2007 Ozone Plan

Chapter 2 

 

Meeting Federal Requirements 
2007 Ozone Plan

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Chapter 2: Meeting Federal Requirements 

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Chapter 2: Meeting Federal Requirements 

2.1 INTRODUCTION 

Pursuant to the federal Clean Air Act (CAA), the U.S. Environmental Protection Agency 

(EPA) sets primary air quality standards to protect public health and secondary 

standards to protect welfare. Achieving the primary federal standards improves public 

health and reduces the region’s health care costs. Meeting federal air quality standards 

helps protect public health and improves the quality of life for Valley residents. This 

chapter describes some of the health effects of ozone, EPA’s process for setting healthbased standards, and how the San Joaquin Valley meets federal requirements for 

attaining those standards. 

2.2 HEALTH EFFECTS 

The human health impacts of ozone include chest pain, coughing, throat irritation, and 

congestion. Breathing ozone can reduce lung function and inflame the linings of the 

lungs. Repeated exposure may permanently scar lung tissue. Other symptoms 

triggered by ozone include wheezing, coughing, pain when taking a deep breath, and 

breathing difficulties during exercise or outdoor activities. Studies have linked rising 

hospital admissions and emergency room visits to higher ozone levels. 

Children are most at risk from exposure to ozone. Children breathe more air per pound 

of body weight than adults. Because children’s respiratory systems are still developing, 

they are more susceptible to environmental threats. Also, ground-level ozone is highest 

in the summertime, when children are outside playing and exercising at summer camps, 

playgrounds, neighborhood parks, and in backyards. In fact, anyone who spends time 

outdoors in the summer, including outdoor workers and people exercising, may be 

impacted. 

These health impacts carry economic costs as well. In The Health and Related 

Economic Benefits of Attaining Healthful Air in the San Joaquin Valley, researchers 

Jane V. Hall, Victor Brajer, and Frederick Lurmann report that the economic benefits of 

meeting the federal standards for both PM2.5 and ozone in the valley could save an 

average of nearly $1,000 per person per year Valley-wide for a total of more than $3 

billion annually (2005 dollars). They report that attaining both standards may result in 

fewer premature deaths, fewer asthma attacks, fewer cases of bronchitis, and fewer 

hospital admissions. These effects are attributed to attaining both the PM2.5 and ozone 

standards, not just the 8-hour ozone standard; many of the potential health impacts in 

Hall’s study may be linked to diesel particulates (a component of PM2.5), though 

reducing unhealthful ozone concentrations will reduce some of these costs to the 

Valley. In Table V-1 of the Hall’s study, the total cost of health impacts from ozone is 

estimated at $32.64 million annually, and Table V-2 shows the total cost of health 
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impacts from PM2.5 to be approximately $3.2 billion annually (Hall 2006). The cost of 

PM2.5 health effects is almost 100 times higher than the cost of ozone health effects. 

The deadline to attain the PM2.5 standard is 2015, so the total health cost of air 

pollution will decrease dramatically by 2015 to no more than $32.62 million annually. 

Hall’s study is the first of its kind for the San Joaquin Valley. Future studies will improve 

our understanding of air pollution effects and costs and affirm the importance of 

programs that bring the Valley into attainment of federal air quality standards. 

Health Effects of Ozone 

! Considerable research over the past 35 years has investigated the responses of 

humans to ozone inhalation. These studies have consistently shown that ozone can 

lead to inflammation and irritation of the airway tissues. 

! Symptoms and responses to ozone exposure vary widely among individuals. Typical 

symptoms include cough, chest tightness, shortness of breath, pain when taking a 

deep breath, and increased asthma symptoms. In persons with asthma, ozone can 

worsen asthma symptoms. 

! Ozone in sufficient doses can also increase the permeability (“leakiness”) of lung 

cells, making them more susceptible to environmental toxins and infection caused by 

microorganisms such as viruses and bacteria. 

! In epidemiologic studies, ozone exposure has been associated with an increase in 

hospital admissions and emergency room visits, particularly for causes related to the 

lungs, such as asthma and chronic obstructive pulmonary disease (COPD). 

! Ozone exposure also has been associated with increased premature death in elderly 

people with chronic diseases of the lungs and circulatory system. 

