2007 Ozone Plan

 

 

Executive Summary 
2007 Ozone Plan

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San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-1

Executive Summary

The San Joaquin Valley’s severe air-quality problems present a unique opportunity for 

the Valley to shine. Building on our past efforts, we can take the Valley to a place 

where our collective ingenuity and hard work on air quality will be a source of pride for 

all Valley residents. Despite uniquely difficult geographical and meteorological 

conditions, the Valley has a history of success when battling air-quality challenges. The 

2007 Ozone Plan is a continuation of the San Joaquin Valley Air Pollution Control 

District’s (District) mission to improve the air quality in the San Joaquin Valley. 

Plan prepared with extensive public input

The 2007 Ozone Plan was developed with numerous opportunities for the general 

public, environmental and community advocacy groups, and industry representatives to 

offer critique and suggestions. In the summer of 2006, the District held a series of six 

Town Hall meetings throughout the Valley in Bakersfield, Delano, Fresno, Huron, 

Modesto, and Stockton. About 300 participants (many of whom took advantage of the 

Spanish translation made available) attended these meetings. After District staff 

outlined the Valley’s air quality progress and challenges, participants were invited to 

give verbal comments. Written comments were also received over the weeks following 

the Town Hall meetings. These comments are summarized in Appendix G of this plan. 

The District held public workshops on the Draft 2007 Ozone Plan on October 17, 2006 

and on February 8, 2007. Verbal comments were received during the workshop, and 

written comments were accepted during specified periods after the workshops. 

Workshop comments and responses are summarized in Appendix L, and responses 

have also been incorporated into Appendix I as well as other portions of this plan. 

Subsequent to the Town Hall meetings and the public workshop, the District staff held a 

number of meetings with various environmental organizations and business 

representatives to discuss various components of the plan and to solicit further 

suggestions for control strategies. 

In considering public comments, reviewing plans and control measures from other air 

districts, and completing an exhaustive analysis of all sources of smog-forming 

emissions in the San Joaquin Valley, the District has left no stone unturned in 

developing this plan. There will be future opportunities for public involvement. A final, 

noticed 30-day public comment period was held from March 8, 2007 through April 6, 

2007. The public hearing before the District Governing Board to consider the 2007 

Ozone Plan is scheduled for April 30, 2007. Once the plan is adopted, the public will 

have additional opportunities for involvement as the individual strategies, programs, and 

rules in the plan are developed over the coming years. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-2

What will this plan do? 

This plan contains a comprehensive and exhaustive list of regulatory and incentivebased measures to reduce emissions of ozone and particulate matter precursors 

throughout the Valley. Additionally, this plan calls for major advancements in pollution 

control technologies for mobile and stationary sources of air pollution, and a significant 

increase in state and federal funding for incentive-based measures to create adequate 

reductions in emissions to bring the entire Valley into attainment with the federal ozone 

standard. 

The proposed plan calls for a 75% reduction in ozone-forming oxides of nitrogen (NOx) 

emissions. These reductions come on the heels of past successful efforts in the Valley 

that have already reduced ozone precursor emission by nearly 50%. As illustrated in 

Figure ES-1 below, regulatory measures for mobile and stationary sources will reduce 

NOx emissions by 382 tons per day (61%) by 2023. The remaining 14% would come 

from incentives and the deployment of advanced technologies. The incentive-based 

measures contained in this plan generate NOx reductions of 50 tons per day in 2012, 56 

tons per day in 2015, 41 tons per day in 2020, and 26 tons per day in 2023. 

Figure ES-1 San Joaquin Valley NOx Emissions, 2005-2023 

625

160

0

100

200

300

400

500

600

700

200520072009

2011

2013

2015

2017

2019

2021

2023

Reductions

from

Regulatory

Measures

Reductions

from

Incentives

Advanced

Technology

NOx, 

tons 

per 

day 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-3

In addition to the above-mentioned reductions in NOx emissions, full implementation of 

this plan will reduce Volatile Organic Compound (VOC) emissions by 111 tons per day 

through regulatory measures, which equates to a 25% reduction. 

Under this plan, all proposed local measures will be adopted by the San Joaquin Valley 

Air Pollution Control District before 2012. Additional measures requiring technology 

advancement or new incentive funding will also be adopted and implemented as 

expeditiously as they become available. As this plan is implemented, the ambient 

ozone concentrations will decrease dramatically over time in all areas of the Valley. All 

Valley residents will experience cleaner air quickly and continually. By 2015 over 50% 

of the Valley’s population will reside in areas meeting the federal ozone standard. The 

segment of Valley population residing in areas meeting the federal ozone standard will 

increase to 90% by 2020. 

