin Valleywide Air Pollution 

Study Agency. 

54. Blanchard, C., 1997, "California Regional PMIO Air Quality Study 1995 lntegrated Monitoring 

Study Data Analysis Combined Workplan for Tasks 4.2.1 and 4.5.6", prepared by 

Envair for the San Joaquin Valleywide Air Pollution Study Agency. 

55. Chinkin, L. R. et al., 1997, "IMS 95 Data Analysis Workplans for Tasks 4.1.2, 4.5.1, 4.5.3, 4.6.1, 

4.6.2, 4.7.1, and 4.7.2", prepared by Sonoma Technology, Inc. for the San Joaquin 

Valleywide Air Pollution Study Agency. 

56. Collins, J., 1997, "IMS95 Data Analysis Workplan for Work Element 3.3 Boundaries and 

Backgrounds", prepared by the University of California, Riverside, CE-CERT for the 

San Joaquin Valleywide Air Pollution Study Agency. 

57. Collet, J., 1997, "~&k Plan for Work Element 4.6.711, prepared by Colorado State University for 

the San Joaquin Valleywide Air Pollution Study Agency. 

58. Collet, J., 1997, "Work Plan for Work Element 4.6.8", prepared by Colorado State University for 

the San Joaquin Valleywide Air Pollution Study Agency. 

59. Pandis, S., 1997, "Work Plan for Work Element 4.6.4", prepared by Carnegie Mellon University for 

the San Joaquin Valleywide Air Pollution Study Agency. 

60. "Lehrman, D. L., 1997, "Work Plan for IMS95 Analysis Elements 2.2.2 and 2.2.3", prepared by 

Technical & Business Systems, Inc. for the San Joaquin Valleywide Air Pollution Study 

Agency. 
61. McDade, C. E., 1997, "Draft Final Report IM95 Data Analysis Work Elements 7.3 Contributions of 

Chemical Constituents to Visibility Reduction, 7.4 Contributions of Chemical 

Constituents to Light Extinction Budget, 7.5 Contributions of Emission Sources to Light 

Extinction Budget", prepared by ENSR Consulting and Engineering for the San Joaquin 

Valleywide Air Pollution Study Agency. 

62. Chinkin, L. R. et al., 1998, "Use of Ambient Data to Evaluate a Regional Emission lnventory in the 

San Joaquin Valley", presented at the A&WMA PM2.5: A Fine Particle Standard 

Conference, Long Beach, CA. 

63. Coe, D. L. et al., 1998, "Technical Support Study 15: Evaluation and Improvement of Methods for 

Determining Ammonia Emissions in the San Joaquin Valley Final Report", prepared by 

Sonoma Technology, Inc. for the San Joaquin Valleywide Air Pollution Study'Agency. 

64. Hackney, R. A. et at., 1998, "Meteorological Data Analysis of Surface, Upper Air, and Synoptic 

Conditions during the lntegrated Monitoring System 1995 (IMS95) Study Period, from 

November 1995 through January 1996", presented at the A&WMA PM2.5: A Fine 

Particle Standard Conference, Long Beach, CA. 

65. Hughes, V. et al., 1998, "Development of the Baseline PM-10 Emissions Inventory for Modeling 

and Data Analysis of the IMS-95 Wintertime Field Study", presented at the A&WMA 

PM2.5: A Fine Particle Standard Conference, Long Beach, CA. 

66. Hoag, K. et al., 1998, "lntegrated Monitoring Study 1995: Variations in Fog Chemistry as a 

Function of Drop Size and Their Effects on Aerosol Processing", presented at the 

A&WMA PM2.5: A Fine Particle Standard Conference, Long Beach, CA. 

67. Collett, J. L. et at., 1998, "lntegrated Monitoring Study 1995: The Effect of Internal Acid Buffering 

on Aerosol Formation in San Joaquin Valley Fogs", presented at the A&WMA PM2.5: A 

Fine Particle Standard Conference, Long Beach, CA. 

68. Schauer, J. J. et al., 1998, "Source Apportionment of Wintertime Gas-Phase and Particle-Phase 

Air Pollutants Using Organic Compounds as Tracers", presented at the A&WMA 

PM2.5: A Fine Particle Standard Conference, Long Beach, CA. 

69. Kaduwela, A. P. et al., 1998, "Numerical Simulation of Particulate Matter in the San Joaquin 

Valley: Application of UAM-AERO to the January 4-6, 1996 Winter Episode", presented 

at the A&WMA PM2.5: A Fine Particle Standard Conference, Long Beach, CA. 

70. Magliano, K. L. et al., 1998, "Chemical Mass Balance Modeling of the 1995 lntegrated Monitoring 

Study Database", presented at the A&WMA PM2.5: A Fine Particle Standard 

Conference, Long Beach, CA. 

71. Coe, D. L. et al., 1998, "The Use of a Day-Specific Source Activity Database to Augment CMB 

Source Apportionment Modeling", presented at the A&WMA PM2.5: A Fine Particle 

Standard Conference; Long Beach, CA. 

72. Kumar, N. et al., 1998, "Evaluation of Gas-Aerosol Phase Distribution of Nitrogen and Sulfur in the 

IMS95 Winter Study", presented at the A&WMA PM2.5: A Fine Particle Standard 

Conference, Long Beach, CA. 
73. Richards, L. W. et al., 1998, "1995 lntegrated Monitoring Study: Comparison of Light Scattering 

Measurements During Winter in the San Joaquin Valley", presented at the A&WMA 

PM2.5: A Fine Particle Standard Conference, Long Beach, CA. 

74. Dye, T. S. et al., 1998, "Mixing Depth Structure and Evolution Durirlg the Wintertime in the San 

Joaquin Valley as Diagnosed from Upper-Air Meteorological Data", presented at the 

A& WMA PM2.5: A Fine Particle Standard Conference, Long Beach, CA. 

75. McDade, C. et al., 1998, "Optical Properties of the San Joaquin Valley Aerosol Collected During 

the 1995 lntegrated Monitoring Study", presented at the A&WMA PM2.5 : A Fine 

Particle Standard Conference, Long Beach, CA. 

76. Solomon, P.A. et al., 1998, "Overview of the 1995 lntegrated Monitoring Study: Field Study, Data 

Analysis, and Modeling", presented at the A&WMA PM2.5: A Fine Particle Standard 

Conference,; Long Beach, CA. 

77. Collett, J. L. et al., 1998, "1995 lntegrated Monitoring Study: Measurements at Several Heights on 

a TV Tower During Fog Events in the San Joaquin Valley", presented at the A&WMA 

PM2.5: A Fine Particle Standard Conference, Long Beach, CA. 

78. Blanchard, C. L. et al., 1998, "Spatial and Temporal Variability of Particulate Concentrations and 

Composition as Measured in Four Saturation Monitoring Networks During the 1995 

lntegrated Monitoring Study in the San Joaquin Valley, California", presented at the 

A&WMA PM2.5: A Fine Particle Standard Conference, Long Beach, CA. 

79. Collett, J. L. et al., 1998, "Final Report: 1MS95 Data Analysis Work Element 4.6.8 How Does 

Acidification of Drops Due to Aqueous Phase Acid Production Limit Aerosol Formation 

in Fog Drops", prepared by Colorado State University for the San Joaquin Valleywide 

Air Pollution Study Agency. 

