2008 PM2.5 Plan 

Chapter 6 

 

District Strategy 
2008 PM2.5 Plan 

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Chapter 6: District Strategy 

2008 PM2.5 Plan 

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Chapter 6: District Strategy 

6.1 INTRODUCTION 

Attaining the federal PM2.5 standard will require the involvement of all sectors of the 

economy and the population. Chapter 4 (Strategy) details the District’s four-faceted 

control strategy: 

1. Regulatory Control Measures for Stationary Sources 

2. Incentive-based Strategies 

3. Innovative Strategies and Programs 

4. Local, State, and Federal Sources/Partnerships 

A summary of the plan strategy, which includes the District’s regulatory stationary 

source control measures, incentive measures and innovative programs, is included in 

this chapter. Chapter 7 of this plan presents emissions reductions from state, federal 

and local measures. 

As summarized in Tables 6-3a, 6-3b, and 6-3c, the District’s regulatory control measure 

component of this plan achieves 16.17 tons per day (tpd) of combined NOx, SO2, and 

PM2.5 reductions by 2012 and 16.59 tpd of reductions by 2014. Additional reductions 

will be achieved from the District’s incentives programs, which are discussed Section 

6.5 of this chapter and in Chapter 7 of the 2007 Ozone Plan. 

As discussed in Chapter 3, emission reductions of NOx, directly emitted PM2.5, and 

SO2 are needed to demonstrate attainment of the PM2.5 NAAQS in the San Joaquin 

Valley. The gridded regional modeling performed by ARB and the receptor modeling 

performed by the District each identify the need for reductions of directly emitted PM2.5 

and secondary particulates, including nitrates and sulfates, in order to demonstrate 

attainment of the PM2.5 NAAQS. 

6.2 REGULATORY COMPONENT: RACT/RACM 

The Stationary Source Control Measures in Section 6.3 were developed according to 

the federal guidance for reasonably available control technologies (RACT) and 

reasonably available control measures (RACM). That guidance requires PM2.5 

nonattainment areas to consider RACT and RACM that might contribute to expeditious 

attainment in a specific nonattainment area. This section discusses the details of those 

requirements that were used to determine the control measures that will be pursued. 

The U.S. Environmental Protection Agency (EPA) interprets RACM as a collection of 

measures that, taken as a group, advance the NAAQS attainment date by at least one 

year. A RACT/RACM analysis must consider which emissions sources to control, to 

what level, and when the controls can and should be implemented. According to the 
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federal guidance, states need not analyze every conceivable measure. RACT/RACM 

are, by their definition, reasonable. Any unreasonable measure, which is absurd, 

unenforceable, impractical, or that would cause severely disruptive socioeconomic 

impacts (e.g., gas rationing and mandatory source shutdowns), would not be required. 

Measures that are not necessary to satisfy Reasonable Further Progress (RFP) or 

expeditious attainment are also not required RACT/RACM for the area. Finally, any 

measures that, collectively, would not advance attainment by at least one year are not 

required for PM2.5 RACT/RACM, even if those measures are individually reasonable. 

Similar to New Source Review requirements, RACT/RACM analyses must address both 

direct PM2.5 and gaseous precursors, in particular SO2 and NOx, unless NOx and SO2

emissions do not significantly contribute to PM2.5 in the area. RACT/RACM are not 

needed for ammonia or VOC unless modeling shows that reductions of these are 

effective in reducing PM2.5 levels in the area. EPA encourages States to consider the 

potential for reducing condensable emissions when evaluating potential measures for 

RACT. EPA expects areas to more rigorously identify RACT/RACM for those 

precursors that are most effective in reducing PM2.5. Less rigorous analysis is needed 

for pollutants that have trivial impacts on PM2.5 reductions. 

While an area’s RACT determination may include an appropriately supported 

certification of previously conducted RACT determinations, such as those completed for 

ozone or PM10, existing RACT should be closely reviewed in light of newer information 

that may have arisen since the initial determinations. Identifying potential RACT/RACM 

measures entails three main steps: 

(1) Examining the emissions source categories in the nonattainment area with direct 

PM2.5 and precursor emissions, such as NOx and SO2. Priority should be given 

to categories with the largest inventory of PM2.5 or precursors. Although many 

of these sources are already well controlled, small incremental improvements 

result in higher emission reductions than categories with smaller inventories. 

(2) Considering technologically feasible emissions control technologies or measures 

for each source. Technological feasibility determinations should include 

considerations of the source’s operating procedures, raw materials, physical 

plant layout, and any other environmental impacts. The cost of preventing 

adverse water, solid waste, and energy impacts should be considered when 

assessing the economic feasibility of the PM2.5 control technology. 

(3) Considering the control efficiency and possible emissions reductions, by 

pollutant, for each technology or measure and the date by which the technology 

or measure could be reasonably implemented. States should consider the 

capital costs, annual costs, and cost effectiveness of an emissions reduction 

technology, as well as any effects on the local economy. EPA is not proposing a 

fixed cost effectiveness threshold for RACT. If essential reductions are more 

costly to achieve because many sources are already controlled, the cost per ton 

of control may necessarily be higher. The significant benefits associated with 
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PM2.5 ambient reduction should be a relevant consideration in control strategy 

development. 

Because NAAQS violations generally reflect a combination of regional scale, 

metropolitan scale, and local scale impacts, all three scales must be addressed in an 

area’s RACT/RACM analysis. Considering the variety of emissions sources, control 

measure types, and nonattainment situations, EPA did not define a de minimis 

threshold for the PM2.5 RACT analysis. A state needing significant emission reductions 

for attainment will likely consider controls on smaller sources than would be analyzed by 

states that don't require significant reductions. 

The RACT/RACM control measures are selected based on the reductions needed to 

obtain the earliest possible attainment year. The selected measures should be adopted 

and submitted to EPA within three years of the nonattainment designation, which would 

be April 2008 for the District. Implementation of RACT measures should in no case 

start later than the beginning of the year before the attainment date. 

For 8-hour ozone, the District prepared a RACT SIP analysis that was adopted by the 

District Governing Board and submitted to ARB for transmittal to EPA by the September 

16, 2006 deadline. The RACT SIP analysis showed that the District’s rules meet or 

exceed RACT requirements for all applicable EPA source categories. Because EPA 

has since issued new Control Technologies Guidelines (CTGs), the District is updating 

the 8-hour ozone RACT SIP analysis to address these new guidelines. 