Although ozone concentrations will drop measurably throughout the entire Valley, areas 

east of Arvin and in Northwest Fresno will require additional reductions in emissions to 

meet the federal ozone standard. These additional reductions in emissions require 

further advancements in technology and are expected to occur after 2020 but no later 

than 2023. 

Guiding Principles 

The degree of difficulty and the enormity of the challenge faced by the Valley in meeting 

the new federal ambient air quality standards are unmatched by any other region in the 

nation. This plan is designed to gain state and federal approval, comply with all 

applicable laws and regulations, and bring the entire Valley into attainment with the 

federal health-based ozone standard. For this reason, the District has adhered to the 

following guiding principles in formulating this Plan: 

 

1. With public health as our number one priority, meet the federal ambient air 

quality standards as expeditiously as practicable. 

2. Recognize that the Valley’s economic vitality and prosperity are essential to 

having the resources necessary to achieve our public health goals. 

3. Recognize that no “silver bullet” exists – every sector, from the public through 

all levels of government, business, and industry, must reduce emissions. 

4. Achieve emission reductions in the most cost-effective way possible to get the 

“biggest bang for the buck.” 

5. When scheduling regulatory actions such as rules and strategies, allow 

adequate time for full public participation. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-4

6. Consider total impact on businesses; allow reasonable time for 

implementation of current and future rules. 

7. Give precedence to nitrogen oxides (NOx) emissions reductions to assist with 

attainment of the federal standard for particulate matter (PM). NOx emissions 

contribute to both ozone and PM formation. 

8. Take advantage of imminent new technologies and allow time to get more 

reductions if needed. 

9. Do not let “one-size-fits-all” governmental policies and bureaucracy stand in 

the way of timely, innovative, and cost-effective emission reductions. 

10. Use sound science in assessing public health impacts, the magnitude of 

emissions from various source categories, and the availability, effectiveness, 

and feasibility of emissions control measures. 

11. Do not rely exclusively on the state and federal government to reduce mobile 

source emissions. Consistent with state and federal laws, find effective and 

innovative regulatory and incentive measures at the local level to address 

mobile source emissions. 

12. Consider seasonal, episodic, and regional measures to more strategically 

target limited resources for optimum air quality benefits throughout the Valley. 

Why has this plan been prepared? 

Ozone, the primary ingredient of summertime smog, is a colorless and odorless gas that 

can be harmful to human health at certain concentrations. To protect public health, the 

U.S. Environmental Protection Agency (EPA) has established standards for ozone 

concentrations in ambient – or outdoor – air, as averaged over the course of eight-hour 

periods. The District’s plan to meet the 8-hour ozone standard is due to the EPA by 

June 15, 2007. At completion, this plan will meet federal requirements, including those 

for permitting and controls on major stationary sources of air pollution, demonstrating 

“reasonable further progress,” and providing contingency provisions. The District is 

committed to meeting all of the EPA’s requirements for an 8-hour ozone plan, thereby 

improving air quality for Valley residents. Chapter 2 presents current federal mandates 

for 8-hour ozone. 

As discussed in Chapter 1 and Appendix A, the San Joaquin Valley’s ozone “design 

values” indicate nonattainment at 17 of the Valley’s 21 monitoring stations. In 2005, the 

Valley’s highest design value was approximately 35 percent above the federal ozone 

standard. While this value may be less than those recorded in the South Coast Air 

Basin or Houston, Texas, the San Joaquin Valley tends to record as many or more days 

with 8-hour ozone averages above the level of the federal standard (or “exceedance 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-5

days”) than the other regions. During the years 2003 through 2005, the San Joaquin 

Valley recorded an average of 105 exceedance days per year. Because exceedance 

days are counted at more than 20 monitoring sites covering the 25,000 square miles of 

the San Joaquin Valley, the Valley-wide exceedance total does not fairly represent the 

air quality in any one community. In fact, the Valley’s urban populations appear to be 

exposed to far fewer 8-hour exceedance days than certain downwind rural areas. For 

example, in 2005, the Valley’s urban monitoring site with the highest number of 

exceedance days was the Bakersfield Golden State Avenue site, with 33 days over the 

standard. Typically, however, more exceedance days occur in areas downwind of the 

Valley’s urban centers. For instance, in 2005, the monitors east of Arvin and in Sequoia 

Kings Canyon National Park both registered 54 exceedance days, the most in the 

Valley. 