80. Collett, J. L. et al., 1998, "Final Report: IMS95 Data Analysis Work Element 4.6.7 The Influence of 

Drop Size-Dependent Fog Chemistry on Aerosol Production and Deposition in San 

Joaquin Valley Fogs", prepared by Colorado State University for the San Joaquin 

Valleywide Air Pollution Study Agency. 

81. Lehrman, D. E. et al., 1998, "Final Report California Regional PMlOlPM2.5 Air Quality Study 

(CRPAQS) 1995 lntegrated Monitoring Study Data Analysis Work Element 2.2.2 - 

Meteorological Representativeness and Work Element 2.2.3 - Fog And Low Clouds 

Characteristics", prepared by Technical & Business Systems, Inc. for the San Joaquin 

Valleywide Air Pollution Study Agency. 

82. Strader, R. et al., 1998, "Final Report 1995 lntegrated Monitoring Study Data Analysis 6.5 

Evaluation of Secondary Organic Aerosol Formation in Winter", prepared by Carnegie 

Mellon University for the San Joaquin Valleywide Air Pollution Study Agency. 

83. Pandis, S. et al., 1998, "Final Report 1995 lntegrated Monitoring Study Data Analysis Fog Effects 

on PM Concentration and Composition in the SJV", prepared by Carnegie Mellon 

University for the San Joaquin Valleywide Air Pollution Study Agency. 
84. Blanchard, C. L. et al., 1998, "Final Report for Tasks 4.2.1 and 4.5.6 Spatial Representativeness 

of Monitoring Sites and Zones of Influence of Emission Sources", prepared by Envair 

for the San Joaquin Valleywide Air Pollution Study Agency. 

85. Magliano, K. L. et al., 1998, "Final Report Chemical Mass Balance Modeling of Data from the 1995 

lntegrated Monitoring Study", prepared by the California Air Resources Board for the 

San Joaquin Valleywide Air Pollution Study Agency. 

86. Carr, E. L. et al., 1998, "Final Report San Joaquin Valley Regional PM-10 Study Characterizing 

Micrometeorological Phenomena: Mixing and Diffusion in Low Wind Speed Conditions 

Phase Ill: Monitoring and Data Analysis", prepared by Systems Applications 

International for the San Joaquin Valleywide Air Pollution Study Agency. 

87. Dye, T. S. et al., 1998, "Measurement Methods Validation: Adequacy and Validation of 

Meteorological Measurements Aloft During IMS9513, prepared by Sonoma Technology, 

Inc. for the San Joaquin Valleywide Air Pollution Study Agency. 

88. Coe, D. L. et al., 1998, "Emission Source Activity Detection: Analysis of CMB Model Results and 

Daily Activity Data for IMS95", prepared by Sonoma Technology, Inc. for the San 

Joaquin Valleywide Air Pollution Study Agency. 

89. Main, H. H. et al., 1998, "Characterization of the Spatial and Temporal Patterns of Visibility in the 

San Joaquin Valley During IMS95, prepared by Sonoma Technology, Inc, for the San 

Joaquin Valleywide Air Pollution Study Agency. 

90. Carr, E. L. et al., 1998, "1995 lntegrated Monitoring Study Data Analysis Work Element 4.6.3: 

Time and Length Scales for Mixing of Secondary Aerosols During Stagnation Periods1', 

prepared by Systems Applications International for the San Joaquin Valleywide Air 

Pollution Study Agency. 

91. Collins, J. F., 1998, "Characterization of Boundaries and Backgrounds in the San Joaquin Valley 

lntegrated Monitoring Study 1995", prepared by University of California Riverside CECERT for the San Joaquin Valleywide Air Pollution Study Agency. 

92. Haste, T. L. et al., 1998, "Use of Ambient Data Collected During IMS95 to Evaluate a Regional 

Emissions Inventory for the San Joaquin Valley", prepared by Sonoma Technology Inc. 

for the San Joaquin Valleywide Air Pollution Study Agency. 

93. Kumar, N., et al., 1998, "Analysis of Atmospheric Chemistry During 1995 lntegrated Monitoring 

Study", prepared by Sonoma Technology, Inc. for the San Joaquin Valleywide Air 

Pollution Study Agency. 

94.. Magliano, K. L., et al., 1998, "Draft Modeling Protocol for the California Regional PMIO/PIbl2.5 Air 

Quality Study: Preliminary Approaches and Data Requirements", prepared by the 

California Air Resources Board for the San Joaquin Valleywide Air Pollution Study 

Agency. 

95. Pun, B. et al., 1998, "Comments on Field Program Plan for the California Regional PMlOlPM2.5 

Air Quality Study", prepared by Atmospheric and Environmental Research for Pacific 

Gas & Electric. 
96. Pun, B. et al., 1998, "Phase II Reports lntegrated Monitoring Study 95: Assessment of 

Mathematical Models and Associated Data Needs", prepared by Atmospheric and 

Environmental Research for Pacific Gas & Electric. 

97. Pun, B- et al., 1998, "Conceptual Model of Particulate Matter Pollution in'the California San 

Joaquin Valley", prepared by Atmospheric and Environmental Research for Pacific Gas 

& Electric. 

98. Richards, W. L. et al., 1998, "Characterization of the Validity of Light Scattering Measurements 

During the 1995 lntegrated Monitoring Study", prepared by Sonoma Technology Inc. 

for the San Joaquin Valleywide Air Pollution Study Agency. 

99. Schauer, J. J. et al., 1998, "Source Contributions to Airborne Particles in the San Joaquin Valley 

During the IMS95 Study", prepared by California Institute of Technology for the San 

Joaquin Valleywide Air Pollution Study Agency. 

100. Seinfeld, J. H. et al., 1998, "Grid-Based Aerosol Modeling: A Tutorial", prepared by California 

lnstitute of Technology for the San Joaquin Valleywide Air Pollution Study Agency. 

101. Watson, J. G. et al., 1998, "Aerometric Field Program Plan for the California Regional 

PM2.5lPM10 Air Quality Study", prepared by Desert Research lnstitute for the San 

Joaquin Valleywide Air Pollution Study Agency. 

102. Wilkinson, J. G., et al., 1998, "A Model to Estimate Temporally Resolved Ammonia Emissions 

at a Dairy", presented at the A&WMA 9IS'Annual Meeting, San Diego, CA. 

103. Richards, W. L. et al., 1999, "Effects of Atmospheric Dynamics and Chemical Concentrations 

on Aerosol Formation in Fog " prepared by Sonoma Technology, Inc. for the San 

Joaquin Valleywide Air Pollution Study Agency. 

104. Magliano, K. L. et al., 1999, "California Regional PMlOlPM2.5 Air Quality Study: Objectives 

and Associated Data Analysis and Modeling Approaches", prepared by the California 

Air Resources Board for the San Joaquin Valleywide Air Pollution Study Agency. 

105. Chow, J.C. et al., 1999, "Temporal Variations of PM2.5, PM10, and Gaseous Precursors 

During the 1995 lntegrated Monitoring Study in Central California", Atmospheric 

Environment (33). 

106. Collett, J. L. et al., 1999, "Spatial and Temporal Variations in San Joaquin Valley Fog 

Chemistry", Atmospheric Environment (33). 

107. Magliano, K. L. et al., 1999, "Recommendations for Emissions Work in Support of the 

California Regional PMI 0lPM2.5 Air Quality Study", prepared by the California Air 

Resources Board for the San Joaquin Valleywide Air Pollution Study Agency. 