Due to limitations on time and resources, EPA is not developing additional Control 

Technologies Guidelines in advance of the PM2.5 SIP submission date. However, EPA 

provided a list of source categories as a starting point for identifying potentially available 

control strategies, including both regulatory and voluntary measures, to illustrate the 

general types of sources and measures that States can consider. Table 6-1 lists those 

control strategies and the equivalent control measure that the District or ARB has either 

adopted or will develop for that category. Nonattainment areas should also consider 

additional measures, other than those suggested in Table 6-1, based on the unique 

considerations of the area and comments received from the public. 

Control measures are discussed in Section 6.3 with more detailed information 

presented in Appendix I. Thus far, the District has not excluded any reasonable 

measures. The District is continuing discussions with EPA and ARB on RACT/RACM 

determinations and will evaluate public suggestions on control measures during the rule 

development process and during future Plan updates. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Chapter 6: District Strategy 

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Table 6-1 EPA’s List of Suggested PM2.5 Control Measures 

 EPA Control Measure District Equivalent 

Stationary Source Measures 

SSM-1 Stationary diesel engine retrofit, rebuild or 

replacement, with catalyzed particle filter 

District Rule 4702 includes standards for 

existing stationary internal combustion engines. 

EPA Tier 4 diesel engine standards are 

expected to include particulate filter systems. 

SSM-2 

New or upgraded emission control 

requirements for direct PM2.5 emissions at 

stationary sources, e.g. installation or 

improved performance of control devices 

such as a baghouse or electrostatic 

precipitator; revised opacity standard; 

improved compliance monitoring methods. 

Source-specific District rules, such as Rule 

4204 (Cotton Gins) currently include PM 

emission control requirements. The new and 

amended rule development projects (see Table 

6-2) will also examine appropriate controls for 

other sources of direct PM and precursors. 

SSM-3 

New or upgraded emission controls for 

PM2.5 precursors at stationary sources 

(e.g., SO2 controls such as wet or dry 

scrubbers, or reduced sulfur content in fuel; 

desulfurization of coke oven gas at coke 

ovens; improved sulfur recovery at 

refineries; increasing the recovery 

efficiency at sulfuric acid plants). 

The new and amended rule development 

projects (Table 6-2) will also examine 

appropriate controls for sources of direct PM 

and precursors. SOx controls are currently 

included in the initial drafts for amendments to 

the glass melting furnace and boiler rules. 

SSM-4 

Energy efficiency measures to reduce fuel 

consumption and associated pollutant 

emissions (either from local sources or 

distant power providers). 

The 2007 Ozone Plan includes commitments to 

promote Alternative Energy Sources and 

reduce consumption through Energy 

Conservation, Green Contracting, and Heat 

Island Mitigation projects. These efforts will 

also reduce PM2.5 emissions. 

SSM-5 Measures to reduce fugitive dust from 

industrial sites. 

District Regulation VIII addresses control of 

fugitive dust emissions from a variety of 

sources, operations and areas. 

Mobile Source Measures 

MSM-1 

On-road diesel engine retrofits for school 

buses, trucks and transit buses using EPAverified technologies 

District Rule 9310 addresses school bus fleets. 

State programs address truck and transit bus 

fleets emissions. Early implementation of fleet 

upgrades are encouraged through state and 

local incentive funds. 

MSM-2 Non-road diesel engine retrofit, rebuild or 

replacement, with catalyzed particle filter 

In September 2007, ARB adopted stringent 

PM2.5 control standards for non-road 

equipment which would require retrofit, repair 

or repowering of diesel engine powered 

equipment. 

MSM-3 Diesel idling programs for trucks, 

locomotive, and other mobile sources 

ARB adopted idling standards for a variety of 

diesel vehicles. Additionally, the District 

incentive program has subsidized truck stop 

support equipment to reduce diesel truck idling 

along the main goods movement corridors. 

MSM-4 

Transportation control measures (TCM) 

including those listed in section 108(f) of 

the CAA, as well as other transportation 

demand management and transportation 

systems management strategies. 

Integrated, area-wide TCM are developed, 

adopted and implemented by Metropolitan 

Planning Organizations, in accordance with 

state and federal mandates. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Chapter 6: District Strategy 

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Table 6-1 EPA’s List of Suggested PM2.5 Control Measures (continued) 

 EPA Control Measure District Equivalent 

MSM-5 

Programs to reduce emissions or 

accelerate retirement of high emitting 

vehicles, boats, and lawn and garden 

equipment. 

District programs include incentives for 

scrapping high-emitting cars and trucks and 

replacing gas-powered lawn mowers with 

electric mowers. State regulations require 

lower emissions from engines for boats, offroad equipment and lawn care equipment. 

MSM-6 Emissions testing and repair/ maintenance 

programs for on-road vehicles. 

ARB regulations mandate an enhanced smog 

check for on-road vehicles in non-attainment 

areas. State funds are available to subsidize 

repairs or scrapping of high-emitting vehicles. 

MSM-7 

Emissions testing and repair/maintenance 

programs for non-road heavy-duty vehicles 

and equipment. 

ARB has adopted stringent standards for a 

wide variety of non-road equipment from 

forklifts to construction equipment. 

MSM-8 Programs to expand use of clean burning 

fuels. 

ARB is developing standards for alternative 

and low-carbon fuels. 

MSM-9 

Low emissions specifications for equipment 

or fuel used for large construction 

contracts, industrial facilities, ship yards, 

airports, and public or private vehicle fleets. 

Over $1 billion in state funds will be available to 

reduce emissions from equipment at ports and 

from long-haul trucking along major goods 

movement corridors. 

MSM10 

Opacity or other emissions standards for 

‘‘gross-emitting’’ diesel equipment or 

vessels. 

ARB regulations mandate an enhanced smog 

check for on-road vehicles in non-attainment 

areas. State funds are available to subsidize 

repairs or scrapping of high-emitting vehicles. 