Valley’s challenge is greater than any other region in the nation 

The same characteristics that make the Valley the world’s most fertile agricultural region 

and a beautiful place to live also create optimal conditions for creating and trapping air 

pollution. Surrounding mountains, stagnant weather patterns, hot summers, and foggy 

winters make the formation of air pollution in the Valley inevitable and prevent air 

pollutants from dispersing. The Valley air basin has a natural propensity to form and 

retain ozone. Figure ES-2 below provides a graphical illustration of how pollution is 

trapped within the Valley during winter months. Due to temperature inversions, the 

same phenomenon occurs during summer months and the rest of the ozone season. 

Figure ES-2 Unique Valley Conditions Trap Air Pollution 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-6

Due to Valley’s unique geography and meteorology, no other region in California faces 

the enormous degree of difficulty that the Valley faces in meeting the ambient air quality 

standards for ozone and particulates. This is illustrated by the fact that the San Joaquin 

Valley has far fewer pollutant emissions per square mile (“emission density”) than other 

regions in California that have equivalent or even better air quality (as shown in Figure 

ES-3). The Valley has reduced its emissions at the same rate or better than other areas 

in California. Nonetheless, despite the Bay Area having six times more emissions per 

square mile than the Valley, that region enjoys good air quality most of the time 

because of the sea breezes that disperse its emissions. Los Angeles, which also has 

more favorable meteorology and topography, has a pollution density 10 times greater 

than ours, yet their air quality is only marginally worse. 

Although ozone concentrations and the frequency of exceeding the federal ozone 

standards in Southern California are somewhat higher than those for the Valley, that 

region has experienced a more dramatic reduction in ozone levels since 1990. This is 

despite the fact that (as shown in Figure ES-4) the total NOx emissions in the Valley 

have been reduced at a faster rate than those in Southern California. 

Figure ES-3 VOC + NOx per Square Mile in the SJV and Other Areas in California 

(Based on ARB’s 2006 Almanac) 

 

ROG + NOx 

tons/day per square mile

0

0.1

0.2

0.3

0.4

0.5

0.6

1990 2005 2020

San Joaquin Valley

Bay Area

South Coast
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-7

Figure ES-4 Past Efforts to Reduce Air Pollution by Region 

Percent Decrease, NOx

Source: Based on ARB's 2006 Almanac

-45.0%

-40.0%

-35.0%

-30.0%

-25.0%

-20.0%

-15.0%

-10.0%

-5.0%

0.0%

1990 1995 2000 2005

year

percent decrease

South Coast

San Joaquin

 

Building on past efforts to achieve cleaner air 

Our past successes give us confidence that similar measures will be effective in the 

future. Given the enormity of the problem and the added challenge with the 8-hour 

versus 1-hour standard, we need to expand beyond past measures. The District has a 

history of success in reducing the two types of smog-forming chemicals -- NOx and 

volatile organic compounds (VOCs) -- as well as significantly reducing particulate 

emissions. The effectiveness of the District’s groundbreaking rules, such as Indirect 

Source Review, Conservation Management Practices, wine fermentation, and 

residential fireplaces, is evidenced by improvements in the Valley’s air quality. Based 

on the ARB’s 2006 Almanac, from 1990 through 2005, Valley-wide NOx emissions have 

decreased by 42 percent and VOC emissions have decreased by 37 percent. These 

reductions represent an impressive accomplishment, especially in light of the 37-

percent increase in population in the San Joaquin Valley over the same time period. 

These emissions reductions are, in part, the result of the 500-plus rules and rule 

amendments the District has adopted since its formation in 1992, expenditure of over 

$100 million in incentive grants, plus state and federal measures for reducing mobile 

source emissions. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-8

As a result of the significant emissions reductions, air quality has improved in the Valley. 

We have reached attainment for PM10. With regard to ozone, design values at every 

monitoring site in the Valley are lower in 2005 than in 2003, indicating progress towards 

meeting the 8-hour standard. Also, each site in the Valley is experiencing fewer days 

with ozone concentrations above the level of the 8-hour ozone standard, reducing the 

public exposure to harmful air. Even more progress had been made toward the federal 

1-hour ozone standard, which, though now revoked, was the focus of the District’s 

previous ozone plan. The District’s progress, ambient air quality data, and emissions 

inventories are discussed in further detail in Chapter 1 and associated appendices. 

