SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-1 Final Staff Report with Appendices for 

Proposed Rule 9610 

Appendix D 

Manual of Procedures 

for Proposed Rule 9610 (State Implementation Plan Credit for 

Emission Reductions Generated through Incentive Programs) 

June 20, 2013 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-2 Final Staff Report with Appendices for 

Proposed Rule 9610 

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-3 Final Staff Report with Appendices for 

Proposed Rule 9610 

Manual of Procedures 

for Proposed Rule 9610 (State Implementation Plan Credit for Emission 

Reductions Generated through Incentive Programs 

Pursuant to Section 3.3 of Proposed Rule 9610, the District will develop and maintain a 

Manual of Procedures for SIP-creditable incentive-based emission reductions claimed 

through this rule. The Manual of Procedures assures that all incentive program 

guidelines used for SIP creditability are publicly available, and maintained in a 

centralized location on the District’s website. To increase public understanding and 

awareness of the guidelines and the role they play in SIP-creditable of emission 

reductions, the website will also contain a description of how each incentive program 

guideline ensures that the incentive program emission reductions are SIP-creditable. 

The following is the design and contents of the Manual of Procedures web page that will 

be presented and maintained on the Districts website after adoption of the proposed 

rule. 

Manual of Procedures 

The on-going mission of the San Joaquin Valley Unified Air Pollution Control 

District (District) is to improve air quality and protect the health of residents in the 

San Joaquin Valley air basin (Valley). Incentive programs achieve emission 

reductions beyond those achieved by regulations alone by accelerating the 

adoption of cleaner technologies. Since 1992, the District’s incentive programs 

have provided over $500 million in incentive funds, resulting in over 100,000 tons 

of lifetime emission reductions. 

SIP-Creditability of Incentive-Based Emission Reductions 

When given State Implementation Plan (SIP) credit, incentive-based emission 

reductions can be used to complement regulatory-based emission reductions to 

assist meeting federal Clean Air Act (CAA) requirements. District Rule 9610 

(State Implementation Plan Credit for Emission Reductions Generated through 

Incentive Programs) establishes a process through which incentive-based 

emission reductions can receive federal SIP credit. For incentive-based 

emission reductions to receive SIP-credit, the District must demonstrate that the 

emission reductions are Surplus, Quantifiable, Enforceable, and Permanent. 

The following is a brief discussion of each of these elements as applicable to the 

District and incentive-based emission reductions. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-4 Final Staff Report with Appendices for 

Proposed Rule 9610 

Surplus 

The District funds incentive projects based on incentive program guidelines 

that ensure that the resulting emission reductions are not otherwise required 

by any federal, state, or local regulation or other legal mandate. The 

emission reductions must also be in excess of the SIP baseline emission 

inventories underlying a SIP demonstration; meaning the base year, 

attainment year, and interim year emissions inventories as reported in a SIP 

that serve as a primary starting point for modeling and other SIP analyses. 

Quantifiable 

The District evaluates the potential reductions that would be achieved by 

replacing the old equipment with the new equipment using the established 

calculation methods and emissions factors in the appropriate program 

guidelines. To be quantifiable, emission reductions must be reliably 

determined and replicated through the use of well-established emission 

factors and calculation methodologies, as outlined in applicable incentive 

program guidelines. Using well-established emission factors and calculation 

methodologies ensure that the emission reductions can be replicated. 

Enforceable 

Emission reductions are enforceable if the incentive programs include the 

following provisions: 

o The emission reductions must be independently and practicably 

verifiable for the duration of the project life through inspections, 

monitoring, and/or other mechanisms; 

o Incentive program violations are defined through legally binding 

contracts, including identifying party or parties responsible for ensuring 

that emission reductions are achieved; 

o Grantees are obligated to provide all records needed to demonstrate 

that emission reductions are achieved; and 

o The public has access to all emission-related information for reductions 

claimed in the annual demonstration report. 

Permanent 

For purposes of SIP-creditability of incentive-based emission reductions, 

permanent is defined as permanent for the lifetime of the project. 