108. Solomon, P. A. et al., 1999, "The 1995 lntegrated Monitoring Study (IMS95) of the California 

Regional PMlOlPM2.5 Air Quality Study (CRPAQS): Study Overview", Atmospheric 

Environment (33). 
Solomon, P. A. et at., 1999, "Objectives and Design of Central California's 1995 lntegrated 

Monitoring Study of the California Regional PM10lPM2.5 Air Quality Study", Journal 

A&WMA. 

Magliano, K. L. et al., 1999, "Spatial and Temporal Variations in PM10 and PM2.5 Source 

Contributions and Comparison to Emissions During the 1995 lntegrated Monitoring 

Study", Atmospheric Environment (33). 

Lehrman, D. E., et al., 1999, "Assessment of the Methods and Adequacy of Meteorology 

Measurements for IMS95", Atmospheric Environment (33). 

McDade, C. et al., 1999, "Optical Properties of the San Joaquin Valley Aerosol Collected 

During the 1995 lntegrated Monitoring Study", Atmospheric Environment (33). 

Blanchard, C. L. et al., 1999, "Spatial Scales of Transport and Influence During the 1995 

lntegrated Monitoring Study in California's San Joaquin Valley", Atmospheric 

Environment (33). 

Lillis, D. et al., 1999, "Production and Removal of Aerosol in a Polluted Fog Layer - Part I 

Model Development and Evaluation", Atmospheric Environment (33). 

Lillis, D. et al., 1999, "Production and Removal of Aerosol in a Polluted Fog Layer - Part II 

Effects of Fogs on PM in the San Joaquin Valley", Atmospheric Environment (33). 

Collett, J. L. et al., 1999, "Internal Acid Buffering in San Joaquin Valley Fog Drops and its 

Influence on Aerosol Processing", Atmospheric Environment (33). 

Hoag, K, J., et al., 1999, "The Influence of Drop Size-Dependent Fog Chemistry on Aerosol 

Processing by San Joaquin Valley Fogs", Atmospheric Environment (33). 

Strader, R. et al., 1999, "Evaluation of Secondary Organic Aerosol Formation in Winter", 

Atmospheric Environment (33). 

Pun, B. et al., 1999, "Understanding Particulate Matter Formation in the California San Joaquin 

Valley: Conceptual Model and Data Needs", Atmospheric Environment (33). 

Magliano, K. L. et al., 1999, "Field Program Plans for the California Regional PMlOlPM2.5 Air 

Quality Study", in Proceedings of the A&WMA 9znd Annual Meeting. 

Wittig, A. E. et al., 1999, "Health and Safety Plan for the California Regional PMlOlPM2.5 Air 

Quality Study (CRPAQS)", prepared by Sonoma Technology Inc. for the San Joaquin 

Valleywide Air Pollution Study Agency, STI-999215-1894-HASP. 

Magliano, K.L. et al, 2000, "Coordinated Efforts of the California Regional PMlOlPM2.5 Air 

Quality Study and the U.S. Environmental Protection Agency Supersite in Fresno, 

California", in Proceedings of the 9? Annual A&WMA Conference, Salt Lake City, UT, 

June 19-24, 2000. 

Magliano, K. L. et at., 2000, "Light Scattering Measurements in the California Regional 

PM10lPM2.5 Air Quality Study", In Proceedings of the 93rd Annual A&WMA 

Conference, Salt Lake City, UT, June 19-24, 2000. 
Schauer, J. J. et al., 2000, "Source Apportionment of Wintertime Gas-Phase and ParticlePhase Air Pollutants Using Organic Compounds as Tracers", Environmental Science 

and Technology (34), 1821 -1 832. 

Blanchard, C. L. et al. 2000, "The Use of Ambient Measurements to Identify Which Precursor 

Species Limit Aerosol Nitrate Formation", Journal of the Air and Waste Management 

Association (50), 2073-2084. 

Wittig, A. E. et al., 2000, "Quality Integrated Workplan for the Continuous and Filter Air Quality 

Measurements in the California Reqional PM10lPM2.5 Air Quality Study (CRPAQS)", 

prepared by Sonoma Technology Inc. for the San Joaquin Valleywide Air Pollution 

Study Agency, 81-1-999214-1921 -QIWP. 

Flocchini, R. G. et al., 2001, "Sources and Sinks of PMIO in the San Joaquin Valley", Interim 

Report to U.S. Department of Agriculture, Contract Nos. 94-33825-0383 and 98-38825- 

6063, prepared by University of California Davis. 

Main, H. et al. 2001, "Managing Data from the California Regional PMlOlPM2.5 Air Quality 

Study", in Proceedings of the A&WMNAGU Regional Haze and Global Radiation 

Balance Conference, Bend, OR, October 2-5, 2001. 

Magliano, K.L. et al., 2001, "The California Regional PMlOlPM2.5 Air Quality Study 

(CRPAQS): Field Study Description and Initial Findings1', in Proceedings of the 

A&WMNAGU Regional Haze and Global Radiation Balance Conference, Bend, OR, 

October 2-5, 2001. 

Richards, L.W. et al., 2001, "Light Scattering Measurements During the California Regional 

PMlOlPM2.5 Air Quality Study", in Proceedings of the A&WMA/AGU Regional Haze 

and Global Radiation Balance Conference, Bend, OR, October 2-5, 2001. 

Watson, J. G. et al., 2001, "Comparison of Nephelometer Light Scattering Measurements in 

Central California as a Function of Meteorological Variables Particle Size, and Particle 

Composition", in Proceedings of the A&WMA/AGU Regional Haze and Global 

Radiation Balance Conference, Bend, OR, October 2-5, 2001. 

Chow, J. C. et al., 2001, "Particle Nitrate Measurements at the Fresno Supersite", in 

Proceedings of the A&WMA/AGU Regional Haze and Global Radiation Balance 

Conference, Bend, OR, October 2-5, 2001. 

Lowenthal, D. H. et al., 2001, "Particle Size Relationships at the Fresno Supersite", in 

Proceedings of the A&WMA/AGU Regional Haze and Global Radiation Balance 

Conference, Bend, OR, October 2-5, 2001. 

Pun B. K, et al., 2001; "Sensitivity of Particulate Matter Nitrate Formation to Precursor 

Emissions in the California San Joaquin Valley"; Environmental Science and 

Technology; (35), 2979-2987. 

Watson, J.G. et al., 2001, "Comparison and Evaluation of In-Situ And Filter Carbon 

Measurements at the Fresno Supersite", Journal of Geophysical Research - 

Atmospheres". 
136. Rappolt, T.J. et al., 2001, "Mapping Air Quality Plumes from Fossil Energy Sources to Assess 

the Impacts of Secondary Aerosol Development", presented at the SPE/EPA/DOE 

Exploration and Production Environmental Conference, San Antonio, TX, February 

2001. 

137. Funk, T. et. al., 2001, "Development of Gridded Spatial Allocation Factors for the State of 

California", prepared by Sonoma Technology Inc. for the San Joaquin Valleywide Air 

Pollution Study Agency. 

138. Knuth, W. et al., 2001, "Fall Saturation Network - An Element of the Satellite Network 

Operations for the CRPAQS", prepared by Technical & Business Systems Inc. for the 

San Joaquin Valleywide Air Pollution Study Agency. 