What amounts of additional reductions are needed? 

Although the Valley has fewer emissions per square mile than other areas, significant 

emission reductions will be needed to meet the 8-hour ozone standard. To predict 

ozone concentrations in future years, air-quality models are used to simulate the 

formation, transport, and removal of ozone from the lower atmosphere. The models are 

used to develop an emission-control strategy to meet the 8-hour ozone standard. For 

this ozone plan, computer models predict ozone levels based on various degrees of 

emission reductions. Modeling results are then used to develop a corresponding control 

strategy. The model suggests that the San Joaquin Valley needs NOx emissions to be 

no higher than about 160 tons per day to meet the 8-hour ozone standard. As the 

Valley’s NOx emissions in 2005 were approximately 624 tons per day, attainment of the 

ozone standard requires a Valley-wide reduction of approximately 75% from the 2005 

level. VOC emission reductions are less critical for attainment, but serve to expedite air 

quality improvements from current levels in the less impacted areas. A detailed 

discussion of the impact on ambient ozone levels from NOx and VOC reduction 

strategies is presented in Chapter 3. 

How difficult is it to reduce NOx emissions by another 75%? 

As stated above, the latest modeling indicates that bringing the entire Valley into 

attainment will require a 75% reduction in NOx emissions. With our natural low capacity 

for pollution, attaining the tough, federal health-based standards in the timelines 

required by federal law will be a daunting task. To put this in perspective, we would not 

meet this goal if we in the Valley undertook any one of the following actions: shutting 

down all businesses; shutting down agriculture; removing all truck traffic; or removing all 

passenger cars (see Figure ES-5). Of course, these are extreme and unrealistic 

measures offered only to illustrate the magnitude of our problem. Our ultimate strategy 

will require investment and participation from all sectors. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-9

Figure ES-5 How Difficult is Achieving the Valley’s NOx 

Carrying Capacity for Ozone? 

0

100

200

300

400

500

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700

2005

Emission

Inventory

2020

Emission

Inventory

2020 w/o

Light Duty

Passenger

Vehicles

2020 w/o

Diesel Trucks

2020 w/o

Motor

Vehicles

2020 w/o

Stationary

Sources

2020 w/o

Agriculture

NOx, tons per day

How do legal jurisdictional boundaries assigned to various governmental entities 

affect the design and implementation of this plan? 

The US EPA is responsible for regulating emissions from locomotives, aircraft, heavyduty trucks used in interstate commerce, and other sources, such as off-road engines 

that are either exempt from state control or best regulated at the national level. Under 

state authority, ARB is responsible for regulating on-road motor vehicles, some off-road 

sources, and consumer products, such as spray paint, household cleaners and 

hairspray. ARB also establishes fuel specifications for California. Local governments, 

such as cities and counties, can influence air quality by addressing emissions from 

vehicles in their land-use and transportation planning processes and projects. For 

example, reducing urban sprawl and increasing street connectivity reduce emissions 

and help improve air quality. 

The District has primary responsibility for regulating stationary sources, such as power 

plants and manufacturing facilities, as well as some area sources, such as agricultural 

operations. However, state and federal laws preempt the District’s authority to directly 

or indirectly regulate or establish tail-pipe emission standards for mobile sources. 

Nonetheless, consistent with our guiding principle number 11 above, this plan contains 

local regulatory and incentive-based measures aimed at reducing the use or providing 

for mitigation of emissions from mobile sources. 

In spite of the lack of regulatory jurisdiction as described above, the District is still 

charged with developing and adopting this plan, as well as with the ongoing tracking 

NOx carrying capacity 

for Ozone 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-10

and reporting on the progress called for in this plan. The plan includes local, state, and 

federal measures necessary to reach attainment. 

What is the strategy for attainment? 

A successful and comprehensive strategy to bring the entire Valley into attainment with 

the 8-hour ozone standard will require effective partnerships with the local, state, and 

federal agencies to address all sources of air pollution. This plan has been prepared in 

close coordination with the state Air Resources Board (ARB) and in consultation with 

the Region IX of the federal Environmental Protection Agency (EPA). The District and 

ARB have a long history of working effectively together in advancing the science of air 

pollution, and jointly implementing a number of regulatory and incentive-based 

measures. The degree of difficulty that the Valley faces will require a further 

strengthening of the local, state, and federal partnerships to address major sources of 

pollution in the Valley. This is true especially in light of the fact that mobile sources, the 

largest contributors to the Valley’s ozone and particulate problems, are primarily under 

the jurisdiction of the state and federal governments. 