! A recent study of a large number of school-aged children living in twelve different 

Southern California communities, the ARB-funded Children’s Health Study (CHS), 

found that ozone is associated with increased school absences. The CHS also 

indicated that ozone may contribute to the development of asthma in children who 

played sports outdoors. 

! People who exercise or work outdoors are at greater risk of experiencing adverse 

health effects from ozone exposure because they inhale more ozone. This is 

because effects are related to the inhaled dose of ozone, which is related to the 

ozone concentration in the air, a person’s breathing rate, and the length of their 

exposure, and because ozone concentrations are generally higher outdoors than 

indoors (unless there is a significant indoor source of ozone). 

! When there is an indoor source of ozone, particularly in the home, there is also a risk 

of increased dose, because the concentration of ozone is elevated and the duration 

of exposure is long. In addition, young children are at greater risk because they 

spend more time in the home than adults, and inhale more ozone per pound of body 

weight than do adults because they breathe more rapidly than adults.

Source: ARB, 2006 

 

2.2.1 Other Effects of Ozone 

In addition to human health impacts, ozone affects Valley ecosystems and crops. 

Ozone damages plant cells and deteriorates leaf tissue, which reduces the plants’ ability 

to photosynthesize and produce their own food. Plants respond by growing more 

leaves, which depletes carbohydrates stored in roots and stems. This weakens plants 
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and makes them susceptible to disease, pests, cold, and drought. Ozone reduces 

agricultural yields for many economically important crops, such as grapes, soybeans 

and cotton, and damages the leaves of trees and other plants, marring the appearance 

of cities, national parks, forests, and recreational areas. 

Ozone can cause substantial damage to a variety of materials such as rubber, plastics, 

fabrics, paint, and metals. Over time, ozone exposure progressively damages both the 

functional and aesthetic qualities of materials and products. The resulting increases in 

maintenance, upkeep, and replacement of materials can accumulate to significant 

economic losses. 

2.3 HEALTH-BASED STANDARDS 

Based on human health and environmental considerations, both the state and the 

federal government set ambient air quality standards for ozone. The federal 

government’s “primary standards” are set to protect public health and are set at levels 

that include a margin of safety, while “secondary standards” are established to protect 

public welfare in issues such as crop damage, material degradation, haze, and 

environmental effects. 

California standards are set to protect public health. The California ambient air quality 

standards are considerably more stringent than the federal standards and are more 

protective of human health. ARB approved a 1-hour ozone standard of 0.09 ppm in 

1987. In 2005, ARB approved an 8-hour ozone standard allowing no concentrations 

above 0.07 ppm. ARB retained the previously adopted 1-hour standard. California has 

no mandated timelines for attaining state air quality standards. The current California 

and national ambient air quality standards for ozone are listed in Table 2-1. 

When EPA reviews the NAAQS for a pollutant such as ozone, it develops a "criteria 

document," a compilation and scientific assessment of health and environmental effects 

studies. EPA develops a staff paper on the information available that is compiled by 

technical staff who interpret the most relevant information in the criteria document to be 

used in making policy decisions. The staff paper also contains staff recommendations to 

the EPA Administrator regarding any revisions to the standards needed to protect public 

health and welfare.1

Both the criteria document and staff paper are based on thousands of peer-reviewed 

scientific studies and are part of an extensive scientific assessment process that 

includes rigorous scientific peer review and public comment. Before these documents 

become the basis for policy decisions, they undergo repeated, detailed reviews by the 

scientific community, industry, public interest groups, the general public, and the Clean 

Air Scientific Advisory Committee (CASAC), a Congressionally mandated group of 

 

1

 On December 7, 2006, EPA announced changes to the NAAQS review process, replacing the criteria document 

with the more concise Integrated Science Assessment (ISA) document. 
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Table 2-1 Federal and State Ambient Air Quality Standards for Ozone 

Averaging Time 

8-hour ozone 1-hour ozone Form 

Federal 0.08 ppm a NA b 3-year average of annual 4th highest daily 

maximum 8-hr ozone concentrations (for 

the 8-hr standard only) 

California 0.07 ppm 0.09 ppm No exceedances a

 ppm stands for parts per million 

b

 The federal 1-hour ozone standard was revoked, effective June 15, 2005. On December 22, 2006, the United States 

Court of Appeals for the District of Columbia Circuit Court vacated the rule containing this revocation. On March 22, 2007, 

EPA requested rehearing. Further developments are expected in 2007. 

independent scientific and technical experts.2

 As part of its mandate, the Clean Air 

Scientific Advisory Committee also makes recommendations to EPA on the adequacy of 

the standards. By reaching the federal health-based standards for ozone, we will 

greatly reduce the negative health impacts of this pollutant. 