Area Source Measures

ASM-1 

New open burning regulations and/or 

measures to improve program 

effectiveness such as programs to reduce 

or eliminate burning of land clearing 

vegetation 

District Rule 4103 (Open Burning) addresses 

the Valley's agricultural burn management 

program. Additional burn restrictions are 

scheduled for 2010. Burning is prohibited for 

non-agricultural purposes, such as land 

clearing for residential or commercial 

development. 

ASM-2 

Programs to reduce emissions from 

woodstoves and fireplaces including 

outreach programs, curtailments during 

days with expected high ambient levels of 

PM2.5, and programs to encourage 

replacement of woodstoves when houses 

are sold. 

District Rule 4901 (Wood Burning Fireplaces 

and Wood Burning Heaters) strictly regulates 

the installation of such devices in new or resold 

homes. It also includes mandatory burn 

prohibitions that are publicized through the 

highly successful "Check Before You Burn" 

program. 

ASM-3 Controls on emissions from charbroiling 

or other commercial cooking operations. 

District Rule 4692 (Commercial Charbroiling) 

mandates exhaust controls on certain 

charbroiling operations. 

ASM-4 

Reduced solvent usage or solvent 

substitution (particularly for organic 

compounds with 7 carbon atoms or more, 

such as toluene, xylene, and trimethyl 

benzene). 

In September 2007, the Governing Board 

amended eleven District rules to dramatically 

reduce the emissions from cleaning solvents 

from automobile refinishing operations, metal 

and wood product fabricators, printers, and 

other similar sources. 
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Chapter 6: District Strategy 

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6.3 STATIONARY SOURCE CONTROL MEASURES 

As discussed in Section 6.2, EPA provided federal guidance for analyzing possible 

RACT/RACM. This section describes the District’s process to exhaustively consider 

control measures, in accordance with those guidelines, which could be included as part 

of the stationary source regulatory component. The detailed descriptions of the control 

measures are included in Appendix I, Candidate Control Measures. Tables 6-2 and 6-

3a to 6-3c include a summary list of the stationary source control measures and the 

reductions they are expected to achieve. 

In scheduling rule development projects, the District is giving priority to NOx controls. 

NOx reductions yield the most benefit for reducing both PM2.5 and ozone in the San 

Joaquin Valley Air Basin. The tables also include control measures for SO2, and 

directly emitted PM2.5, since ARB modeling indicates these reductions are required to 

demonstrate attainment. 

The District’s regulations address emissions from specific source categories, or 

facilities, within the San Joaquin Valley Air Basin: 

 “Source categories” identify types of equipment or processes. Examples include 

devices such as boilers and dryers, and processes, such as application of paints 

and solvents. 

 In general, “facilities” are businesses or institutions which have one, several, or 

many different source categories, at specific locations. Examples include oil 

refineries, food processing plants, confined animal facilities, and glass 

manufacturing. 

6.3.1 Process for Identifying and Evaluating Potential Control Measures 

To generate ideas for control measures, District staff has taken the following steps: 

 Conducted a brainstorming effort involving staff from the Planning, Permits, and 

Compliance departments. 

 Reviewed recommendations from the 2003 ARB audit of District rule making 

activities, as well as the 2007 ARB staff report, “Accelerating Attainment in the 

San Joaquin Valley.” 

 Reviewed Further Study Measures in the District’s 2007 Ozone Plan.

 Reviewed control measures suggested by the public since the adoption of the 

2007 Ozone Plan, as part of the District’s “Fast Track” program. 

 Investigated control strategies and measures in other districts and agencies, 

including the South Coast AQMD, Sacramento Metropolitan AQMD, Bay Area 

AQMD, and Ventura County APCD. 
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 Reviewed all District rules affecting NOx, VOC, SOx and PM to assess 

possibilities for strengthening and expanding their applicability, including using 

Best Available Control Technologies, whenever feasible. This review involved a 

thorough comparison of the District’s rules with those from other air districts. 

 Evaluated EPA’s list of possible PM2.5 control measures listed in Table 6-1. 

 Defined emission control scenarios to investigate via modeling exercises. These 

include the possibilities of episodic and geographic control measures, patterned 

after the District’s highly successful rule for wood-burning fireplaces. 

 Additional control measures or refinements of listed control measures may also 

occur based on comments received during the public review of the draft plan and 

during the future rule development process. 

 District staff also evaluated the controls recommended by the International 

Sustainable Systems Research Center (ISSRC) in its draft document “Clearing 

the Air: A Path to Clean Air by 2017”, dated August 2007. District staff under the 

2007 Ozone Plan commitments is already proposing some recommendations, 

such as the use of selective catalytic reduction on large boilers. However, where 

applicable, ISSRC recommendations were added to the control measure 

descriptions in Appendix I for further consideration during rule development. 

Appendix I includes a Control Measure discussion for each category in the emission 

inventory. Each Control Measure discussion is a description of the source category, 

current control levels, future control options, concerns regarding the implementation of 

controls, and potential emission reductions. The Stationary Source Regulatory 

Implementation Schedule, Table 6-2, shows the schedule for regulatory adoption and 

implementation of the emission reductions. The schedule was developed based on a 

variety of factors, including: 

 Technological feasibility and practicality of emission controls; 

 Magnitude of emissions from the source category and likely emission reductions; 

 Possible uncertainty in the emission inventory of the source category; 

 Cost, financial impacts, and potential for socioeconomic impacts (e.g., 

employment, profitability); 

 District authority and enforceability of emission reductions; 

 Rate and timing of emissions reductions; 

 Public acceptability, including interests and concerns of community members; 

 Pollutants reduced – NOx, PM2.5, VOC, SO2, or multiple pollutants; 

 Any potential adverse environmental impacts; and 

 Potential for disparate environmental impacts (environmental justice). 

District staff also evaluated the Emission Inventory Codes (EIC) for several source 

categories that were not assigned to control measures in the 2007 Ozone Plan. Where 
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possible, the unassigned EIC and corresponding emissions were placed in an 

appropriate Control Measure in Appendix I. District staff also made adjustments to the 

Emissions Inventory for the unassigned EIC based on the District’s updated Area 

Source Emission Inventory methodology. These adjustments have also been 

incorporated in the appropriate Control Measures presented in Appendix I. District staff 

will continue to evaluate remaining unassigned EIC and determine if any further 

adjustments to the emissions inventory are warranted or if the EIC emissions are either 

errors in the inventory, too small to be significant, or are not able to be controlled by 

traditional controls or incentive measures. 