139. Knoderer, C, et. al., 2001, "Data Collected by a 915-MHz Radar Wind Profiler, RASS, and 

Surface Meteorological Station at San Martin, California During Fall 2000 and Winter 

2001 for the California Regional PMlOlPM2.5 Air Quality Study (CRPAQS)", prepared 

by Sonoma Technology Inc. for the San Joaquin Valleywide Air Pollution Study 

Agency. 

140. Chung, A. et. al, 2001, "Detection of Alkaline Ultrafine Atmospheric Particles at Bakersfield, 

California, Environmental Science Technology, (35), 21 84-21 90. 

141. Bush, D. et al., 2002, "An Evaluation of Portable Nephelometer Performance During 

CRPAQS", presented at A&WMA Symposium on Air Quality Measurement Methods 

and Technology, November 13-1 5, 2002. 

142. Watson, J. G. et al., 2002, "Air Quality Measurements from the Fresno Supersite", Journal of 

the Air and Waste Management Association, (50), 1 321 -1 334. 

143. Watson, J. G. et al., 2002, "A Wintertime PM2.5 Episode at the Fresno, CA, Supersite", 

Atmospheric Environment (36), 465-475. 

144. Watson, J.G., 2002, "Particle Size Relationships at the Fresno Supersite", Journal of the Air 

and Waste Management Association, (52), 822-827 

145. Herckes, P. et al., 2002, "Organic Matter in Central California Radiation Fogs", Environmental 

Science & Technology, (36), 4777-4782. 

146. Hyslop, N. et. al., 2002, "Continuous PM Measurements in a Rural Town in the San Joaquin 

Valley", presented at A&WMA Symposium on Air Quality Measurement Methods and 

Technology, November 1 3-1 5,2002. 

147. Holmen 8. A. et al., 2002, "Lidar-Assisted Measurement of PMIO Emissions from Agricultural 

Tilling in California's San Joaquin Valley - Part I: Lidar", Atmospheric Environment 

(35), 3251 -3264. 

148. Holmen B. A. et al., 2002, "Lidar-Assisted Measurement of PMIO Emissions from Agricultural 

Tilling in California's San Joaquin Valley - Part II: Emission Factors", Atmospheric 

Environment, (35), 3265-3277. 
Technical & Business Systems Inc., 2002, "Satellite Network Operations for the California 

Regional PMlOlPM2.5 Air Quality Study1', prepared by Technical & Business Systems 

Inc. for the San Joaquin Valleywide Air Pollution Study Agency. 

Bush, D. et. al., 2002, "Final Quality Assurance Audit Report California Regional PM10lPM2.5 

Air Quality Study", prepared by Parsons Engineering Science for the San Joaquin 

Valleywide Air Pollution Study Agency. 

Stiefer, P. et al., 2002, "Atlas of Ground Truth Surveys", prepared by Sonoma Technology Inc. 

for the San Joaquin Valleywide Air Pollution Study Agency. 

Engelbrecht, J. P., 2002, "Laboratory Measurement Systems Audit", prepared by Desert 

Research Institute for the San Joaquin Valleywide Air Pollution Study Agency. 

Countess Environmental, 2002, "Quantifying the Contribution of Fugitive Geological Dust to 

Ambient PMI 0 and PM2.5 Concentrations in the San Joaquin Valley", prepared for the 

San Joaquin Valley Air Pollution Control District. 

Whiteaker, J.R., 2002, "Effects of Meteorological Conditions on Aerosol Composition and 

Mixing State in Bakersfield CAI Environmental Science and Technology, (36), 2345- 

2353. 

Ashbaugh, L.L. et al., 2003, "Soil Sample Collection and Analysis for the Fugitive Dust 

Characterization Study", Atmospheric Environment, (37)) 1 163-1 173. 

Chow, J.C. et al., 2003, "Similarities and Differences in PMIO Chemical Source Profiles for 

Geological Dust From the San Joaquin Valley, California", Atmospheric Environment, 

(37), 1317-1340. 

Rinehart, L.R. et al., 2003, "Characterization of PM2.5 Associated Organic Compounds of 

Emission Sources Collected During the California Regional PMlOlPM2.5 Air Quality 

Study", in Proceedings of the 96th Annual A&WMA Conference, San Diego, CA, June 

2003. 

Najita, T. et al., 2003, "Relationship Between PM2.5 and PMIO During the California Reqional 

Particulate Air Quality StudyJ1, presented at the 2003 Annual Conference of the 

American Association for Aerosol Research, Anaheim, CA, October 20-24,2003. 

Velasco, P. et al., 2003, "Diurnal Variations in PM2.5, PMIO, Chemical Components, Gaseous 

Precursors, and Co-Pollutants during the California Regional Particulate Air Quality 

Study1', presented at the 2003 Annual Conference of the American Association for 

Aerosol Research, Anaheim, CA, October 20-24, 2003. 

Turkiewicz, K. et al., 2003, "Spatial and Temporal Variations of PM2.5, PM10, and their 

Chemical Components during the California Regional Particulate Air Quality Study", 

presented at the 2003 Annual Conference of the American Association for Aerosol 

Research, Anaheim, CA, October 20-24, 2003. 

Casuccio, G. et al., 2003, "Characterization of San Joaquin Valley Samples Using Scanning 

Electron Microscopy (SEM) Techniques", presented at the 2003 Annual Conference of 

the American Association for Aerosol Research, Anaheim, CA, October 20-24,2003. 
Chow, J. C. et al., 2003, "Spatial and Temporal Variations in PM2.5 Chemical Composition 

during Winter, 200012001 Episodes in Central California", presented at the 2003 

Annual Conference of the American Association for Aerosol Research, Anaheim, CA, 

October 20-24, 2003. 

Watson, J., et al., 2003, "Equivalence and Comparability Among Different PM2.5 Mass 

Measurements in Central California", presented at the 2003 Annual Conference of the 

American Association for Aerosol Research, Anaheim, CA, October 20-24, 2003. 

Countess, R. et. al. 2003, "Fugitive Dust Concentrations in the San Joaquin Valley", presented 

at the 2003 Annual Conference of the American Association for Aerosol Research, 

Anaheim, CA, October 20-24,2003. 

Herckes, P. et. al., 2003, '!Fog Processing of Atmospheric Organic Compounds During the 

California Regional PMI 01PM2.5 Air Quality Study (CRPAQS)", presented at the 2003 

Annual Conference of the American Association for Aerosol Research, Anaheim, CA, 

October 20-24, 2003. 

McDonald, C. et. al., 2003, "Evaluation of Transport of Particulate Matter and Its Precursors 

Into and Out of the San Joaquin Valley, California, Using Two Approaches presented 

at the 2003 Annual Conference of the American Association for Aerosol Research, 

Anaheim, CA, October 20-24, 2003. 

Kleeman, M, et. al., 2003, "Characterization of Atmospheric Nano-Fine Particles at Bakersfield 

California", presented at the 2003 Annual Conference of the American Association for 

Aerosol Research, Anaheim, CA, October 20-24, 2003. 

Kleeman, M. et. al., 2003, "Simulating Air Quality in the San Joaquin Valley with a SourceOriented Externally Mixed Airshed Model; Evaluation of Model Performance and 

Control Strategy Effectiveness", presented at the 2003 Annual Conference of the 

American Association for Aerosol Research, Anaheim, CA, October 20-24, 2003. 