Reducing mobile source emissions is key to the success of this Plan. Mobile source 

emissions, as illustrated in Figure ES-6, make up the overwhelming majority of NOx 

emissions in the Valley in 2005. Furthermore, emissions from stationary sources, under 

the District’s jurisdiction, have already been controlled through several generations of 

strict regulations. 

Figure ES-6 Ozone Precursors by Major Category1

(Based on 2005 Summer Emissions Inventories, O3 SIP (v1.06_RF980)2

) 

 

1

 Please note that Mobile Sources includes on-road and off-road sources. For NOx, 67% of the total mobile source 

emissions in 2005 come from on-road sources, and 33% of the total mobile source emissions come from other mobile 

sources. For VOC, 57% of the total mobile source emissions come from on-road sources, and 43% of the total 

mobile source emissions comes from other mobile sources. 

2

 With NOx adjustment in heavy heavy duty diesel trucks. 

Oxides of Nitrogen (NOx)

Stationary & 

Area 

Sources

20%

Mobile 

Sources

80%

Volatile Organic Compounds

Stationary & 

Area 

Sources

55%

Mobile 

Sources

45%
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-11

The emission control strategy of the 2007 Ozone Plan consists of four main facets: 

! District Regulatory Control Measures for Stationary Sources: Stationary 

sources in the District are already subject to some of the toughest regulatory 

requirements in the nation. The enormity of air quality problems, however, 

requires further reductions from these sources through feasible control 

measures. After exploring all possible measures to enhance stationary controls, 

under this plan, the District will promulgate approximately 19 new and amended 

rules to control NOx and VOC emissions, and 20 additional mid-term measures 

based upon the results of Feasibility Studies. Included in these control measures 

is a regulation requiring Valley employers to establish ridesharing programs. For 

additional details on stationary control measures, please refer to Chapter 6 and 

Appendix I.

! Incentive-based Measures: Even with an aggressive regulatory component as 

proposed in this plan, regulations alone cannot bring about all the reductions that 

are necessary to reach attainment. Stationary sources are already heavily 

controlled, and more stringent tail-pipe standards for new vehicles will not 

produce reductions until the old engines are replaced with cleaner new engines. 

With incentives, the full benefit of the new engine standards will be accelerated 

by several years. Incentive grants can also allow for adoption of cleaner 

technologies that may otherwise be unaffordable. 

As this plan is implemented, over 50% of the Valley’s population will see 

attainment of the 8-hour ozone standard in 2015, with over 90% reaching 

attainment in 2020. Without the incentive funds identified in this plan, these 

figures will be reduced to 35% in 2015 and 65% in 2020. Therefore, without the 

incentive measures proposed in this plan, attainment of the ozone standard will 

be delayed to after 2020 for over 1,000,000 Valley residents. Furthermore, 

without the proposed incentives, the Valley may not reach attainment of the PM 

2.5 federal standard by 2015 as currently mandated by the federal Clean Air Act. 

The amount of state and local funds currently available for incentive-based 

programs is approximately $40 million per year. The primary sources for these 

funds are the expected revenues from the District’s Indirect Source Review rule, 

voluntary development mitigation agreements, local DMV surcharge fees, and 

the state’s Carl Moyer program. This plan calls for a significant increase in 

incentives to bring a large segment of the Valley population into attainment 

earlier than otherwise possible and to allow for the application of advanced 

technologies that will be required for the bringing the entire Valley into 

attainment. To reach this goal, the Valley will need an average of $188 million in 

incentive funding annually until attainment is reached. Chapter 7 provides a 

detailed action plan for securing and expending the proposed incentive funds. 

As binding commitments (e.g., state and/or federal legislation) securing the 

proposed funding levels for incentive measures are put in place, the magnitude 

of the black box will decrease. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

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! Innovative Strategies and Programs: As mentioned earlier, the enormity of 

our challenge requires strategies that go beyond the traditional approaches and 

can better target our limited resources. Consistent with our guiding principle 

number 3, this plan calls for innovative strategies and programs that will involve 

wide-ranging public and private participation. Furthermore, consistent with 

guiding principle number 11, the District will not solely rely on the state and 

federal government to address mobile source emissions. To the extent 

permissible by the state and federal laws, under this plan the District will enact 

innovative measures to reduce mobile and area source emissions. 