EPA promulgated the 8-hour ozone standard in July 1997 and finalized Phase 1 of the 

ozone implementation rule in April 2004 (69 FR 23857-23951). Phase 1 set forth the 

nonattainment area classification scheme and upheld specific 1-hour ozone obligations. 

On November 9, 2005, EPA released the Phase 2 rule (70 FR 71611-71705), which 

outlines emission controls and implementation plan requirements, including RFP and 

RACT. Attainment plans must be submitted to EPA by June 15, 2007. EPA also 

revoked the 1-hr ozone standard, for which the Valley’s attainment year was 2010.3

 

This plan addresses the federal 8-hour ozone standard. Appendix E, “California Clean 

Air Act Triennial Progress Report and Plan Revision,” satisfies state 1-hour ozone 

planning requirements. 

2.4 CLASSIFICATIONS AND REQUIREMENTS 

On April 15, 2004, EPA designated and classified the SJVAB as serious nonattainment 

for the federal 8-hour ozone standard, effective June 15, 2004. As a serious area, the 

valley is to attain the standard as expeditiously as practicable, but no later than June 15, 

2013. The 2007 Ozone Plan, the first 8-hour ozone plan for the SJVAB, is due to EPA 

by June 15, 2007. Following receipt of a Plan, the EPA must find the Plan complete 

within six months of receipt. The EPA must approve, disapprove, partially approve, or 

conditionally approve the plan within one year of finding the plan complete [CAA Section 

110(k)]. Table 2-2 summarizes the timelines and requirements for areas classified 

serious or higher. Notice that all four classifications must submit a SIP by June 15, 

2007, but the compliance and attainment date, as well as other requirements, vary 

among the classifications. 

 

2 EPA’s December 7, 2006 changes to the NAAQS review process modified the role of CASAC in the standard-setting process.

3 On December 22, 2006, the United States Court of Appeals for the District of Columbia Circuit Court vacated the rule containing

this revocation. On March 22, 2007, EPA requested rehearing. Further developments are expected in 2007.
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Table 2-2 Timelines and Requirements 

Requirement Serious Areas Severe-15 Areas Severe-17 Areas Extreme Areas 

Attainment 

demonstration, RFP, 

and NSR SIP 

submission 

6/15/07 6/15/07 6/15/07 6/15/07 

Compliance Date: 

Achieve all emissions 

reductions needed for 

attainment 

By start of the 

2012 ozone 

season 

By start of the 

2018 ozone 

season 

By start of the 

2020 ozone 

season 

By the start of the 

2023 ozone 

season 

Attainment date 6/15/2013 6/15/2019 6/15/2021 6/15/2024 

Although this is the first plan for 8-hour ozone in the Valley, the District Governing Board 

has adopted ozone plans in the past, culminating with the Extreme Ozone Attainment 

Demonstration Plan for the 1-hour ozone standard on October 8, 2004 and adopted 

amendments on October 20, 2005. On June 15, 2005, EPA revoked the federal 1-hour 

ozone standard. As such, transportation conformity and de minimis thresholds for 1-

hour ozone no longer apply, contingency measures are not needed, and EPA will not 

make a finding of a failure to attain. However, other requirements still apply, including 

anti-backsliding provisions, rate of progress reductions, reasonably available control 

technology (RACT) controls, black box measures (provisions of an Extreme Area’s 

implementation plan that anticipate development of new control techniques or 

improvement of existing control technologies).4

 Control measures cannot be removed 

from the SIP solely because of revocation, and the measures included in the 1-hour 

ozone plan will also contribute to the District’s 8-hour ozone strategy. 