Heissler, S. 2003, "Contributions of Chemical Constituents to Visibility Reduction during the 

California Regional PMlOlPM2.5 Air Quality Study", presented at the 2003 Annual 

Conference of the American Association for Aerosol Research, Anaheim, CA, October 

20-24, 2003. 

Countess, R. et. al., 2003, "Contribution of Vegetative Burning to PM2.5 Concentrations in the 

San Joaquin Valley", presented at the 2003 Annual Conference of the American 

Association for Aerosol Research, Anaheim, CA, October 20-24, 2003. 

Rappolt, T.J. et. al., 2003, "Near-Term and Low Wind Dispersion Measurements of Plumes 

from Steam Generators during the CRPAQS presented at the 2003 Annual Conference 

of the American Association for Aerosol Research, Anaheim, CA, October 20-24, 2003. 

Alcorn, S. et. at., 2003, "Comparisons Between California Regional PMlOlPM2.5 Air Quality 

Study (CRPAQS) Particle Light Scattering and Fine Particle Mass Data1', presented at 

the 2003 Annual Conference of the American Association for Aerosol Research, 

Anaheim, CA, October 20-24, 2003. 
Chen, A. et. al., 2003, "Evaluating Similarities of Source Profiles Using Pair Slope Distribution 

(PSD) Method: Applications to PM2.5 Source Profiles from the BRAVO and CRPAQS 

Studies", presented at the 2003 Annual Conference of the American Association for 

Aerosol Research, Anaheim, CA, October 20-24, 2003. 

Hyslop, N. et. al., 2003, "Vertical Variations in PM and PM Precursor Concentrations in the 

San Joaquin Valley, California", presented at the 2003 Annual Conference of the 

American Association for Aerosol Research, Anaheim, CA, October 20-24, 2003. 

Chang, et. al., 2003, "Aerosol Processing and Removal by Fogs: Observations in Radiation 

Fogs During the CRPAQS Study", presented at the 2003 Annual Conference of the 

American Association for Aerosol Research, Anaheim, CA, October 20-24, 2003. 

Chin, et. al., 2003, "Comparison Between Particulate Matter Sampled at Urban and Rural 

Locations in the San Joaquin Valley: Continuous Measurement of Single Particle Size 

and Composition", presented at the 2003 Annual Conference of the American 

Association for Aerosol Research, Anaheim, CA, October 20-24., 2003. 

Rinehart, L. et. al., 2003, "Semi-volatile Organic Compound Characterization and Evaluation of 

PM2.5 Emission Sources Collected During the California Regional PM101PM2.5 Air 

Quality Study", presented at the 2003 Annual Conference of the American Association 

for Aerosol Research, Anaheim, CA, October 20-24, 2003. 

Hering, S. et. al., 2003, "Temporal and Spatial Distribution of Fine Particle Nitrate and Black 

Carbon in the San Joaquin Valley of California, USA", presented at the 2003 Annual 

Conference of the American Association for Aerosol Research, Anaheim, CA, October 

20-24. 2003. 

Scow, K. M. et al., 2003, "DNA Profiling Analysis of Dust and Source Material Collected in the 

CRPAQS Fall 2000 Sampling Campaign", prepared by the University of California, 

Davis for the San Joaquin Valleywide Air Pollution Study Agency. 

Hafner, H. R., et. al., 2003, "California Reqional PMlOlPM2.5 Air Quality Study (CRPAQS) 

Management of Anchor Site Data", prepared by Sonoma Technology Inc for the San 

Joaquin Valleywide Air Pollution Study Agency, STI-999242-2087-FR. 

Wittig, A.E., et. al., 2003, "California Regional PMlOlPM2.5 Air Quality Study (CRPAQS) 

Anchor Site Measurements and Operations", prepared by Sonoma Technology Inc for 

the San Joaquin Valleywide Air Pollution Study Agency, STI-999231-2332-FR. 

Hyslop, N. P., et. al., 2003, "California Regional PMlOlPM2.5 Air Quality Study (CRPAQS) 

Data Quality Summary Reports", prepared by Sonoma Technology Inc for the San 

Joaquin Valleywide Air Pollution Study Agency, SPI-999242-2310-FR. 

Neff, W.D., et. al., 2003, "Final Report Contract 99-4PM A Study of Mesoscale Transport and 

Boundary Layer Processes in the Central Valley of California", prepared by the 

National Oceanic and Atmospheric Administration for the San Joaquin Valleywide Air 

Pollution Study Agency. 
Zielinska, B. et. al., 2003, "California Regional PM10/PM2.5 Air Quality Study - Organic 

Compound Measurements", prepared by Desert Research Institute for the San Joaquin 

Valleywide Air Pollution Study Agency. 

Ervens, B. et. al., 2003, "On the Drop-Size Dependence of Organic Acid and Formaldehyde 

Concentrations in Fog", Journal of Atmospheric Chemistry, (46), 239-269. 

Whiteaker, J.R., 2003, "Hydroxymethanesulfonate as a Tracer for Fog Processing of Individual 

Aerosol Particles", Atmospheric Environment, (37), 1033-1 043. 

Fitz, D. et. al., 2004, "Development of a Gas and Particulate Matter Organic Speciation Profile 

Database", prepared by the University of California, Riverside Center for 

Environmental Engineering and Technology for the San Joaquin Valleywide Air 

Pollution Study Agency. 

Prather, K., 2004, ATOFMS Field Study Operations Final Report, prepared by the University of 

California, San Diego, Prather Research Group for the San Joaquin Valleywide Air 

Pollution Study Agency. 

Chow, J.C. et. al., 2004, "Comparison of PM2.5 Chemical Composition from the Fresno 

Supersite During Wintertime Pollution Episodes in Central California", presented at the 

13'~ World Clean Air and Environmental Protection Congress and Exhibition, London 

England, August 2004. 

Watson, J.G. et. al., 2004, "Particle Nitrate Sampling Artifacts in California's San Joaquin 

Valley", presented at the 13'~ World Clean Air and Environmental Protection Congress 

and Exhibition, London England, August 2004. 

DeYoung, R.J. et. al., 2004, "Aerosol Transport in the California Central Valley Observed by 

Airborne Lidar" 

Collett, J.L. et. al., 2004, "The Organic Composition of California Fogs", submitted to the 3rd 

lnternational Conference on Fog and Fog Collection, Capetown, South Africa, October 

2004. 

Carillo, J.H. et. al., 2004, "An Economical Optical Fog Detector", submitted to the 3rd 

lnternational Conference on Fog and Fog Collection, Capetown, South Africa, October 

2004. 

Hyslop, N.P., et. al., 2004, "Exploratory Data Analysis of Particulate Matter Concentrations in 

Corcoran, California", prepared by Sonoma Technology, Inc, for the San Joaquin 

Valleywide Air Pollution Study Agency, S-TI-999300-2485-FR. 

Bahm, K.E. et. al., 2004, "Detecting Source Activities and Reconciling Ambient Measurement 

Variations with Field Observations - California Regional PlbllO and PM2.5 Air Quality 

Study (CRPAQS) Data Analysis Task 4.3", prepared for the San Joaquin Valleywide 

Air Pollution Study Agency by Sonoma Technology Inc., S-TI-902328-2579-TM. 

Baxter, B. et. al., 2004, "Task 1.3 Adequacy and Validity of Meteorological Measurements", 

prepared by Technical & Business Systems for the San Joaquin Valleywide Air 

Pollution Study Agency. 
Lehrman D. et. al., 2004, "Task 3.3 How Well Do Measurements Characterize Critical 

Meteorological Features", prepared by Technical & Business Systems for the San 

Joaquin Valleywide Air Pollution Study Agency. 