The list of these innovative programs includes the following: Green Contracting, 

Expanded Spare - the - Air, Employer-based Trip Reduction, Heat Island 

Mitigation, Alternative Energy Production, Energy Conservation, Enhanced 

Indirect Source Review, Episodic and Regionally-focused Control Measures, and 

Advanced Emission Reduction Options (AERO). Please refer to Chapter 8 for 

additional details on these programs. 

! Local, State, and Federal Controls: With mobile source emissions constituting 

80% of the Valley’s total NOx emissions, the bulk of the necessary emissions 

reductions must come from state and federal control measures for mobile 

sources. The District will work diligently with the state and federal government, 

through the regulatory and legislative process, to ensure adequate controls on 

mobile sources are promulgated and implemented. These measures will include 

more stringent tail-pipe standards for new on-road and off-road mobile sources, 

and regulations designed to accelerate the deployment of newer, cleaner 

engines. The District will also work to expedite emission reductions from the 

mobile sources through District-administered incentive programs. 

Mobile source emissions will be reduced by implementing land-use and 

transportation policies that reduce vehicle miles traveled. To reach this goal, the 

District will work with the local lands-use and transportation agencies, and will 

provide guidance for air-friendly growth and community designs. 

Other sources requiring state measures are consumer products, pesticides, and fuel 

formulation. For more details on local, state, and federal strategies, please refer to 

Chapter 9. 

Why is an “Extreme” attainment plan required? 

The ultimate goal of this plan is to bring the entire Valley into attainment with the federal 

health-based 8-hour ozone standard. The Valley’s classification establishes the 

Valley’s attainment date of the ozone standard. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-13

Under the federal Clean Air Act and its implementing regulations, the region’s nonattainment designation is determined by measuring air quality during the worst days at 

the worst spots in the Valley. Although over 90% of the Valley will be in attainment by 

2020, since reductions from technologies that are not yet available are needed for areas 

east of Arvin and in northwest Fresno to reach attainment, the Valley is left with no 

choice but to seek an “Extreme” nonattainment classification. 

To bring the entire Valley into attainment, the summer-day NOx emissions must be 

reduced to 160 tons per day. Reducing VOC emissions, although useful for some early 

reductions in ozone concentrations in certain areas, will not change the fact that the 

summer-day NOx emissions must be reduced to 160 tons per day. In 2005, the Valley’s 

NOx emissions were at approximately 624 tons per day. With the stationary and mobile 

source control measures proposed in this plan and with the reductions in emissions that 

result from the natural turnover of older and dirtier vehicles and engines, the Valley’s 

NOx emissions will be reduced to the following levels: 

• 2012 NOx emissions = 459 tons per day (26% reduction since 2005) 

• 2020 NOx emissions = 259 tons per day (58% reduction since 2005) 

With the above reductions, the gaps for attainment will be as follows: 

• 2012 attainment gap = 299 tons per day of NOx 

• 2020 attainment gap = 99 tons per day of NOx 

Consistent with our guiding principle number 1, the District’s position has been that an 

“Extreme” designation will only be sought if no other option is possible. In pursuit of the 

earliest possible attainment date, the District has examined all regulatory and incentivebased options and has reached the following conclusions: 

• Even if all financial and logistical constraints were to be disregarded, it is not 

possible to reduce NOx emissions by sufficient quantities to fill the attainment 

gaps in 2012 or 2020. Based on our estimates, assuming no constraints, if all 

light, medium, and heavy duty vehicles, locomotives, and all off-road engines are 

replaced with the latest and cleanest available units, NOx emissions could be 

reduced by another 144 tons per day in 2012, and 77 tons per day in 2020. The 

cost would well over $60 billion and the reductions well short of the attainment 

gap. Please see Chapter 7 for further details and the estimates for the “noconstraint” emission reductions. 

• $188 million per year is an ambitious but a reasonable amount of incentive 

funding to seek. At this time, the District is assured of approximately $40 million 

per year from 2007 through 2015, and approximately $25 million per year 

thereafter. This estimate reflects projected revenues from the District’s Indirect 

Source Review Rule mitigation fees, local DMV surcharges, and the Moyer 

program. Based on our conversations with and commitments from California’s 

U.S. Senators and the Valley’s entire congressional delegation we are looking for 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-14

$100 million per year in incentive funds from federal government. The remaining 

$60 million per year will be sought from the state of California. 