A few source categories are not being pursued in this planning effort. The control 

measure evaluation process brought to light that for some categories there is a lack of 

activity or sources operating within the District. Reductions from any control measure(s) 

that are completed and adopted by the District Governing Board before the adoption of 

this plan will be added to Appendix B. In addition, any source categories that are 

directly under ARB’s jurisdiction and control are being deferred to ARB for further 

discussion and will be found in later chapters of this plan. Mobile source categories that 

are outside of the District’s jurisdiction, but for which incentive programs will be 

developed to achieve reductions, are discussed in Chapter 7 of the 2007 Ozone Plan. 

6.4 IMPLEMENTATION SCHEDULE FOR STATIONARY SOURCE CONTROL 

MEASURES 

Table 6-2 lists the candidate regulatory stationary source control measures and shows 

the rule adoption completion date; the rule compliance and emission reduction 

implementation dates. The schedule shown in Table 6-2 demonstrates a reasonable 

implementation schedule with all of the proposed measures being developed by 2010 

and compliance implementation starting no later than 2012. 

The emission reductions estimates in Tables 6-3a to 6-3c are based on control 

techniques existing at the time this plan was developed. The District expects that 

technologies will advance and that new, more effective control techniques may be 

available at the time of rule development for each measure. Any more effective control 

techniques will be considered during the rule development project. Additionally, the 

District will consider episodic controls and regionally focused controls during each rule 

development project in order to optimize the benefits of each measure while mitigating 

undue impacts to the regulated sources. 

It should be noted that the emission reductions for NOx, PM2.5, and SOx indicated in 

Tables 6-3a, 6-3b and 6-3c, respectively, are discussed in detail in each of the Control 

Measure narrative stationary source category in Appendix I. The VOC emission 

reductions from the 2007 Ozone Plan are not currently included as part of Appendix I of 

the PM2.5 Plan. According to EPA guidance, VOC controls would only be included in a 

PM2.5 plan if required based on modeling. The indicated VOC measures are, however, 

commitments in the 2007 Ozone Plan, so the reductions will be achieved. 
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Additional work on source categories will continue through the development of 

feasibility/future studies listed in Table 6-4. These studies will provide the background 

needed in determining which source categories might be viable control measures for 

additional reductions beyond the 2012 date, if needed for attainment or continued 

maintenance of the PM2.5 NAAQS. 

Considering the overwhelming attainment challenge in the upcoming years, it was 

imperative to consider a strategy that encompasses all opportunities to include: 

regulatory approaches, program improvements, incentive programs, feasibility studies 

for source categories that are not well understood but may prove to be fruitful in a future 

rulemaking schedule, as well as those measures that will not be pursued further due to 

lack of sources or the activity does not occur during the PM2.5 season. For additional 

discussion on the overall strategy that includes all four strategy components, please see 

Chapter 4 of the 2007 Ozone Plan. 

For the purposes of implementing this plan, the District is committed to developing and 

implementing control measures that will achieve, in aggregate, the emissions reductions 

specified in Tables 6-3a through 6-3c. 

Table 6-2 Stationary Source Regulatory Implementation Schedule

CM# Measure 

Name 

Completion

Date 

Compliance 

Date 

Reduction 

Start

S-AGR-1 Open Burning 2010 2Q 2010 2009 

S-COM-1 

Boilers, Steam Generators 

and Process Heaters 

(>5 MM Btu/hr) 

2008 3Q 2012 2012 

S-COM-2 

Boilers, Steam Generators 

and Process Heaters 

(2 to 5 MMBtu/hr) 

2008 3Q 2012 2012 

S-COM-3 

Boilers, Steam Generators 

and Process Heaters 

(0.075 to <2 MMBtu/hr) 

2009 4Q 2011 2011 

S-COM-5 Stationary Gas Turbines 2007 3Q 2012 2012 

S-COM-6 Reciprocating Internal 

Combustion Engines 2010 4Q 2012 2012 

S-COM-7 Glass Melting Furnaces 2008 3Q 2009 2009 

S-COM-9 Residential Water Heaters 2009 1Q Attrition 2011 

S-COM-10 Natural Gas-Fired, Fan Type 

Residential Central Furnace 2010 2Q Attrition 2012 

S-COM-11 Wood Burning Fireplaces and 

Wood Burning Heaters 2009 3Q 2010 2010 

S-IND-9 Commercial Charbroiling 2009 2Q 2011 2011 
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Table 6-2 Stationary Source Regulatory Implementation Schedule

CM# Measure 

Name 

Completion

Date 

Compliance 

Date 

Reduction 

Start

S-IND-21 Flares 2009 2Q 2010 2010 

M-TRAN-1 Employer Based Trip 

Reduction Programs 2009 4Q 2012 2011 

VOC control measures are not included in either Table 6-2 or Appendix I, since modeling 

did not show that the measures are necessary for attainment. Because those measures 

are commitments in the 2007 Ozone Plan, rule development is already required and the 

reductions will occur even if they are not PM2.5 commitments. 

Emission reduction estimates are summarized in Tables 6-3a through 6-3c. If the 

reductions were not known, due to uncertainty in emission factors, controls efficiency, or 

inventory, the control measure may have been excluded from the tables for clarity. This 

is not to imply that no reductions are expected from a control measure, only that the 

amount of reductions could not be estimated at this time.
San Joaquin Valley Unified Air Pollution Control District 

Chap

6-11 Table 6-3a - NOx Emissions Reductions

Winter NOx Reductions (tons/day) Annual Average NOx R

2009 2010 2011 2012 2013 2014 2009 2010 2011 2

S-AGR-1 Open Burning 1.84 2.96 4.07 4.05 4.04 4.02 1.21 1.95 2.68 

S-COM-1 

Boilers, Steam Generators and Process Heaters (>5 MM Btu/hr) 

0 0 0 1.43 1.44 1.46 0 0 0 

S-COM-3 

Boilers, Steam Generators and Process Heaters (0.075 to <2 MMBtu/hr) 