Knuth, B., 2004, "Task 5.1 CRPAQS Synoptic Conditions Weather Typing", prepared by 

Technical & Business Systems for the San Joaquin Valleywide Air Pollution Study 

Agency. 

Held, T. et. al., 2004, "Modeling Particulate Matter in the San Joaquin Valley with a SourceOriented Externally Mixed'Three-Dimensional Photochemical Grid Model: Atmospheric 

Environment, 38(22), 3689-371 1. 

Heisler, S. L, 2004, "Contributions of Chemical Constituents to Visibility Reduction During the 

California Regional PMIO/PM2.5 Air Quality Study", prepared by ENSR Corporation for 

the San Joaquin Valleywide Air Pollution Study Agency. 

Tracer ES&T, 2004, "California Regional PMlOlPM2.5 Air Quality Study (CRPAQS) Initial Data 

Analysis of Clean Airship 1 Measurements (Task 6.4)", prepared by Tracer 

Environmental Sciences & Technologies, Inc., for the San Joaquin Valleywide Air 

Pollution Study Agency. 

Buhr, M.P. et. al., 2004, Examination of Reactive Nitrogen Partitioning at the Bakersfield and 

Angiola Field Sites", prepared by Sonoma Technology Inc, for the San Joaquin 

Valleywide Air Pollution Study Agency. 

Buhr, M.P. et. al., 2004, "comparison and Descriptive Evaluation of the Airborne and GroundBased Measurements Collected During the CCOS Field Experiment", prepared by 

Sonoma Technology Inc. for the San Joaquin Valleywide Air Pollution Study Agency. 

Yoho, D. et. al., 2004, "How is Visibility Affected by Atmospheric Constituents, Sources, and 

Meteorology - Sources of Light Extinction in the Mojave Desert", prepared by 

Technical & Business Systems for the San Joaquin Valleywide Air Pollution Study 

Agency. 

Alcorn, S.A. et. al., 2004, "Comparisons Between Light Scattering and Fine-Particle Mass 

Data", prepared by Sonoma Technology Inc. for the San Joaquin Valleywide Air 

Pollution Study Agency. 

Pun, B., 2004, "CRPAQS Task 2.7 When and Where Does High 03 Correspond to High 

PM2.5? How Much PM2.5 Corresponds to Photochemical End Products?", prepared 

by Atmospheric and Environmental Research, Inc. for the San Joaquin Valleywide Air 

. Pollution Study Agency. 

Collett, J. L. et. al., 2005, "Examination of the influence of California Regional Particuiate Air 

Quality Study Fog Episodes on Aerosol Formation and Removal", prepared by 

Colorado State University for the San Joaquin Valleywide Air Pollution Study Agency. 

Raffuse, S. M. et. al., 2005, "Emission Inventory Reconciliation in the San Joaquin Valley", 

prepared by Sonoma Technology Inc. for the San Joaquin Valleywide Air Pollution 

Study Agency. 
Held, T, et. al., 2005, "A Comparison of the UCDlClT Air Quality Model and the CMB SourceReceptor Model for Primary Airborne Particulate Matter", Atmospheric Environment, 

(39), 2281 -2297. 

Kleeman, M.J., Ying, Q., Kaduwela, A. 2005. "Control Strategies for the Reduction of Airborne 

Particulate Nitrate in California's San Joaquin Valley". Atmospheric Environment, (39): 

5325-5341. 

Fahey, K.M., Pandis, S.N., Collett, Jr. J.L., Herckes, P. 2005. "The influence of sizedependent droplet composition on pollutant processing by fogs1'. Atmospheric 

Environment, (39): 4561 -4574. 

Blanchard, C., 2005, "Comparison of Particulate Nitrate Formation in Different Chemical 

Regimes", presented at the American Association for Aerosol Research (AAAR), 

Supersites Conference, February 2005, Atlanta, GA. 

Cahill, T., 2005, "Continuous Analysis of Fresno Aerosols by Size, Time, and Elemental 

Concentrations, March - December 200In, presented at the American Association for 

Aerosol Research (AAAR), Supersites Conference, February 2005, Atlanta, GA. 

Collett, J., 2005, "Pollution Processing by Radiation Fogs During the California Regional 

PMlOlPM2.5 Air Quality Study (CRPAQS)", presented at the American Association for 

Aerosol Research (AAAR), Supersites Conference, February 2005, Atlanta, GA. 

Goohs, K., 2005, "Function and Performance of a New Real-Time Black Carbon Monitor 

During the 2004 Fresno Study", presented at the American Association for Aerosol 

Research (AAAR), Supersites Conference, February 2005, Atlanta, GA. 

Herckes, P., 2005, "Fog Processing of Atmospheric Organic Matter", presented at the 

American Association for Aerosol Research (AAAR), Supersites Conference, February 

2005, Atlanta, GA. 

Lurmann, F., 2005, "Spatial Representativeness of the Fresno Supersite PM and Gaseous CoPollutant Measurements", presented at the American Association for Aerosol Research 

(AAAR), Supersites Conference, February 2005, Atlanta, GA. 

Magliano, K., 2005, "Comparison of Air Quality During Two Winter Episodes", presented at the 

American Association for Aerosol Research (AAAR), Supersites Conference, February 

2005, Atlanta, GA. 

M'agliano, K., 2005, "PM2.5 Concentrations in Urban and Rural Areas", presented at the 

American Association for Aerosol Research (AAAR), Supersites Conference, February 

2005, Atlanta, GA. 

McCarthy, M., 2005, "The Role of Nighttime Chemistry in Winter Ammonium Nitrate Formation 

in the San Joaquin Valley", presented at the American Association for Aerosol 

Research (AAAR), Supersites Conference, February 2005, Atlanta, GA. 
221. Pun, B., 2005, "Relationships Between Ozone and PM During CRPAQS", presented at the 

American Association for Aerosol Research (AAAR), Supersites Conference, February 

2005, Atlanta, GA. 

222. Qin, X., 2005, "ATOFMS Measurements at Urban and Rural Locations: Comparison of Single 

Particle Size and Composition", presented at the American Association for Aerosol 

Research (AAAR), Supersites Conference, February 2005, Atlanta, GA. 

223. Watson, J., 2005, "Spatial Variability of PM2.5 Species in the California Central Valley", 

presented at the American Association for Aerosol Research (AAAR), Supersites 

Conference, February 2005, Atlanta, GA. 

224. Zielinska, B., 2005, "Semi-volatile Organic Compounds: Characterization at the Fresno 

Supersite During Wintertime Stagnation Episodes", presented at the American 

Association for Aerosol Research (AAAR), Supersites Conference, February 2005, 

Atlanta, GA. 

225. Cassucio, G., 2005, "Corcoran Fall 2000 study: Apportionment of ambient PMIO using 

scanning electron microscopy", presented at the American Association for Aerosol 

Research (AAAR), Supersites Conference, February 2005, Atlanta, GA. 

226. Chow, J., 2005, "Particulate carbon measurements in California's San Joaquin Valley", 

presented at the American Association for Aerosol Research (AAAR), Supersites 

Conference, February 2005, Atlanta, GA. 

227. Chow, J.C., 2005, "Loss of PM2.5 Nitrate from Filter Samples in Central California", Journal of 

the Air and Waste Management Association, (55) 1 1 58-1 168. 