If we are able to secure the above funding, we can generate additional 

reductions totaling 48 tons per day in 2012; 56 tons per day in 2015; and 41 tons 

per day in 2020. These reductions will shrink the attainment gap and will bring 

larger segments of the Valley into attainment before 2015 and 2020. However, 

these reductions will not be sufficient to fully bridge the attainment gap. 

Please refer to Chapter 7 for a detailed plan for incentive fund expenditures, 

projected reductions, and the District’s legislative action plan to secure the 

necessary funding. 

• Expected reductions from new funding that is not yet secured cannot be used in 

an approvable plan to show attainment. Therefore, as long as any portion of the 

reductions necessary for attainment relies on yet to be secured funding, the 

District cannot claim attainment in a serious or severe ozone area plan. 

• Currently available pollution control technology and the known technology 

scheduled for future availability cannot produce sufficient reductions to satisfy the 

Valley’s attainment gap. This is the case even if money were no object. Bringing 

the Valley into attainment will require major advancement in pollution control 

technology for mobile and stationary sources. 

Pursuant to the federal Clean Air Act, section 182(e)(5), the “Extreme” nonattainment classification is the only one that allows for an approvable plan that 

relies on future advancements in technology. With proposed control measures in 

this plan, in 2023, 82 tons per day of NOx reductions are needed that can only be 

achieved through the development and application of advanced control 

technologies that do not yet exist (see Table 11-1). Please refer to Chapter 7 for 

a detailed plan for incentive fund expenditures and projected reductions. 

 

Considering the above conclusions, the Valley has no choice but to step up to an 

“Extreme” non-attainment classification. 

Journey to Attainment 

Several areas of the San Joaquin Valley currently comply with the 8-hour ozone 

standard, and all areas of the Valley will come into attainment as emissions are reduced 

pursuant to this plan. All areas of the Valley will see short term improvement in ozone 

concentrations and will continue to experience cleaner air on an ongoing basis. 

Figure ES-7 provides a graphical illustration of the Valley’s journey to attainment under 

this plan. The green dots in Figure ES-7 indicate monitoring sites that have a design 

value below the level of the 8-hr ozone standard for the year specified. The red dots 

identify sites whose design values are expected to exceed the 8-hr ozone 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-15

Figure ES-7 Journey to Attainment 

2005 2015

2020 2023 

Monitoring sites in attainment 

 Monitoring sites not in attainment 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-16

standard. Figure ES-7 is based on carrying capacities generated through modeling, 

coupled with the emissions reductions identified in this plan. Because of analytical 

limitations, the Figure does not adequately reflect the expected reduction in the number 

of days over the ozone standard or the decline in ozone design values. 

Could a different approach ensure earlier attainment? 

The International Sustainable Systems Research Center (ISSRC), a Southern 

California-based non-profit organization, was tasked by community and environmental 

organizations under funding from the William and Flora Hewlett Foundation with 

developing an “alternative SIP” that could show attainment with the 8-hour ozone 

standard by 2013. ISSRC took on this enormous task without participating in the 

District’s public plan-development process and without communication with the District 

staff. ISSRC released their first version of the “Alt SIP” on February 6, 2007, and 

published a “Revised Alt SIP” on February 19, 2007. Three main strategic elements in 

the Alt SIP are: operational restrictions; increased funding for incentives; and additional 

stationary source control measures. Upon close review of the “Alt SIP” proposals, the 

District found the following: 

• Operational restrictions: The “Alt SIP” effectively proposes to prohibit driving, 

farming, and construction on up to 100 days each year. These restrictions are 

unenforceable, are beyond District authority, and could cripple the Valley’s 

economy. The reductions would not achieve the emission levels needed for 

attainment. 

• Incentive funding: The “Alt SIP’s” proposed incentive measures rely on $450 

million per year in unsecured funding and would therefore not be federally 

approvable in a State Implementation Plan for attainment in 2013. The “Alt 

SIP’s” expenditure plan is also impractical and would not achieve the proposed 

reductions. 

• Stationary source control measures: Most reductions from the “Alt SIP’s” 

stationary source measures reflect double-counting. Existing and proposed 

District measures are more stringent. 