0 0 0.13 0.28 0.41 0.57 0 0 0.12 

S-COM-5 Stationary Gas Turbines 0 0 0 2.20 2.20 2.20 0 0 0 S-COM-7 Glass Melting Furnaces 1.22 1.25 1.18 1.60 1.67 1.58 1.22 1.25 1.18 S-COM-9 Residential Water Heaters 0 0 0.20 0.25 0.32 0.40 0 0 0.20 

S-COM-14 

Wood Burning Fireplaces and Wood Burning Heaters 

0 0.08 0.15 0.14 0.14 0.13 0 0.04 0.08 

TOTAL NOx REDUCTIONS 3.06 4.29 5.73 9.95 10.22 10.36 2.43 3.24 4.26 
San Joaquin Valley Unified Air Pollution Control District 

Chap

6-12 Table 6-3b - PM2.5 Emissions Reductions

Winter PM2.5 Reductions (tons/day) Annual Average PM2.5 

(tons/day) 

2009 2010 2011 2012 2013 2014 2009 2010 2011 201

S-AGR-1 Open Burning 2.41 3.88 5.34 5.32 5.30 5.28 1.60 2.57 3.53 3.5

S-COM-1 

Boilers, Steam Generators and Process Heaters (>5 MM Btu/hr) 

0 0 0 0.22 0.22 0.22 0 0 0 0.2

S-COM-14 

Wood Burning Fireplaces and Wood Burning Heaters 

0 0.76 1.48 1.43 1.39 1.35 0 0.39 0.76 0.7

S-IND-9 Commercial Charbroiling 0 0 2.16 2.21 2.25 2.28 0 0 2.17 2.2

TOTAL PM2.5 REDUCTIONS 2.41 4.64 8.98 9.18 9.16 9.13 1.60 2.96 4.46 6.6

Table 6-3c - SOx Emissions Reductions

Winter SOx Reductions (tons/day) Annual Average SOx Reduc

2009 2010 2011 2012 2013 2014 2009 2010 2011 201

S-AGR-1 Open Burning 0.09 0.14 0.20 0.20 0.20 0.20 0.06 0.10 0.14 0.1

S-COM-1 

Boilers, Steam Generators and Process Heaters (>5 MM Btu/hr) 

0 0 0 0.76 0.76 0.76 0 0 0 0.7

S-COM-14 

Wood Burning Fireplaces and Wood Burning Heaters 

0 0.01 0.03 0.03 0.03 0.03 0 0.01 0.02 0.0

M-TRAN-1 Employer Based Trip Reduction Programs TBD TBD TBD TBD TBD TBD TBD TBD TBD TB

TOTAL SOx REDUCTIONS 0.09 0.15 0.23 0.99 0.99 0.99 0.06 0.11 0.16 0.9
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If not enough information is available to satisfactorily evaluate a particular control 

measure, it is included as a feasibility study measure. Emissions reductions from 

feasibility studies are not currently quantifiable. These studies will be conducted in 

addition to the regulatory measures and will engage the public and industry in 

uncovering new, potential emission reduction opportunities. Study reports will be 

released by the completion dates listed in Table 6-4. Studies that point toward possible 

emission reductions opportunities will be included in future plan updates with specific 

development schedules and emission reductions commitments. 

Table 6-4 Feasibility Study Implementation Schedule 

CM# Measure Name Completion 

Date 

S-AGR-2 Conservation Management Practices 2010 

S-COM-4 Solid Fuel Boilers Steam Generators, Process Heaters 2009 

S-COM-6A Small Spark-Ignited Engines and Agricultural SparkIgnited Engines 2008 

S-COM-8 Lime Kilns 2011 

S-COM-11 Dryers 2011 

S-GOV-6 Prescribed Burning 2008 

S-IND-8 Cotton Gins 2009 

S-IND-4 Fugitive PM10 Prohibitions (Regulation VIII) 2009 

M-OTH-8 Indirect Source Review (ISR) Enhancement 2010 

M-OTH-10 Fireworks 2012 

6.5 DISTRICT INCENTIVE PROGRAMS 

The District has operated highly successful grant programs since 1992, and several of 

these programs have expanded in funding and increased in sophistication over the 

years. The District is currently operating two incentive programs aimed at reducing 

precursor emissions: the Heavy-Duty Engine Emission Reduction Incentive Program 

(Heavy-Duty Engine Program) and the Reduce Motor Vehicle Emissions II (REMOVE II) 

Program. As opportunities to achieve cost-effective emission reductions present 

themselves and funding becomes available, the District has been willing to develop new 

programs and to add new components for existing programs. 

Since 1992, the District has awarded over $180 million to projects that have resulted in 

approximately 58,000 tons of lifetime emission reductions with a cost-effectiveness of 

approximately $2,600/ton. In 2006 alone, the District executed 473 agreements through 

the incentive programs for a total of $43.9 million. The types of projects funded include 

diesel agricultural irrigation pump replacements, on-road and off-road vehicle engine 

replacements, new vehicle purchases, locomotive replacements, vanpools, bicycle path 
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construction and transit pass subsidies. Over the project life, these projects are 

expected to reduce 7,850 tons of NOx, PM, and ROG or VOC. 

When developing new incentive programs, the District begins by securing funding. 

Then, after any necessary and appropriate discussions with the California Air 

Resources Board (ARB) and federal Environmental Protection Agency (EPA), the 

District develops a proposed framework for the policies and procedures for program 

administration. These procedures are designed to ensure efficient program 

administration, applicant and District accountability, and adequate enforcement 

authority. Typically, new incentive policies and procedures are based on existing ARB 

guidance documents, such as the Carl Moyer Program Guidelines. The District then 

presents the proposed framework to the public for comments. Upon receiving 

comments, District staff refines the framework as appropriate and develops a policies 

and procedures document for program administration. This document is presented at a 

public meeting where the ARB, EPA, and public have an opportunity to comment. 

Finally, the document is presented to the District's Governing Board for approval. Upon 

approval by the District's Governing Board, the new program is implemented in 

accordance with the approved policies and procedures document. 

In order to maximize SIP creditability of District incentive-based reductions, the District 

will implement the incentive program changes as described in Chapter 7 of the adopted 

and state-approved 2007 Ozone Plan as well as the accompanying resolution on SIP 

creditability of incentive-based emission reductions. 