Once the federal government sets a standard, states and air districts with nonattainment 

areas are required to adopt plans, rules, and programs that reduce emissions to bring 

the area into attainment of the standard. In California, air pollution control districts 

and/or air quality management districts are responsible for developing the overall 

attainment strategy in their respective geographic areas. Plans, such as the 2007 

Ozone Plan, are the first step in the process. To develop a plan, areas evaluate air 

quality data, emissions inventory data, and computer modeling results to determine the 

rules and programs that are needed to reach the federal standards by the deadlines 

specified in the CAA. The CAA contains several SIP requirements for areas classified 

as an extreme nonattainment area for 8-hour ozone. Table 2-3 outlines these 

requirements. The rules and programs in a plan are then implemented over time to 

reduce the emissions that go into the air, reducing unhealthful concentrations of air 

pollutants and helping areas reach federal air quality standards. 

The state compiles all of the air quality plans for the state’s nonattainment areas into a 

SIP. During the regional planning process, ARB develops air quality models, conducts 

 

4 On December 22, 2006, the United States Court of Appeals for the District of Columbia Circuit Court vacated the rule containing

this revocation. On March 22, 2007, EPA requested rehearing. Further developments are expected in 2007.
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and funds air quality research, develops emissions inventories, develops statewide 

emission control measures, and provides other assistance to local air districts. Once 

nonattainment areas adopt their plans, ARB is responsible for preparing and submitting 

the California SIP to the EPA. 

Periodic plan revisions may be necessary to ensure reasonable further progress and to 

reflect the latest science. Once an area’s ambient air quality data meets the federal 

standard, the area will request a finding of attainment. Then a maintenance plan and 

other requirements must be met before an area can be officially redesignated to 

attainment. 

Table 2-3 Federal Requirements for Extreme 8-hour Ozone Nonattainment Areas 

Requirements Federal 

CAA Description 

General 

Requirements 

110 and 

172(c) 

Includes RACM, RFP, emissions inventory requirements, need for permits, 

contingency measures, enforcement, adequate resources, etc. 

Severe Area 

Requirements1 182(e) 

Extreme areas must meet all severe area requirements (i.e., de minimis, 

RACT, RFP, and contingency provisions) except as modified by Section 

182(e). 

Major Stationary 

Source 182(e) 

Include any stationary source or group of sources located within a 

contiguous area and under common control that emits, or has the potential 

to emit, at least 10 tons per year of VOCs.2

Offset requirement 182(e)(1) 

The ratio of total VOC emission reductions to total increased VOC 

emissions shall be at least 1.5 to 1, unless all existing major sources are 

required to use BACT, in which case the ratio shall be at least 1.2 to 1. 

Modifications 182(e)(2) 

Any change (besides changes made to comply with the offset requirement) 

at a major stationary source that results in emissions increases shall be 

considered a modification, unless the operator offsets the increase of at 

least 1.3 to 1. 

Clean fuels at 

electric utilities and 

industrial & 

commercial boilers 

182(e)(3) 

Such sources that emit more than 25 tons per year of NOx must burn 

specified primary fuels or use advanced control technologies. 

Traffic control 

measures during 

heavy traffic hours 

182(e)(4) 

SIPs may contain provisions establishing traffic control measures applicable 

during heavy traffic hours to reduce use of high polluting vehicles or heavyduty vehicles. 

New technologies 182(e)(5) 

Allows for provisions in an Extreme SIP that anticipate development of new 

control techniques or improvement of existing control technologies (i.e. 

black box). State must demonstrate that such provisions are not necessary 

for the first ten years [182(e)(5)(A)] and that the SIP includes enforceable 

commitments to develop and adopt contingency measures [182(e)(5)(A)]. 

Nonattainment Fee 185 

If an extreme area fails to attain the standard by June 15, 2024, major 

stationary sources of VOCs in the area shall pay a fee to the state of 

$5000/ton of VOC emissions per calendar year in excess of 80% of a 

baseline defined as the actual or allowable emissions. 1

 Also includes requirements for serious areas (182(c)) and moderate areas (182(b)), except as modified by higher 

classifications. 

2

 Plan provisions required for major sources of VOCs also apply to major sources of NOx subject to EPA review 

[Section 182(f)].
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2.5 FEDERAL CAA PLANNING REQUIREMENTS ADDRESSED BY THE 2007 OZONE 

PLAN

This 2007 Ozone Plan meets federal requirements for extreme areas, as discussed in 

the following paragraphs and in Appendix M. 