Permanence is ensured by actions taken to physically destroy or permanently 

disable, existing or baseline equipment, practices, or vehicles. 

Mobile Sources 

 

A large portion of the projects that are currently being funded are from mobile 

sources. These projects provide a unique challenge in that they may opreate only 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-5 Final Staff Report with Appendices for 

Proposed Rule 9610 

a percentage of time within the San Joaquin Valley. To ensure that SIP-creditable 

emissions reductions are only reported for the amount occuring in the San 

Joaquin Valley, the District requires that percent use in the District is reported at 

the time an application for funding is submitted. This information is also reported 

by the grantee each year during the project life through the annual Usage Report 

Surveys that every grantee is contractually required to complete and submitt to 

the District. 

Each program guideline addresses California operation within it’s specific 

methodology but percent use in the San Joaquin Valley is not adjusted for within 

the program guideline methodolgies. The District uses the percent use in the San 

Joaquin Valley reported by the grantee to adjust the total emissions reductions for 

each project prior to reporting SIP-creditable emissions reductions with Rule 

9610. The formula for adjusting for percent use in the San Joaquin Valley is as 

follows: 

Total Lifetime NOx Reduced (tons) * (Percent Operation in SJV/100) = NOx 

Lifetime Reduced Adjusted Percent Operation (tons) 

(5.59 tons/life) * (90%/100) = 5.03 tons 

The formula is repeated for each pollutant being reported. 

Incentive Program Guidelines 

Carl Moyer Memorial Air Quality Standards Attainment Program Guidelines 

The Carl Moyer Memorial Air Quality Standards Attainment Program (Carl 

Moyer Program) has been successfully implemented through the cooperative 

efforts of the California Air Resources Board (ARB) and air districts in 

California. As directed by the California Health and Safety Code (CH&SC), 

ARB’s role is to oversee the Carl Moyer Program by managing program 

funds, developing and maintaining guidelines, and determining costeffectiveness methodologies. Air districts use the Carl Moyer Program 

Guidelines to select, fund, and monitor projects in their jurisdiction by 

providing grants to public and private entities for the incremental cost of 

cleaner-than-required engines and/or equipment. 

The guidelines include robust administrative requirements to ensure that 

emission reductions are enforceable and are achieved throughout the life of a 

project. The District has used the Carl Moyer Program Guidelines to develop 

the practices that are currently in place to ensure all emissions are surplus, 

quantifiable, enforceable, and permanent, and that emission reductions are 

SIP-creditable. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-6 Final Staff Report with Appendices for 

Proposed Rule 9610 

Carl Moyer Guidelines: 

• 2011 Carl Moyer Program Guidelines (approved 4/28/2011): 

http://www.arb.ca.gov/msprog/moyer/guidelines/current.htm. 

o Applicable project type chapters include 4, 5,7,9, and 10 

o Sample Calculations: 

http://www.arb.ca.gov/msprog/moyer/guidelines/2011gl/suppdoc

s/examcalcs2011.pdf

• 2008 Carl Moyer Program Guidelines (approved 3/27/2008): 

http://www.arb.ca.gov/msprog/moyer/guidelines/current.htm

o Applicable project type chapters include 3, 4, 5, and 10 

o Sample Calculations (Appendix E): 

http://www.arb.ca.gov/msprog/moyer/guidelines/cmp_guidelines

_part4.pdf

• 2005 Carl Moyer Program Guidelines (approved 11/17/2005): 

http://www.arb.ca.gov/msprog/moyer/archive/archive.htm

o Applicable project type chapters include 1, 2, 5, and 10 

o Sample Calculations (Appendix D): 

http://www.arb.ca.gov/msprog/moyer/archive/2005_Carl_Moyer

_Guidelines_Part4.pdf

The following is a summary of how Carl Moyer Guidelines ensure emissions 

reductions are SIP-creditable. 