6.5.1 Types of Incentive Programs 

6.5.1.1 Heavy-Duty Engine Emission Reduction Incentive Program 

The Heavy-Duty Engine Program is by far the District's largest and most successful 

incentive program. The Heavy-Duty Engine Program accepts applications for a wide 

variety of engines that power vehicles or equipment. It provides funding for new 

purchases (differential cost only, in most cases), engine repowers, and/or retrofits. 

Emission reductions are obtained when the project applicant purchases vehicles and/or 

engines that are cleaner than required by current emission standards or installs 

emission certified/verified retrofit kits on existing engines. The District pays a portion of 

the differential cost of purchasing the lower emitting technology compared to 

conventional technology up to a cost-effectiveness cap of $14,300 per combined tons of 

NOx, PM and VOC. 

The first projects that were funded began operating in 1998. Each year since then, 

additional funds have been allocated to the program and additional projects have 

become operational. Project life varies from 3 to 20 years depending on the application, 

with an average project life of 5 years based on the mix of projects received to date. 

Emission reductions are cumulative since additional projects are completed each year. 
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The 2003 PM10 Plan projected emission reductions utilizing currently available funding 

would amount to 6.3 tons per day of NOx by 2005. The 2003 PM10 Plan also indicated 

that the District expected additional funding would be obtained to allow continued 

emission reductions in later years. 

The most successful component of the Heavy-Duty Engine Program is the replacement 

of agricultural irrigation pump engines used for water pumping. Approximately 65% of 

all engines re-powered have been uncontrolled diesel agricultural irrigation pump 

engines that have been replaced with new engines meeting current off-road engine 

standards or electric motors. 

In addition to the Agricultural Irrigation Pump Engine Component, other principal 

components of the Heavy-Duty Engine Program are the On-Road Vehicle Component, 

Off-Road Vehicle Component, Locomotive Component, Marine Vessel Component, 

Forklift Component, Airport Ground Support equipment, Idle Reduction Component, and 

Alternative Fuel Infrastructure Component. 

6.5.1.2 REMOVE II Program 

The Reduce Motor Vehicle Emissions (REMOVE) Program was the District's first 

incentive program. It began its first phase in 1992. The District has developed a new, 

enhanced program (REMOVE II) that was approved by the Governing Board in 

February 2005. REMOVE II reduces emissions from light- and medium-duty motor 

vehicles in the District. The purpose of this grant program is to assist the District in 

attaining air quality standards. This is accomplished by allocating funds to cost-effective 

projects that have the greatest motor vehicle emission reductions, thereby creating 

long-term air quality benefits for the San Joaquin Valley. All projects must have a direct 

air quality benefit to the District. Any portion of a project that does not directly benefit 

the District within its boundaries is not allowed for funding or in calculating emission 

reductions. 

Principal components of the REMOVE II Program are the Light- and Medium-Duty 

Vehicle Component, the E-Mobility (Telecommunications) Component, the Bicycle 

Infrastructure Component, the Public Transportation and Commuter Vanpool Subsidy 

Component, Accelerated Vehicle Retirement Component and the Alternative Fuel 

Vehicle Mechanic Training Component. 

6.5.1.3 Light and Medium-Duty Vehicle Incentive Program 

In 2002, the District completed a highly successful Light and Medium-Duty Vehicle 

Incentive Program. The program provided incentives for the purchase of low-emission 

passenger vehicles, light trucks, small buses, and trucks less than 14,000 pounds gross 

vehicle weight. The purpose of the program was to encourage the early introduction of 

low-emission vehicles in the District. The program paid between $1,000 and $3,000 per 
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vehicle depending on the emission certification level and size of the vehicle. Vehicles 

were required to be powered by alternative fuel, electricity, or hybrid electric 

engines/motors. Emission reductions from vehicles purchased under this program were 

claimed under ARB's Low Emission Vehicle program. These types of vehicle projects 

are now funded through the REMOVE II Program. 

6.5.1.4 Electric Lawnmower Incentives 

For the last several years, the District has operated an electric lawnmower exchange 

incentive program known as the Clean Green Yard Machine Program. The District 

worked with electric lawnmower manufacturers and local equipment dealers to provide 

large discounts to people who turned in their gasoline-powered mowers in exchange for 

electric or push-type lawn mowers. For 2004, District funding provided discount 

coupons for electric and push-type lawn mowers and 327 mowers were sold in 2004 

under the coupon program. In 2005, the District sold 595 electric lawn mowers to 

District residents who traded-in their old gas-powered mowers. In 2006, the District 

increased the program and sold 798 electric mowers over the course of five events. 

This is an example of a new program that will likely be continued in coming years if 

funding is available. 

6.5.1.5 Woodstove Changeout Incentives 

In the 2006-2007 wood burning season, the District, in partnership with Operation Clean 

Air, initiated its “Burn Cleaner” program that offered financial incentives to change out 

old wood-burning fireplaces, stoves and inserts for cleaner-burning options. The District 

used a voucher program over a six-week period; 33 Valley hearth retailers participated, 

and 14 recyclers in the Valley crushed old devices. The District issued more than 500 

vouchers to Valley residents, and about $50,000 in funds was paid to retailers. The 

District plans to continue this program for the 2007-2008 season. 

6.5.2 Existing Incentive Funding Sources in the San Joaquin Valley 

Current programs use a combination of state and local funds, including ARB's Carl 

Moyer Program, the District’s Department of Motor Vehicles Surcharge Fees (DMV 

Fees), Indirect Source Review (ISR) fees and Voluntary Developer Mitigation Contract 

(DMC) fees, as shown in Table 6-5. The District has achieved significant, cost-effective 

emission reductions from a variety of grant programs and will seek funding for costeffective programs from all potential sources. Emission reductions claimed for this plan 

are based on funding already committed, as shown in the table below. The mix of 

locally generated funding, state funding, and federal funding will vary. 
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Table 6-5 Existing Funding Sources 

Source Estimated Annual 

Available Funding* 

Funding 

Duration 

DMV Surcharge Fees $10 Million On-going 

Moyer Funds $10 Million 7 Years 

ISR/DMC Funds $20 Million On-going 

Total $40 Million 

* The total available funding can potentially be reduced by approximately $15 million per 

year beginning in 2016 unless reauthorizations are granted for the Moyer Program and 

$2 DMV Surcharge Fee (AB 923) funds. 