2.5.1 Reasonably Available Control Technologies (RACT) 

Section 172(c)(1) of the federal Clean Air Act requires air quality plans for 

nonattainment areas to “provide for the implementation of all reasonably available 

control measures as expeditiously as practicable (including such reductions in 

emissions from existing sources in the area as may be obtained through the adoption, 

at a minimum, of reasonably available control technology) and shall provide for 

attainment of the national primary ambient air quality standards.” 

EPA’s Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality 

Standard—Phase 2 (70 FR 71707) modified 40 CFR 51.912 to require nonattainment 

areas to submit a SIP revision that meets the NOx and VOC RACT requirements in 

Sections 182(b) and 182(f) of the federal Clean Air Act no later than 27 months after 

designation for the 8-hr ozone NAAQS (which equates to September 15, 2006). The 

District prepared this RACT SIP through a public process, and adopted it on August 17, 

2006. The RACT SIP analysis showed that the District’s rules meet or exceed RACT 

requirements for all applicable EPA source categories. The District submitted this 

RACT SIP to ARB in August 2006 for review and transmittal to EPA by the September 

15, 2006 deadline. ARB transmitted the SJV RACT SIP and other districts’ RACT SIPs 

to EPA on January 31, 2007. 

For areas designated as extreme non-attainment for the 8-hr ozone NAAQS, RACT 

control measures would apply to sources with emissions greater than 10 tons per year. 

The SJVAB was classified as extreme nonattainment for the 1-hr ozone NAAQS that 

EPA revoked effective June 15, 2005, and EPA’s Final Rule to Implement the 8-Hour 

Ozone National Ambient Air Quality Standard—Phase I (69 FR 23858) contains antibacksliding provisions that require former 1-hr ozone nonattainment areas to keep the 

RACT applicability thresholds for their prior classification, even though the standard was 

revoked.5

 The District has amended applicable rules to ensure compliance with this 

rulemaking’s anti-backsliding provisions for RACT applicability thresholds. 

2.5.2 Attainment Demonstration 

Section 182(c)(2)(A) of the federal CAA requires nonattainment areas to demonstrate, 

using federally-approved photochemical modeling, that the plan will provide for 

 

5

 On December 22, 2006 the United States Court of Appeals for the District of Columbia Circuit Court vacated the 

Phase I rule and remanded the rule to EPA for revision. On March 22, 2007, EPA requested rehearing. 
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attainment of the standard by the applicable date. As discussed in Chapter 3 and 

Appendix F, ARB used federally approved models in conducting the modeling for this 

Draft 2007 Ozone Plan. These federally-approved models were further enhanced using 

field data, analysis studies, and other findings of the $30+ million air pollution studies 

conducted in the San Joaquin Valley. Thus the ARB modeling done for this plan 

reflects state-of-the-science understanding of ozone formation in the Valley. 

2.5.3 Reasonable Further Progress (RFP) Demonstration 

Section 182(c)(2)(B) requires nonattainment areas to show that the plan will result in 

VOC and NOx emission reductions as specified in the federal CAA. Chapter 10 of the 

2007 Ozone Plan shows that the Valley meets these requirements with emission control 

measures already adopted for all milestone years. 

2.5.4 Contingency Provisions 

Sections 172 and 182 of the federal CAA require nonattainment areas to have in place 

emission reductions that will go into effect without further action by the State or EPA if 

the nonattainment area fails to meet a milestone for RFP or attainment. Section 10.4 of 

this plan shows that the Valley has the required magnitude of contingency emission 

reductions for all years with adopted measures. 

2.5.5 Major Stationary Source Threshold 

The District revised its new source review (NSR) rule (Rule 2201) on April 20, 2005 to 

reflect the extreme classification (10 ton per year major source threshold) under the 

federal 1-hour ozone standard and submitted those revisions to ARB for transmittal to 

EPA. The District’s NSR rule revisions were to take effect immediately upon EPA 

approval into the SIP. Before this approval occurred, EPA’s revocation of the 1-hour 

ozone standard became effective, which effectively eliminated the need to reclassify to 

the extreme major source thresholds under the 1-hour ozone new source review.6 The 

Valley’s major source threshold has since remained at 25 tons per year, as dictated by 

the California Health and safety Code (Section 42504). 