Surplus 

The Carl Moyer Program Guidelines ensure that projects are surplus to 

regulations by only allowing projects to be selected that are not required by 

any federal, State or local regulation, memorandum of 

agreement/understanding with a regulatory agency, settlement agreement, 

mitigation requirement, or other legal mandate. For example, the guidelines 

have accounted for each adopted regulation to determine the compliance 

dates of any affected engines and emission benefits claimed by each 

regulation have been determined. Minimum project lives are established in 

each component to ensure that the program does not fund actions taken to 

comply with regulatory deadlines. The minimum project life requirement also 

ensures the overall cost-effectiveness of the program and that the emission 

reductions are real for the life of the project. The below summary provides 

more detail about how the Carl Moyer Program Guidelines ensure that the 

SIP-creditability integrity criteria of “Surplus” is fulfilled: 

• Requirement that emission reductions generated by incentive 

programs are not required by other regulation 

o (Moyer Guidelines Chapter 2, Project Criteria A, H, I, MM). 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-7 Final Staff Report with Appendices for 

Proposed Rule 9610 

• Protocols for quantifying maximum project life and maximum emission 

reductions which account for upcoming regulatory deadlines for a 

given source category 

o (Moyer Guidelines Chapter 2, Project Criteria B, I and MM). 

• Assurance that baseline equipment was in use 

o (Moyer Guidelines Chapter 3, Section Z.6(B) and AA.2.). 

• Assurance that new/upgraded equipment is not already accounted for 

in future-year inventories underlying a SIP attainment demonstration 

by natural fleet turnover, finite equipment life or incentives 

o The definition of surplus in the Moyer guidelines requires that 

the emission reductions achieved are above and beyond those 

required under existing regulations that are incorporated into a 

SIP. As part of the SIP development process, ARB reviews the 

Moyer project mix to ensure that the amount of emission 

reductions credited to program are not included in the future 

year inventories specific to each individual attainment 

demonstration. 

• Procedures that ensure that old equipment was used in the geographic 

area of interest 

o (Moyer Guidelines, Chapter 2, Section S and Chapter 3, Section 

Z.6.(B)). 

Quantifiable 

The District evaluates the potential reductions that would be achieved by 

replacing the old equipment with the new equipment using the established 

calculation methodologies and emissions factors in the program guidelines. 

The calculation methodology, including calculation formulas, assumptions, 

emission factors and sample calculations are part of the Carl Moyer Program 

Guidelines and have been approved through a public process. To ensure that 

real, quantifiable emission reductions are achieved over the life of a project, 

the program guidelines require that emission control technologies be certified 

or verified by ARB (certification or verification by the EPA or International 

Maritime Organization may be allowed for some source categories for which 

ARB does not have a certification or verification program). The below 

summary provides more detail about how the Carl Moyer Program Guidelines 

ensure that the SIP-creditability integrity criteria of “Quantifiable” is fulfilled: 

• Emissions data needed to calculate emission reductions must be 

publicly available current and accurate. This should include 

appropriate emission factors, load factors, and other conversion 

factors. 

o Moyer Guidelines, Appendix D (Publicly Available) and Chapter 

1, Section E.7 (Allows ARB Executive Officer to modify the 

Guidelines under a public process, to keep them effective and 

up-to-date.) 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-8 Final Staff Report with Appendices for 

Proposed Rule 9610 

• Guidelines include necessary formulas and instructions to calculate 

emissions based on above data, and explicit instructions to ensure 

appropriate data are used in calculations 

o Moyer Guidelines, Appendix C (contains formulas and 

instructions) 

o Moyer Guidelines, Supplemental document, “Sample 

Calculations” (contains formulas and instructions) 

o Requirement Moyer Guidelines, Appendix C, Section B.5, and 

Supplemental document, “Sample Calculations” (contains 

explicit instructions regarding inputs) 

• Requirement to provide activity data sufficient to determine actual 

emission reductions. 

o Moyer Guidelines, Chapter 3, Section Z.6.(B) 

• Requirement to demonstrate the percentage of emission reductions 

that occur in the geographic area of interest, and are therefore SIP 

creditable 

o Moyer Guidelines, Section S. 

o Moyer Guidelines, Section Z.6.(B) 

• Requirement to periodically audit completed projects to verify emission 

reduction projections are fulfilled 

o Moyer Guidelines Chapter 2, Sections Z.10. 

o Moyer Guidelines Chapter 3, Sections EE. 