While the February 19 version of the “Alt SIP” conceded to achieving only 95% of their 

own estimate of NOx reductions necessary for attainment, the District found that most of 

the emission reductions proposed in the “Alt SIP” were double-counted or would not be 

legal for the District to claim or pursue. The “Alt SIP” also concluded that attainment 

can be achieved by reducing Valleywide emission levels to 195 tons per day of NOx 

and 230 tons per day of VOC. The District found, based on a proper application of 

photochemical modeling results, that these emission levels would not provide for ozone 

attainment. 

Despite the above shortcomings, the District carefully considered and evaluated all 

control measures proposed by ISSRC for inclusion in the 2007 Ozone Plan. Although 

the District concluded that the “Alt SIP” is not able to achieve attainment, several 

concepts are viable, and these were added to the 2007 Ozone Plan. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-17

The “Alt SIP” analysis confirms that there is no more expeditious path to ozone 

attainment than the path identified by the 2007 Ozone Plan. 

What additional requirements are triggered by an “Extreme” classification? 

A reclassification to an Extreme for the federal 8-hr ozone air quality standard will 

trigger additional permitting and pollution control requirements. As noted in Chapter 2, 

the federal Clean Air Act requires extreme non-attainment areas to define a major 

source as one whose potential emissions of ozone precursors meets or exceed 10 tons 

per year. This lower major source threshold will mean more facilities will be required to 

obtain Title V permits under the Extreme classification. The extreme classification also 

impacts New Source Review and Reasonably Available Control Technology 

requirements for major sources. See Chapter 11 for more details on the additional 

requirements triggered under the extreme classification. 

“Extreme” classification has onerous ramifications. Is not submitting a plan an 

option? 

Failure to prepare a federally approvable plan, to submit it on time to EPA3, and to fully 

implement its commitments would have major public health, legal, and financial 

consequences. Regarding public health, Valley residents will continue to be exposed 

to ozone levels in excess of the health-based federal ambient air quality standard. 

Adverse health impacts will also result in economic cost to the Valley due to costs 

associated with health care, absenteeism, and loss of productivity. 

Failure to submit a timely and approvable plan and to implement its commitments would 

also result in two federal sanctions. The first sanction would make it extremely costly 

for new businesses to locate in the Valley, and for existing businesses to expand, due to 

2:1 offset requirements for permitting major sources in the Valley. The second sanction 

would result in loss of federal highway funds to the Valley estimated at $250 million per 

year. The offset sanction applies in an area 18 months after the date on which EPA 

makes its finding for such an area, and the highway sanctions apply in that area 6 

months following application of the offset sanction (59 FR 39832). EPA has discretion 

to change the sanction sequence. Additionally, the Federal Clean Air Act (Section 

110(c)) requires EPA to impose a federal implementation plan (FIP) 24 months after the 

final rulemaking on a failure to submit or implement a SIP to remedy the deficiencies 

identified by EPA. A FIP would result in a loss of local control. 

 

3

 Nonattainment designations were made in Air Quality Designations and Classifications for the 8-hour Ozone 

National Ambient Air Quality Standards (69 FR 23858-23951), effective June 15, 2004. Section 172(b) of the Clean 

Air Act requires attainment plans to be submitted within three years of the date of the nonattainment designation. On 

December 22, 2006, D.C. Circuit court decision vacated the Final Rule to Implement the 8-Hour Ozone National 

Ambient Air Quality Standard – Phase 1 (69 FR 23951-24000). However, the deadline for 8-hour ozone plans is 

apparently unaffected by the vacating of Phase 1 since designations were made in a separate ruling. EPA has 

requested rehearing on the Phase 1 decision and has urged air districts to move forward on attainment plans and 

observe the June 15, 2007 deadline. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2007

Executive Summary 

2007 Ozone Plan 

ES-18

Public Accountability 

The District will prepare annual reports to show progress in fulfilling its ozone and PM 

plan commitments. These reports, which will help ensure public accountability and 

provide for public assessment of the performance of the local, state, and federal 

agencies in relation to their responsibilities under this plan, will be made available to the 

public and will be presented to the Governing Board annually, beginning in 2008. The 

reports will include ambient air quality data, a summary of rules adopted during the 

previous year, detailed account of the incentive funding expenditures and resulting 

reductions in emissions, as well as other pertinent information. Please see Chapter 5 

for more details on these annual reports.