Calculating the reductions expected from incentive programs involves several steps and 

assumptions. First, although the project life for each project is expected to be 10 years, 

the District conservatively calculates reductions for the first three years of the project 

under the assumption that if the equipment hadn’t been replaced under the grant, then 

after three years, the old equipment would have been replaced under natural fleet 

turnover. Therefore, grant funds awarded in 2007 are expected to achieve surplus 

reductions in 2007, 2008, and 2009. Also, to calculate the total reductions being 

achieved by incentive programs in 2009, for example, the reductions from funds 

distributed in 2009, 2008, and 2007 are considered. Second, the cost effectiveness 

(cost per ton of reductions) for District incentive programs in 2007 is $14,300 per ton. 

The cost per ton increases over time due to inflation, so the District assumes a 6% 

increase in cost effectiveness each year. Third, the total secured incentive funding 

decreases with the expiration of Moyer and part of the total DMV fees in 2015, unless 

these programs are re-authorized by the California Legislature. The total NOx 

reductions achieved by incentive programs with secured funding in key years are shown 

in Table 6-6. 

Table 6-6 NOx Reductions Achieved by District Incentive Measures with Assured 

Funding 1

1

 Reductions achieved with Moyer incentives are not included in 

the reductions listed here since ARB takes credit for appropriated 

Moyer funds in the emissions inventory reported in Appendix B. 

Year NOx Reductions (tpd) 

2012 1.4 

2020 0.7 

2023 0.6 
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6.5.2.1 DMV Surcharge Fees 

State law provides air districts that are designated as state non-attainment for a 

pollutant emitted by motor vehicles to receive revenues from motor vehicle surcharge 

fees collected and disbursed by the State Department of Motor Vehicles. Legislation 

(AB 2766) was enacted in 1990 to enable air districts to receive up to a $4 surcharge 

per vehicle on motor vehicle registration fees. These fees provide air districts with 

funds to meet their responsibilities mandated under the California Clean Air Act (CCAA) 

without raising fees on stationary sources. The California Health and Safety Code 

states that these motor vehicle surcharge fees shall be used to support air districtoperated planning, monitoring, enforcement, and technical studies necessary to 

implement the CCAA, including incentive programs that reduce motor vehicle 

emissions. 

Additional legislation (SB 709) was enacted in 2003 allowing the District to receive an 

additional $1 surcharge per motor vehicle. The funds generated by this surcharge may 

only be used to reduce emissions from vehicular sources, including, but not limited to 

the establishment of a clean fuels program and the adoption and implementation of 

motor vehicle use reduction measures. The District may utilize up to 2 percent of the 

funds received for administrative expenses. 

In 2004, air districts were allowed to adopt an additional $2 motor vehicle surcharge fee 

(AB 923). The funds generated by this additional surcharge may be used only to 

reduce emissions from certain motor vehicle and agriculture sources, including Carl 

Moyer Program projects, and for the new purchase, retrofit, repower, or add-on 

equipment for previously unregulated agricultural sources, school buses, and an 

accelerated vehicle retirement or repair program. The District may utilize up to 5 

percent of the funds received for incentive program administrative expenses. This 

additional surcharge will remain in effect only until January 1, 2015, unless reauthorized by the California Legislature. 

It is estimated that approximately $10 million per year will be available for incentive 

grants from District DMV fees. 

6.5.2.2 Carl Moyer Memorial Air Quality Standards Attainment Program 

The Carl Moyer Memorial Air Quality Standards Attainment Program (Moyer Program) 

is a grant program, implemented by a partnership of the ARB and local air districts, 

which funds the incremental cost of cleaner-than-required engines, equipment, and 

other sources of pollution. Eligible project types include on-road heavy-duty vehicles, 

idle reduction technologies, off-road diesel equipment, transportation refrigeration units, 

off-road spark-ignited equipment, marine vessels, locomotives, and agricultural engines. 

Legislative changes enacted in 2004 provide increased and continued funding for the 

Moyer Program through 2015, unless re-authorized by the California Legislature. 
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It is estimated that approximately $10 million per year will be available to the District for 

incentive grants from Moyer Program funds. 

6.5.2.3 Indirect Source Review and Voluntary Developer Mitigation Contract 

Funds 

The District’s ISR Rule was developed to achieve a number of goals, including the 

reduction of NOx and PM emissions from new development projects. The rule requires 

a certain amount of emission reductions from each development project, which can be 

achieved by utilizing one of several approaches. Paying a fee to fund projects that will 

reduce emissions off-site is an option for rule compliance. Funds from this option will be 

used for NOx and PM emission reduction projects through the District’s incentive 

programs. Additionally, funds are also derived from developer mitigation contracts in 

which certain developers choose to mitigate 100% of the emissions from their 

development projects. These fees are then used to fund emission reduction projects 

through the District’s incentive programs. 

For the purpose of this analysis, it is estimated that approximately $20 million per year 

will be available for incentive grants from ISR and DMC fees. 

6.5.3 Potential Future Incentive Funding 

Current state and local funds available to the San Joaquin Valley for incentive-based 

programs in the District 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. Additionally, the San Joaquin Valley receives funding that 

can be utilized for air quality projects that is allocated by agencies other than the 

District. The District is expecting to receive five major sources of new incentive funding: 

Table 6-7 Estimated New Funding Sources 

Funding Source Estimated Annual 

New Funding 

Funding 

Duration 

Federal Funding $5 Million 1 Year 

Proposition 1B (Goods 

Movement Infrastructure) 1 $50 Million 4 years 

Great Basin UAPCD $223,000 1 Year 

Low Emission School Bus 

Program $20 Million 2 Years 

Total $75.2 Million 

1

 ARB approved the first distribution of funding at a public hearing held 

on February 28, 2008. More information is available at: 

www.arb.ca.gov/bonds/gmbond/gmbond.htm 
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The federal transportation-funding program provides Congestion Mitigation and Air 

Quality (CMAQ) funds to non-attainment areas to fund transportation projects that 

improve air quality. These funds are allocated by the eight county level Metropolitan 

Planning Organizations (MPOs) in the Valley. While the draft guidance for the 

allocation of CMAQ funding provides a renewed focus on cost-effective emissions 

reduction projects, transportation agencies often weigh other criteria, such as 

congestion relief, when allocating CMAQ funds. 