Enforceable 

Emission reductions and other required actions are enforceable if: they are 

independently verifiable; program violations and those liable are defined; 

information needed to determine emission reductions is available to the 

public; and they are practicably enforceable in accordance with other EPA 

guidance on practicable enforceability. The below summary provides more 

detail about how the Carl Moyer Program Guidelines ensure that the SIPcreditability integrity criteria of “Enforceable” is fulfilled: 

• Require grantees to provide all necessary recordkeeping and reporting 

needed to verify emissions reductions 

o Moyer Guidelines, Chapter 3, Section Z.9 and DD 

• Require inspections to ensure incentive program information is 

consistent with actual operating equipment 

o Moyer Guidelines Chapter 3, Sections AA and BB. 

• Identify liable parties and liability associated with contract 

noncompliance 

o Moyer Guidelines Chapter 3, Section Z.11. 

Permanent 

To ensure that the SIP-creditable emissions reductions are permanent, 

actions such as pre-inspections and post inspections of the new equipment 

and verification that the baseline equipment has been destroyed through the 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-9 Final Staff Report with Appendices for 

Proposed Rule 9610 

required process as described in the program guidelines are performed. The 

below summary provides more detail about how the Carl Moyer Program 

Guidelines ensure that the SIP-creditability integrity criteria of “Permanent” is 

fulfilled: 

• Data needed to determine and track location of activity 

o Moyer Guidelines, Chapter 3, Section DD 

• Provisions for ensuring that the project was completed, including the 

verification of disposition of baseline equipment. 

o Moyer Guidelines Chapter 3, Sections AA and BB 

Proposition 1B Goods Movement Guidelines 

Proposition 1B Goods Movement Guidelines were developed by ARB in 

consultation with stakeholders, including: air districts, metropolitan planning 

organizations, port authorities, shipping lines, railroad companies, trucking 

companies, harbor craft owners, freight distributors, terminal operators, local 

port community advisory groups, community interest groups, and airports. 

The guidelines include robust administrative requirements to ensure that 

emission reductions are surplus, quantifiable, enforceable, and permanent. 

Proposition 1B Guidelines: 

• 2013 Proposition 1B: Goods Movement Emission Reduction Program 

Guidelines (approved 1/25/2013): 

http://www.arb.ca.gov/bonds/gmbond/gmbond.htm. 

o Applicable Project Types include Appendix A 

o Sample Calculations For year 4 projects 

 Solicitation 1 

http://www.arb.ca.gov/bonds/gmbond/docs/calculator_dir

ections_trucks_2013_14.pdf 

 Solicitation 2 

http://www.arb.ca.gov/bonds/gmbond/docs/calculator_dir

ections_trucks_2013_14_solicitation_2.pdf 

o Project calculator in Excel format for year 4 projects: 

 Solicitation 1 

http://www.arb.ca.gov/bonds/gmbond/docs/prop_1b_goo

ds_movement_2013_14_trucks_calculator_solicitation_1.

xlsm

 Solicitation 2 

http://www.arb.ca.gov/bonds/gmbond/docs/prop_1b_goo

ds_movement_2013_14_trucks_calculator_solicitation_2.

xlsm 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-10 Final Staff Report with Appendices for 