For the extreme classification under the federal 8-hr ozone standard, the District 

commits to submitting the revised NSR rule to EPA within one year of the date of the 

District’s adoption of the 2007 Ozone Plan. The lower thresholds in this rule would 

apply on the effective date of EPA’s final approval of the revised rule into the SIP. The 

threshold could also be revised in response to the District of Columbia Circuit Court 

 

6

 On December 22, 2006 the United States Court of Appeals for the District of Columbia Circuit Court vacated the 

Phase I rule and remanded the rule to EPA for revision. On March 22, 2007, EPA requested rehearing. 
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ruling7, depending on the government’s response to the ruling and on any subsequent 

court findings. 

2.5.6 Offset Requirements 

After EPA’s approval of the extreme classification NSR rule, the SJVAB’s offset ratio 

would change to the higher level of 1.5 to 1, with the option of a 1.2 to 1 ratio if the 

District is able to demonstrate use of best available control technology on all major 

sources. District revisions to the rule implementing these requirements would be done 

on the same schedule as described in the previous section. 

2.5.7 New Technologies 

Section 182(e)(5) of the federal CAA allows for provisions in an Extreme SIP that 

anticipate development of new control techniques or improvement of existing control 

technologies (i.e. “black box”). More information is available in Chapter 11. 

2.5.8 Clean Fuels 

Section 182(e)(3) of the federal Clean Air Act directs extreme nonattainment areas to 

require: "that each new, modified, and existing electric utility and industrial and 

commercial boiler which emits more than 25 tons per year of oxides of nitrogen - 

(A) burn as its primary fuel natural gas, methanol, or ethanol (or comparable low 

polluting fuel), or 

(B) use advanced technology (such as catalytic control technology or other 

comparably effective control methods) for reduction of emissions of nitrogen" 

District Rules 4305, 4306, and 4352 address NOx emission limits for the boilers in this 

category. Most of the boilers under Rules 4305 and 4306 are fired on natural gas and 

therefore satisfy the requirement of paragraph (A) above. Liquid-fuel fired boilers are 

also addressed by those rules and the applicable NOx emission limits satisfy the 

requirement of paragraph (B) above. Solid-fuel fired boilers are addressed by Rule 

4352 and the applicable NOx emission limits satisfy the requirement of paragraph (B) 

above. 

Therefore, the District already complies with this requirement and there is no need to 

include additional control measures in this plan to satisfy the section of the federal 

Clean Air Act. 

2.5.9 Other Requirements 

The District generally meets all federal monitoring requirements. As Valley population 

increases and other factors trigger the need for new monitors or other changes to the 

network, the District will revise the network as needed. The District continues to 

 

7

 On December 22, 2006 the United States Court of Appeals for the District of Columbia Circuit Court vacated the 

Phase I rule and remanded the rule to EPA for revision. On March 22, 2007, EPA requested rehearing. 
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conduct annual enhanced ozone monitoring. The most recent District enhanced 

monitoring information may be found at http://www.arb.ca.gov/aagm/mldaqsblamn.htm. 

Special ozone air studies conducted in the Valley in the past are summarized in the 

2004 EOADP. The Central California Ozone Study (CCOS) is ongoing and will continue 

to provide information for future plans and plan updates. More information may be 

found at http://www.arb.ca.gov/airways/CCOS/CCOS.htm#recent . 

The traffic control measures [Section 182(e)(4)] are optional. These are likely to have 

minimal benefit for the Valley due to the relatively short durations of “heavy traffic hours” 

in the metropolitan areas of the Valley. Chapter 11 describes the use of “new 

technologies” provisions. Lastly, the District adopted a rule on May 16, 2002 

implementing a nonattainment fee of $5000 per ton of emissions, and submitted the rule 

through ARB to EPA for approval. EPA has not yet taken final action on the rule, which 

was written to apply to either a severe or extreme nonattainment area. 

Ambient air quality data and design values are included in Chapter 1 and Appendix A. 

The emissions inventory is discussed in Chapter 1 and Appendix B. Control measures 

are included in Chapters 6, 7, 8, and 9 as well as Appendices H and I. Modeling 

appears in Chapter 3 and Appendix F. RACM is in Chapter 9 and Appendix C. The 

2007 Ozone Plan satisfies federal requirements for implementation plans (see Appendix 

M). 

References 

Hall, Jane V; Brajer, Victor; and Lurmann, Frederick W. (March 2006). “The Health and Related Economic 

Benefits of Attaining Healthful Air in the San Joaquin Valley.” Institute for Economic and Environmental 

Studies.