228. Watson, J.G., et. al., 2005, "Nanoparticle and IJltrafine Particle Events at the Fresno 

Supersite". Journal of the Air & Waste Management Association, (56) 4.1 7-430. 

229. Gorin, C.A., et. al., 2005, "Wood Smoke Contributions to Ambient Aerosol in Fresno During 

Winter 2003-2004". Prepared for the San Joaquin Valley Air Pollution Control District. 

Fresno, California. 

230. Park, K., et. at., 2005, "Comparison of continuous and filter-based carbon measurements at 

the Fresno Supersite". Journal of the Air & Waste Management Association, (56) 474- 

491. 

231. Herner, J.D., et. al., 2005, "Size and Composition Distribution of Airborne Particulate Matter in 

Northern California 1. Particulate Mass, Carbon, and Water Soluble Ions", Journal of 

the Air & Waste Management Association, (55), 30-51. 

232. Turkiewicz, K., et. al., 2006, "Comparison of Two Winter Air Quality Episodes During the 

California Regional Particulate Air Quality Study". Journal of the Air & Waste 

Management Association (56): 467-473. 

233. Rinehart, L.R., et. al., 2006, "Spatial Distribution of PM2.5 Associated Organic Compounds in 

Central California". Atmospheric Environment (40): 290-303. 
Chow, J.C., Watson, J.G., Park, K., Lowenthal, D.H., Robinson, N.F., Magliano, K.L., 2006. 

"Comparison of Particle Light Scattering and PM2.5 Mass in Central California". 

Journal of the Air & Waste Management Association (56): 398-41 0. 

Chow, J.C., Watson, J.G., Lowenthal, D.H., Chen, A.L-W., Magliano, K.L., 2006. "Particulate 

Carbon Measurements in California's San Joaquin Valley". Chemosphere (62): 337- 

348. 

Chow, J.C., Chen, A.L-W., Watson, J.G., Lowenthal, D.H., Magliano, K.L., Turkiewicz, K., 

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226. 
ATTACHMENT B 

Excerpts from: 

Federal Register / Vol. 69, No. 102 / Wednesday, May 26, 2004 / Rules and 

Regulations 

, 40 CFR Part 52 

Approval and Promulgation of Implementation Plans for California San 

Joaquin Valley PM-10 Nonattainment 

Area; Serious Area Plan for Attainment of 

the 24-Hour and Annual PM-10 

Standards; Final Rule 

II. Public Comments and EPA Responses 

A. NOWPM Strategy 

The Plan relies on an oxides of nitrogen (NOX)/PM strategy as the most effective 

and expeditious strategy for attaining the PM-10 standards in the SJV, based on 

the best available information at this time. The California Air Resources Board 

(CARB) and the SJVUAPCD have examined the effects of controlling ammonia, 

volatile organic compo~lnds (VOC) and oxides of sulfur (SOX), and have 

determined that the effect of controls for ammonia is uncertain, the effect of 

additional VOC controls will not lead to PM-10 reductions throughout the SJV, 

and that the effect of SOX controls would be very limited because the contribution 

of ammonium sulfate to the particulate problem in the SJV is small. EPA concurs 

that these findings are supported by the c1.1rrent analysis of the best available 

data. However, the more extensive California Regional PM-10IPM-2.5 Air 

Quality Study (CRPAQS) field study and modeling will provide an improved basis 

to assess the relationship of precursors in forming secondary particulates. EPA 

expects 'that the results of the CRPAQS study will provide additional technical 

information and is approving the SJVUAPCD's commitment to re-evaluate the 

2003 PM-10 Plan with the results of CRPAQS and to submit a new plan to EPA 

by March 2006. (69 FR 5412, 5414). 

The attainment demonstration for the Plan is based on receptor modeling based 

on chemical analysis of filter samples collected during the CRPAQS field study. 

These samples include filters from days representing typically high PM-10 

concentrations in the SJV. However, the photochemical grid modeling, UAMAero, presented in the Plan was based on the previous, smaller 

field study in the SJV, IMS 95, because the modeling from the CRPAQS field 

study was not complete at the time of the Plan approval. The proposed modeling 

analysis based on CRPAQS will better characterize the interaction 

of precursors to form secondary particulates, because of the more robust 

CRPAQS database and the more extensive CRPAQS modeling approach. 
Responses to comments regarding individual precursors are addressed below. 

2. VOC 

Comment 1: Earthjustice comments that the proposal to determine that VOCs 

"do not significantly contribute" to PM-10 NAAQS exceedances is inappropriate 

because it is based on the UAM-Aero modeling which relies on three days of 

data from 1996, during a period of unusually low PM levels. 

Response: EPA agrees that the IMS 95 database is not ideal; however, it was 

the best available data set at the time of the Plan submittal. The modeling 

presented in the Plan is based on ,the time period most representative of high 

PM-10 during the IMS 95 Study. Modeling based on the more extensive 

CRPAQS field program will not be available until late 2005. The District has 

made an enforceable commitment to reevaluate the 2003 PM-10 Plan with the 

results of CRPAQS and to submit a new plan to EPA by March 2006. 

The District's WAM-Aero modeling was used to deterrr~ine the sensitivity of 

ammonium nitrate to VOC controls (whether VOC controls would increase or 

decrease the ammonium nitrate in the SJV). The chemical nature of the 

atmosphere is not likely to significantly change from one winter period to another 

and, therefore, the response of the atmosphere to reductions in VOC during the 

IMS 95 time period is likely to be similar to the response in different winter time 

periods. Therefore, despite the fact that the PM-10 levels were relatively low, the 

IMS 95 modeling is useful to determine the relative impact of VOC controls on 

the formation of ammonium nitrate. 

As part of the technical support for the Plan, CARB determined the 

expected response to emission reductions through modeling. The sensitivity of 

ammonium nitrate concentrations to VOC controls is presented in the Plan 

(Appendix M, M-6). A 50% reduction of VOCs results in only a small reduction of 

ammonium nitrate concentrations throughout the modeling domain. Plan at 

Appendix M, M-10. This suggests that even with large reductions of VOC 

concentrations, the reduction of the concentrations of ammonium nitrate will be 

small. 

Comment 2: Earthjustice comments that there is evidence that VOCs have 

much to do with facilitating the rate of PM formulation in the Valley. To 

support this argument, Earthjustice refers to an analysis by Pun and 

Seigneur, (Pun and Seigneur C, Conceptual Model of Particulate Matter 

Pollution in the San Joaquin Valley. September 8, 1998 at 3-12). 

Response: EPA agrees that VOC plays a role in the formation of ammonium 

nitrate in the Valley. However, EPA believes that the control of VOC is not an 

effective method to reduce ammonium nitrate in the SJV. EPA has examined the 
analysis by Pun and Seigneur, as well as other material, in considering the 

efficacy of a VOC control strategy in the SJV. The Pun and Seigneur conceptual 

model is also based on the IMS 95 database, and is therefore subject to the 

same limitations as the photochemical modeling used in the Plan. In addition, 

Pun and Seigneur is based on a less sophisticated box model, and is subject to 

the limitations of a box model, compared to the more refined grid model, UAMAero, presented in the 2003 PM-10 Plan. The commenter overstates the 

conclusion of Pun and Seigneur with respect to the efficacy of VOC control. 