The federal farm bill provides air quality funding through the Environmental Quality 

Incentives Program (EQIP). EQIP funds are distributed by the Natural Resource 

Conservation Service (NRCS). San Joaquin Valley agriculture receives approximately 

$5.5 million per year in EQIP funding. These funds can be utilized for dust control 

activities and to reduce emissions from agricultural engines. Historically, approximately 

$1.15 million per year has been utilized to reduce emissions from agricultural engines; 

however, the program does not require that the funds be utilized for any particular 

category. 

The Environmental Protection Agency (EPA) administers funding from the Diesel 

Emissions Reduction Account (DERA) to fund projects that reduce emissions from 

diesel engines. The DERA program is a national program that has been authorized, but 

never fully funded, at $200 million per year. To date, the San Joaquin Valley has 

received approximately $700,000 in DERA funding. However, the Valley could 

potentially receive up to $7.5 million in future near-term DERA funding. 

6.6 DISTRICT INNOVATIVE STRATEGIES AND PROGRAMS 

6.6.1 Fast Track 

On April 30, 2007, the District Governing Board approved an innovative and 

comprehensive “dual-path” strategy to attain cleaner air, meeting the federal 8-hour 

ozone standard as expeditiously as possible. The dual path includes the State 

Implementation Plan for ozone, and a “Fast Track” set of strategies of types that have 

not historically been approved in state implementation plans. The Fast Track measures 

are designed to significantly reduce emissions as expeditiously as possible, well in 

advance of the 2024 attainment deadline. 

The Fast Track contains three primary components: 

1. Assuring effective and expedited regulations by California Air Resources 

Board (ARB) and EPA: Attaining the federal 8-hour ozone standard will require 

a 75% reduction in NOx emissions. 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 
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sources. 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 work diligently to ensure 

stringent and expeditious controls on mobile sources are promulgated and 

implemented by ARB and EPA. Toward that end, the District will take a 

leadership role in devising effective control measures for mobile sources and will 

utilize all available administrative, regulatory, legislative, and legal avenues to 

pressure ARB and EPA to do their fair share in controlling emissions from 

sources under their jurisdiction. 

2. Significant increase in incentive funding: There is broad consensus that 

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. 

3. Fast Track emission reduction measures: Reaching attainment ahead of the 

2024 deadline will require development and implementation of a number of bold, 

innovative, and creative measures. The following is a list of such measures as 

outlined in the District’s 2007 Ozone Plan: 

• Green Contracting: Encourage or require government agencies and 

private businesses to give preference to contractors/vendors who use lowemission processes and equipment. District does not currently have the 

authority to mandate green contracting. 

• Green Fleets: Encourage or require government agencies and private 

businesses to upgrade existing fleets with low-emission vehicles. District 

does not currently have the authority to mandate the use of green fleets by 

private businesses. 

• Truck Replacement/Retrofit/Repower: Provide incentives for early and 

cost effective fleet modernization. This could potentially produce 40 tons 

per day (tpd) NOx emissions reductions at a cost of approximately $1.5 

billion. The measure will depend heavily on participation and funding. 

• Short Sea Shipping: Reduce heavy-duty truck and locomotive vehicle 

miles traveled through the District by transporting goods by water carriers 

between northern and southern California. If short sea shipping replaces 

20% of daily trips in 2010, approximately 8,000 heavy-heavy duty truck 

movements would be eliminated, resulting in 40 tpd of NOx and 1 tpd of 

PM emissions reductions. 

• High-Speed Rail: Use high-speed rail to transport goods and people 

through the Valley. The California High-Speed Rail Authority projects that 

the system would be capable of handling up to 68 million passengers a 

year by 2020, at a total project cost of $33 billion. 
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• Alternative Energy: Utilize lower-emitting sources of energy such as 

electric, solar, and hydrogen fuel cells, to reduce or slow the growth of 

NOx emissions in the Valley. 

• Energy Conservation: Encourage or require government agencies, 

businesses, and residents to employ measures to reduce energy 

consumption in the San Joaquin Valley. 

• Heat Island Mitigation: Adopt methods and practices, such as urban 

landscaping and highly-reflective roofing, to reduce the surface 

temperatures in urban centers and reduce the need for peak electricity 

generation. Additional benefits include cost savings, reduction of 

greenhouse gases, and aesthetic improvements. The mass planting of 

trees could result in increased water usage, maintenance costs, and 

emission of biogenic VOCs. 

• Episodic/Regional Controls: Incentive and regulatory-based measures, 

such as enhancements to the Spare the Air program, designed to reduce 

ozone concentrations at hot-spot locations during the worst days of the 

ozone season. While the District is not proposing major curtailments in 

activity that could have a devastating effect on the Valley economy (e.g., 

no farm days, no construction days), it may be beneficial to include 

episodic provisions in many incentive and regulatory measures. Each 

year, the District averages 25 Spare the Air days and 100 days with AQI 

levels above 100. 

• Inland Ports: Provide linkages between ports and other modes of 

transportation, such as by train for the delivery of goods. Increase the use 

of cargo containers and truck/rail combinations. 

The Fast Track is being developed in an open public process. The APCO has formed a 

task force comprised of members from environmental organizations, industry 

representatives, and the Governor’s San Joaquin Valley Partnership. District staff has 

been meeting regularly with the Fast Track Task force to devise and advance the new 

and innovative measures for early attainment. The Fast Track Task Force will fulfill four 

important roles: 

• An advisory group for refining Fast Track strategies; 

• A source for new ideas for Fast Track strategies; 

• Outreach to inform decision-makers and the public on the Dual Path and Fast 

Track concepts; and 

• Advocacy to help develop the means (i.e., funding for incentives) to implement 

Fast Track strategies. 

The District will also prepare an annual Fast Track Report and present it to the 

Governing Board. For more information on the Fast Track please visit: 

http://valleyair.org/Programs/FastTrack/FastTrackIdx.htm
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6.6.2 Healthy Air Living 

The Healthy Air Living initiative is a lifestyle program aimed at giving businesses, 

communities, civic organizations, municipalities, health organizations, families and all 

Valley residents the tools they need to make substantial permanent lifestyle and 

behavior changes which will reduce emissions in the Valley year-round. 
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