Proposed Rule 9610 

• 2010 Proposition 1B: Goods Movement Emission Reduction Program 

Guidelines (approved 03/25/2010): 

http://www.arb.ca.gov/bonds/gmbond/archives/archives.htm 

o Applicable Project Types include Appendix A 

o Sample Calculations For year 2- 3 projects

http://www.arb.ca.gov/bonds/gmbond/docs/prop_1b_goods_mo

vement_2008-09_calculator_directions.pdf 

o Project calculator in Excel format for year 2 – 3 projects: 

http://www.arb.ca.gov/bonds/gmbond/docs/prop_1b_goods_mo

vement_2008-09_trucks_calculator.xlsx 

• 2008 Proposition 1B: Goods Movement Emission Reduction Program 

Guidelines (approved 02/28/2008): 

http://www.arb.ca.gov/bonds/gmbond/archives/archives.htm 

o Applicable Project Types include Appendix A and B 

o Sample Calculations For year 1 projects 

http://www.arb.ca.gov/bonds/gmbond/docs/calculator_directions

_031108.pdf 

o Project Calculator in Excel format for year 1 projects: 

http://www.arb.ca.gov/bonds/gmbond/docs/truck_bondcalculator

_031108_v2.xls 

The following is a summary of how Proposition 1B Guidelines ensure emissions 

reductions are SIP-creditable. 

Surplus 

The Proposition 1B program supplements ARB’s diesel regulations by funding 

early compliance or providing extra emission reductions beyond those 

required by current rules. The program guidelines require that the District 

ensure all trucks being considered to receive funding have had ARB verify 

compliance with the state’s diesel regulations and further require that any 

trucks under contract with the district be noted as such in the state’s online 

regulation reporting database. This ensures that the new truck will not be 

used towards compliance during the project life ensuring that the emissions 

reductions are surplus. Chapter 6 Section E discusses the requirements that

fleets remain in compliance with the Truck and Bus Regulation and that 

program funded equipment cannot be used towards compliance with the 

regulation. 

Quantifiable 

The District evaluates the potential reductions that would be achieved by 

replacing the old equipment with the new equipment using the Project 
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Appendix D: Manual of Procedures January 31, 2014 

D-11 Final Staff Report with Appendices for 

Proposed Rule 9610 

Benefits Calculator created by ARB. The calculator is available to the public 

on ARB’s website at http://www.arb.ca.gov/bonds/gmbond/gmbond.htm and 

is updated by ARB on a regular basis. Chapter 2 Section C Discusses 

Proposition 1B program emission reduction calculations. 

Enforceable 

The District has created enforceable contracts, based on requirements in the 

Proposition 1B Program guidelines, which are signed by both District 

management and the grantee to ensure that projects are fully accomplished 

and the integrity criteria are met. The legally binding contracts include, but 

are not limited to, usage reporting requirements for the grantee, operating 

location requirements for the new vehicle, the destruction requirements of the 

baseline equipment/engine, and an allowance for the District to conduct an 

audit of the project at any time during the project life. Appendix A of 

Proposition 1B Program guidelines details contract requirements for truck 

projects. 

Permanent 

To ensure that the SIP-creditable emissions reductions are permanent, 

actions such as post inspections of the new equipment and verification that 

the baseline equipment has been destroyed through the required process as 

described in the program guidelines are performed. Chapter 4 Section A of 

the Proposition 1B program discusses scrap and post inspection 

requirements. 

United States Department of Agriculture Natural Resource Conservation Service 

Combustion System Imrpovement of Mobile Engines Guidelines 

The United States Department of Agriculture (USDA) Natural Resource 

Conservation Service (NRCS) Combustion System Improvement of Mobile 

Engines Guidelines (Guidelines) implements robust administrative 

requirements for incentive projects based on those in the Carl Moyer Program 

Guidelines to ensure that emission reductions are surplus, quantifiable, 

enforceable, and permanent. Although the Guidelines provide for multiple 

types of combustion system improvements, only those that can be classified 

as off-road mobile agricultural equipment replacement projects are being 

claimed for SIP credit at this time. 