Although the paper states that the basin may be either NOX or oxidant sensitive, 

it does not conclude which of the precursors is most influential in the SJV: 

The ambient formation of HN03 may be either NOx or oxidant driven. 

Although information regarding the dominant reaction was not available, 

indirect evidence from the diurnal profile of total nitrate (peak concentrations 

in the afternoon) seemd to be indicate that the N02+OH reaction was an 

important nitric acid production route. Thus to understand which primary 

pollutants govern the formation of ammonium nitrate, we need to address the 

oxidation potential of the atmosphere and determine which pollutants (i.e. 

NOx or VOCs) are the most influential for the formation of oxidants in the 

system. 

Although Pun and Seigneur raises the need to address the oxidation potential of 

the atmosphere and determine which pollutants are the most influential, it does 

not conclude that VOC controls are absolutely required in the SJV. The Plan's 

more refined modeling, based on the IMS 95 study, discussed above, indicates 

,that ammonium nitrate concentrations are not very sensitive to VOC control (Plan 

at Appendix M, M-6) in the SJV. In other words, VOC controls will not have as 

great an effect on PM formation. The CRPAQS study sho~~ld provide an 

improved database for more definitive resl-~lts regarding the effect of VOC 

controls in reducing PM-10 in the SJV. 

Comment 3: Earthjustice comments that the NARSTO report indicates "In the 

case of secondary winter PM nitrate in the SJV * * * nitrate formation is thought to 

be sensitive to VOC concentrations in many urban areas." The report opines: 

Reductions in NOX may not be the best course of action for reducing particulate 

nitrate in the possible VOC-sensitive wintertime condition. Box model simulations 

indicate that NOX reductions may have the counterintuitive effect of increasing 

particulate nitrate formation during winter (Pun and Seigneur, 2001). Therefore, 

coordinated efforts will be required to formulate control strategies beneficial to 

both ozone and PM air quality. 

Response: We believe that the NARSTO report's conclusions are subject to 

several limitations. They are based on "Sensitivity of Particulate Matter Nitrate 

Formation to Precursor Emissions in the California San Joaquin Valley," Pun and 

Seigneur, 2001. As mentioned above, this study is based on the IMS 95 field 

study and therefore is subject to the same database limitations as the UAM-Aero 
modeling included in the Plan. In addition, Pun and Seigneur, 2001, is based on 

a less sophisticated box model, and is subject to the limitations of a box model 

compare to the more refined grid model, UAM-Aero, presented in the 2003 PM10 plan. Pun and Seigneur conclude: 

It should be noted that the box model represents some domain-average 

chemistry but cannot characterize the locally specific cherr~ical regimes. 

Other assumptions include stagnant conditions and aloft carry-overs of 

gaseous and PM pollutants. Further work should extend this box model 

analysis to a three-dimensional modeling study so that transport processes 

can be simulated and the spatial variability of the response of PM to 

precursors can be addressed. However, an extensive reliable database is 

needed for the application of a 3-D model. 'The forthcoming California 

Regional PM Air Quality Study (CRPAQS) database may provide such an 

opportunity. 

While Pun and Seigneur indicates that the San Joaquin Valley air basin should 

not be sensitive to ammonia concentrations and may be sensitive to VOC, each 

of these conclusions is subject to the limitations of the investigation. EPA 

concurs that it is important to extend this analysis to a three dimensional model. 

The results of that modeling exercise indicate that nitrate concentrations are not 

very sensitive to VOC concentrations (Plan at Appendix M, M-6). Therefore, 

control of VOC will not be as effective as NOx control. The forthcoming 

CRPAQS database will provide a more extensive, reliable database to support 

additional modeling. EPA expects that the modeling results of the CRPAQS 

study will provide additional technical information and is approving the 

SJVAPCD's commitment to re-evaluate the 2003 PMI 0 Plan with the results of 

CRPAQS and to submit a new plan to EPA by March 2006. 

Comment 4: Earthjustice comments that the VOC emissions are probably 

underestimated for the SJV and that it is irresponsible of the Plan to not include 

controls for livestock waste, a significant VOC source, when the negative effects 

of VOC pollution are well-known. Furthermore, Earthjustice points out that the 

South Coast Air Quality Management Plan relies on VOC reductions to attain the 

PM-10 standard and that the SJV should, as the South Coast has, take the 

prudent course of action by including VOC reductions. 

Response: As discussed above, EPA has determined that for the purposes of 

section 189(b)(l)(B) and (e), VOC does not contribute significantly to PM-10 

levels which exceed the standards in the SJV. While the South Coast and the 

SJV each have a high level of ammonium nitrate, the air basins are quite 

different in terrain, meteorology, and emissions. In addition, the South Coast is 

primarily an urban area, while the SJV is a mix of rural and urban areas. 

Differences in relative emissions of precursors and the atmospheric conditions 

unique to each basin lead to different optimal control strategies for each basin. 
Comment 5: Earthjustice comments that EPA's proposal to find that VOCs "do 

not significantly contribute to PM-I 0 levels which exceed the standard" may 

make it extremely difficult to regulate CAFOs at all under SB 700, which contains 

provisions requiring the District to show that either source categories of 

agricultural practices "cause or contribute to violations of an ambient air quality 

standard" before issuing a perrr~it or BACMIBACT analysis. 

Response: As discussed above, EPA has determined that VOCs do not 

significantly contribute to PM-10 levels which exceed the standard; however, the 

CRPAQS results may change this determination. In addition, VOC reductions 

may be necessary for ozone attainment, and the determination with respect to 

PM-10 does not alter that fact. 

E. Five Percent Demonstration 

Comment I: Earthjustice and CRPE comment that the Plan fails to demonstrate 11* * * an annual reduction of PM-10 or PM-10 precursors of not less than five 

percent * * *" (emphasis added) as required by CAA section 189(d). The 

commenters assert that the statute is clear in requiring PM-10 or PM-10 

precursor emissions to be reduced by at least 5% in each year. The commenters 

also point to legislative history which they assert precludes any interpretation of 

the statute that would allow less than 5% reduction of PM-10 or PM-10 

precursors in each and every year until attainment. Finally, the commenters note 

that the SJV is the first area subject to the requirements of section 189(d), 

making this an important question of first impression: 

Response: . . . EPA has evaluated the 2003 Plan as a whole and concurs that, 

based upon currently available information, the PM-10 and NOX reduction 

strategy will be the most effective approach to attain the PM-10 NAAQS as 

expeditiously as practicable. Accordingly, EPA believes that the reference in 

section 1 89(d) to 5% emission reductions of "PM-10 precursors" should be 

interpreted to mean 5% of the precursors that have been determined to be 

effective for achieving the NAAQS, i.e., 5% of the type of emissions that are 

PM-10 precursors for regulatory purposes. For the 2003 Plan, for example, the 

District has argued and EPA agrees that it would not be an effective strategy for 

the District to obtain 5% reductions of ammonia because this degree of ammonia 

reduction would not appreciably move the SJV towards attainment given that 

most portions of the area appear to be NOX-limited so that reductions of 

ammonia would not be as effective. Similarly, the District has argued and €PA 

agrees that reductions of VOC would not be as useful as reductions of NOX to 

reduce PM formation, so that achieving reductions of 5% of VOC emissions 

would not be as effective. With respect to SOX, the relatively small amount of 

SOX emissions in the District compels the conclusion that achieving annual 

reductions of 5% of SOX emissions would not significantly affect the ambient 

PM-10 levels in the SJV.