NRCS Guidelines Documents: 

NRCS General Manual 

• NRCS General Manual, Title 450, Part 401 – Conservation Practice 

Standards (approved October 18, 2009): 

http://directives.sc.egov.usda.gov/viewerFS.aspx?hid=19430 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-12 Final Staff Report with Appendices for 

Proposed Rule 9610 

• NRCS General Manual, Title 440, Part 512 – Conservation Program 

Contracting (amended October 2006) : ftp://ftpfc.sc.egov.usda.gov/VA/Programs/440_CPM_512_Compiled.pdf

• NRCS General Manual, Title 450, Part 407 – Documentation, 

Certification, and Spot Checking (amended October 2009): 

http://directives.sc.egov.usda.gov/RollupViewer.aspx?hid=25728

NRCS Conservation Practice Standard 372 

• NRCS Conservation Practice Standard 372 – Combustion System 

Improvement (approved September 2010): 

http://efotg.sc.egov.usda.gov/references/public/CA/372-std-09-

2010.pdf 

• NRCS Combustion System Improvement 372 Operation &

Maintenance (approved August 2013): 

http://efotg.sc.egov.usda.gov/references/public/CA/372B-OM-ca-8-

13.doc

• NRCS Combustion System Improvement 372 Operation &

Maintenance (approved September 2010): 

http://efotg.sc.egov.usda.gov/references/public/CA/372-OM-09-10.doc

• NRCS Conservation Practice Standard 372 – Environmental Quality 

Incentive Program California Air Quality Emission Reductions from 

Replacing Engines FY 2012 Guidelines, Policies, and Procedures 

(approved December 2011, updated May 2, 2012): ftp://ftpfc.sc.egov.usda.gov/CA/programs/AQI/2012_Combustion_Systems_Im

provement_Policy_and_Procedures.pdf

• NRCS Conservation Practice Standard 372 – Worksheets: calculation, 

emission factors, certification, and destruction certification: ftp://ftpfc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality

_Initiative_Attachments.pdf

• NRCS Conservation Practice Standard 372 – Conservation Practice 

Specification (approved September 2010): 

http://efotg.sc.egov.usda.gov/references/public/CA/372-spec-09-

10.doc

• NRCS Conservation Practice Standard 372 – Conservation Practice 

Specification (approved November 2013): 

http://efotg.sc.egov.usda.gov/references/public/CA/372-spec-11-

13.doc
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Appendix D: Manual of Procedures January 31, 2014 

D-13 Final Staff Report with Appendices for 

Proposed Rule 9610 

NRCS Conservation Practice Standard 723

• NRCS Interim Conservation Practice Standard 723 – Combustion 

System Air Emission management (approved May 2009):

http://efotg.sc.egov.usda.gov/references/public/CA/CA-Interim-723-

Combustion-Systems-AQ-Management_May_2009.pdf

Additional Documents 

• NRCS Environmental Quality Incentives Program (EQIP) FY 2013 

EQIP Program Information. National Air Quality Initiative: ftp://ftpfc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality

_Initiative_ProgDesc.pdf. 

• NRCS Environmental Quality Incentive Program Conservation 

Innovation Grants (b) Agricultural Emissions Reductions Guidelines, 

Policies, and Procedures (approved April 2009) LINK HERE 

• NRCS Environmental Quality Incentive Program CIG (b) Air Quality – 

Fiscal Year 2010 – Guidelines, Policies, and Procedures - Combustion 

Systems Air Emissions Management Code 723 (approved January 

2010) LINK HERE 

• NRCS Environmental Quality Incentive Program California Air Quality 

Emission Reductions from Replacing Engines – Fiscal Year 2011 – 

Guidelines, Policies, and Procedures - Combustion Systems 

Improvement Code 372 (approved November 2010) LINK HERE 

The following is a summary of how NRCS Guidelines ensure emissions 

reductions are SIP-creditable. 

Surplus 

Under the NAQI, page 3 of the CA-NRCS program guidelines specifies that 

SIP creditable emissions reductions are “achieved from contracts or parts of 

contracts funded under the air quality initiative [that] are not required by any 

federal, state, or local regulation, settlement agreement, mitigation 

requirement, or other legal mandate.” A rule or regulation does not currently 

exist for off-road mobile agricultural equipment, so the emission reductions 

resulting from replacing existing mobile off-road agricultural engines funded 

under the NAQI per Conservation Practice Standard (CPS) 372 - Combustion 

Systems Improvement are surplus. The FY 2013 National Air Quality 

Initiative Programs Description is posted on-line at: ftp://ftpfc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality_Initiati

ve_ProgDesc.pdf. The 2012 CA-NRCS program guidelines are posted online at: ftp://ftpfc.sc.egov.usda.gov/CA/programs/AQI/2012_Combustion_Systems_Improve

ment_Policy_and_Procedures.pdf 
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Appendix D: Manual of Procedures January 31, 2014 

D-14 Final Staff Report with Appendices for 

Proposed Rule 9610 

Quantifiable 

The District provided technical assistance to CA-NRCS in developing their 

calculation methodologies. The methodologies from the Carl Moyer Program 

are the basis for components included in CPS-372 and its supporting 

documents for the NAQI, including the CA-NRCS program guidelines. The 

District provided technical assistance to CA-NRCS in developing their 

calculation methodologies, which are consistent with the Carl Moyer Program. 

The NRCS Field Office Technical Guide places a ten-year lifespan for 

projects implemented under CPS 372 – Combustion System Improvement, 

which is also consistent with the Carl Moyer program. A conservation 

practice lifespan is the minimum time (in years) the implemented practice is 

expected to be fully functional for its intended purpose (NRCS General 

Manual, Title 450, Part 401.15) 

http://directives.sc.egov.usda.gov/viewerFS.aspx?hid=19430. 

A list of California NRCS practice standard life-spans are posted on-line at: 

http://efotg.sc.egov.usda.gov/references/public/CA/List_of_Practices_Lifespa

ns_2012-12_CA_Numeric.xlsx

The emission reductions for each project, including projects with multiple old 

units for one new unit, are calculated using the methodologies outlined in the 

Carl Moyer Guidelines. Additionally, all equipment engines are inspected to 

verify they are certified to ARB standards before they are paid out. All 

equipment engines are cross-referenced against an ARB executive order that 

verifies the emission of every equipment engine. The NRCS calculation 

worksheets and emission factors are posted on-line at: ftp://ftpfc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality_Initiati

ve_Attachments.pdf

Enforceable 

The NRCS inspects equipment in proposals prior to contract development to 

verify the existing mobile off-road agricultural equipment is operational per 

CPS-372 specifications. Destruction of existing equipment is certified by the 

disposal operator and participant and date-stamped photos are provided. 

Certification worksheet is posted on-line at: ftp://ftpfc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality_Initiati

ve_Attachments.pdf. On an annual basis NRCS reviews at least 5% of all 

active projects. From these project reviews NRCS verifies that the new 

equipment is still operational. 

http://directives.sc.egov.usda.gov/RollupViewer.aspx?hid=25728. Per 

Subpart C, 512.22, participants have control of the land for the length of the 

proposed contract through deed, lease, or other written authorization. If the 

applicant does not own the land, the landowner must give written consent to 

install, operate, and maintain the practice through the lifespan of the practice. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-15 Final Staff Report with Appendices for 

Proposed Rule 9610 

This is conducted through a partnership with the USDA Farm Service Agency, 

who is responsible for program eligibility support.

Subpart F covers Contract Administration and provides for recovering 

liquidated damages for certain deviations to a contract. Handling contract 

violations are addressed in Subpart H where violations of contract terms must 

be corrected by the participant within a reasonable period of time to comply. 

If the violation continues, the contract may be terminated and future program 

participation deferred. 

Permanent 

NRCS eligibility is based on the county that the tractor resides in; in this case 

the tractor has to reside within one of the eight counties of the San Joaquin 

Valley. Under the NAQI, the NRCS prioritizes applications based on a 

county’s non-attainment designation within California. Applications received 

from attainment areas are not eligible. Currently, only the emission 

reductions originating from within the eight San Joaquin Valley counties are 

seeking SIP credit under this proposal. The destruction of the existing mobile 

off-road engines and equipment are verified per CPS 372 specifications, 

posted on-line at: http://efotg.sc.egov.usda.gov/references/public/CA/372-

spec-09-2010.doc. Destruction certification worksheets are posted on-line at: 

ftp://ftpfc.sc.egov.usda.gov/CA/programs/EQIP/2013/2013_EQIP_Air_Quality_Initiati

ve_Attachments.pdf. The NRCS also has a stipulation that the tractor has to 

be tied to the land where it is in use. This requires that the tractor be used 

100% of the time in the San Joaquin Valley. Under the NAQI, NRCS staff 

verifies by site visit the operational condition of the existing mobile off-road 

agricultural equipment. Destruction of the existing equipment and emissions 

certification verifications are performed to determine contract compliance. 

The NRCS Combustion Systems Improvement of Mobile Engines incentive 

program is unique from other incentive programs in that NRCS is explicitly 

prohibited from identifying grantees by name. As directed by the Farm Bill (Food 

Security Act of 1985 (7 U.S.C. § 608d(2))), NRCS must maintain the 

confidentiality of information provided by an agricultural producer participating in 

the NRCS Combustion Systems Improvement of Mobile Engines incentive 

program. The information is exempt from mandatory disclosure and may not be 

used in judicial or administrative proceedings without the consent of the person 

involved. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-16 Final Staff Report with Appendices for 

Proposed Rule 9610 

Terminology 

Each program guideline varies in the use of terms for calculation methodolgies 

and project information. The following table identifies the variations between Rule 

9610 terminology and the program guideline terminology. 

Rule 9610 Prop 1B Moyer NRCS Description 

Project 

Identification 

Project 

Name 

 Project 

Identification 

 Project 

Identification 

Unique identification number 

given to a project by the 

implementing agency 

Project Type 

Project 

Option 

Component, 

Component 

Option, and 

Primary Function 

Primary 

Function 

Describes the type of project 

and equipment being funded 

Old Engine 

Year 

Engine 

Model Year Model Year 

Engine Year 

(baseline) 

Manufacturers model year of 

the old engine 

Annual Miles CA VMT Miles Traveled N/A 

Miles travel per year for on-road 

vehicles 

New GVWR GVWR GVWR N/A 

 Gross Vehicle Weight Rating 

applicable to on-road vehicles 

only 

Cost New 

Equipment/ 

Vehicle 

Total Project 

Cost ($) 

Cost of Reduced 

Technology 

Cost of New 

Engine or 

Equipment 

The total amount of money to 

purchase the new replacement 

vehicle, engine or equipment. 

Does not account for amount of 

grant funding. 

Funding 

Amount 

Prop 1B 

Investment Funding Amount Payment 

Amount of grant money 

provided to implement incentive 

project. 

Previously Submitted Annual Demonstration Reports 

The District’s annual demonstration report submitted to EPA and ARB serves as 

the reporting mechanism to claim credit in the SIP for incentive-based emission 

reductions in the Valley that are surplus, quantifiable, enforceable, and 

permanent. The draft annual demonstration report is made available to the 

public and presented to the District Governing Board prior to submittal to EPA 

and ARB no later than August 31 of each year. 

The annual demonstration report provides a description of program guidelines 

used and how each ensures emission reductions are SIP-creditable, accounting 

of emission reductions achieved through implemented incentive projects, 

provides a summary of SIP commitments for which SIP-creditable emission 

reductions will be used to satisfy; provides project specific information, 

summaries of District project monitorng and enforcement activities; and a 

retrospecitve evaluation of the District’s incentive program performance with 

recommendations for improvements as appropriate. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-17 Final Staff Report with Appendices for 

Proposed Rule 9610 

2013 Draft Annual Demonstration Report 

Additional Resources 

Proposed District Rule 9610 

Proposed Staff Report with Appendices for adoption of Rule 9610 

District Grant and Incentive Programs 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Manual of Procedures January 31, 2014 

D-18 Final Staff Report with Appendices for 

Proposed Rule 9610 

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