GOVERNING BOARD

Tom Wheeler, Chair

Supervisor, Madera County

Oliver L. Baines III, Vice Chair

Councilmember, City of Fresno

Sally J. Bomprezzi

Councilmember, City of Madera

Dennis Brazil

Mayor, City of 

John Capitman, Ph.D.

Appointed by Governor

David Couch

Supervisor, Kern County 

Bob Elliott

Supervisor, San Joaquin County

Harold Hanson

Councilmember, City of Bakersfield

Buddy Mendes

Supervisor, Fresno County 

William O’Brien

Supervisor, Stanislaus County

Craig Pedersen

Supervisor, Kings County

Alexander C. Sherriffs, M.D.

Appointed by Governor

Vacant

Small City – Tulare County

Hub Walsh 

Supervisor, Merced County

J. Steven Worthley

Supervisor, Tulare County

Seyed Sadredin

Executive Director

Air Pollution Control Officer

Northern Region Office

4800 Enterprise Way 

Modesto, CA 95356-8718

(209) 557-6400 • FAX (209) 557-6475

Central Region Office

1990 East Gettysburg Avenue

Fresno, CA 93726-0244

(559) 230-6000 • FAX (559) 230-6061

Southern Region Office

34946 Flyover Court

Bakersfield, CA 93308-9725

(661) 392-5500 • FAX (661) 392-5585

www.valleyair.org

DATE: April 16, 2015

TO: SJVUAPCD Governing Board

FROM: Seyed Sadredin, Executive Director/APCO

Project Coordinator: Sheraz Gill 

RE: ITEM NUMBER 7: ADOPT 2015 PLAN FOR THE 

1997 PM2.5 STANDARD, INCLUDING REQUEST 

TO EXTEND ATTAINMENT DEADLINE; APPROVE 

ASSOCIATED COMMITMENTS TO CONTINUE TO 

LEAVE NO STONE UNTURNED IN ASSESSING 

FUTURE AMENDMENTS TO DISTRICT RULES 

THAT MAY PROVIDE ADDITIONAL FEASIBLE 

REDUCTIONS; APPROVE COMMITMENTS TO 

ACHIEVE FURTHER REDUCTIONS IN 

PARTICULATE EMISSIONS AND ITS 

PRECURSORS THROUGH INCENTIVE-BASED 

STRATEGIES TO REPLACE HEAVY DUTY 

TRUCKS AND RESIDENTIAL WOOD BURNING 

DEVICES; APPROVE RESOLUTION 15-4-7B TO 

AMEND RESOLUTION 10-10-14 TO CONTINUE 

NECESSARY AB 2522 DMV FUNDING FOR 

INCENTIVE-BASED COMMITMENTS IN THE PLAN 

TO REDUCE MOBILE SOURCE EMISSIONS

RECOMMENDATIONS:

1. Adopt the Proposed 2015 Plan for the 1997 PM2.5 Standard;

and 

2. Authorize the Chair to sign Resolution 15-4-7A adopting the 

Proposed 2015 Plan for the 1997 PM2.5 Standard and 

requesting an extension of the attainment deadline from 

December 31, 2015 to December 31, 2018 for the 24-hour 

PM2.5 standard and December 31, 2020 for the annual PM2.5 

standard; and 
SJVUAPCD Governing Board

ADOPT 2015 PLAN FOR THE 1997 PM2.5 STANDARD, INCLUDING REQUEST TO EXTEND 

ATTAINMENT DEADLINE; APPROVE ASSOCIATED COMMITMENTS TO CONTINUE TO LEAVE NO 

STONE UNTURNED IN ASSESSING FUTURE AMENDMENTS TO DISTRICT RULES THAT MAY 

PROVIDE ADDITIONAL FEASIBLE REDUCTIONS; APPROVE COMMITMENTS TO ACHIEVE 

FURTHER REDUCTIONS IN PARTICULATE EMISSIONS AND ITS PRECURSORS THROUGH 

INCENTIVE-BASED STRATEGIES TO REPLACE HEAVY DUTY TRUCKS AND RESIDENTIAL WOOD 

BURNING DEVICES; APPROVE RESOLUTION 15-4-7B TO AMEND RESOLUTION 10-10-14 TO 

CONTINUE NECESSARY AB 2522 DMV FUNDING FOR INCENTIVE-BASED COMMITMENTS IN THE 

PLAN TO REDUCE MOBILE SOURCE EMISSIONS

April 16, 2015

3. Authorize the Chair to sign Resolution 15-4-7B to authorize the use of existing AB 

2522 DMV revenues to support commitments for further reductions in emissions 

required by the U.S. Environmental Protection Agency (EPA) to grant a one-time five 

year extension of the attainment deadline, and retain local control to revoke 

imposition of the DMV surcharge fees under AB 2522 upon finding by the Governing 

Board that such revenues are no longer necessary to fulfill mandates under the 

federal Clean Air Act (CAA); and

4. Direct staff to forward the adopted 2015 Plan for the 1997 PM2.5 Standard and 

attached Resolution 15-4-7A to the California Air Resources Board (ARB) for 

approval and submittal to EPA. 

BACKGROUND:

In 1997, EPA set the first National Ambient Air Quality Standard (NAAQS) for particulate 

matter with a diameter that is equal to or less than 2.5 micrometers (PM2.5). EPA set 

the annual standard at 15 μg/m3 and the 24-hour standard at 65 μg/m3

. 

On April 30, 2008, your Board adopted the 2008 PM2.5 Plan satisfying all federal 

implementation requirements for the 1997 federal PM2.5 standard. Per guidance from 

EPA, this plan addressed the 1997 PM2.5 standard under Subpart 1 of federal CAA 

Title 1, Part D (Subpart 1). Subsequently, in 2013, the D.C. Circuit Court ruled that EPA 

erred by solely using CAA Subpart 1 in establishing its PM2.5 implementation rule, 

without consideration of the PM-specific provisions in CAA Title 1, Part D, Subpart 4 

(Subpart 4). In June 2014, EPA then classified the San Joaquin Valley (Valley) as a 

Moderate nonattainment area under Subpart 4 with an attainment date of April 5, 2015. 

EPA recently reclassified the Valley as Serious nonattainment effective May 7, 2015 

with an attainment date of December 31, 2015.

This 2015 PM2.5 Plan addresses the federal mandates for a Serious nonattainment 

area related to the 1997 PM2.5 standard. Building on decades of developing and 

implementing active and effective air pollution control strategies, this plan contains Most 

Stringent Measures (MSM), Best Available Control Measures (BACM), additional 

enforceable commitments for further reductions in emissions, and ensures expeditious 

attainment of the 1997 standard. However, the tortured path that has led to this 

juncture where the District has to rewrite an attainment plan for an old standard 

illustrates the need for modernizing the antiquated provisions of the CAA.

2
SJVUAPCD Governing Board

ADOPT 2015 PLAN FOR THE 1997 PM2.5 STANDARD, INCLUDING REQUEST TO EXTEND 

ATTAINMENT DEADLINE; APPROVE ASSOCIATED COMMITMENTS TO CONTINUE TO LEAVE NO 

STONE UNTURNED IN ASSESSING FUTURE AMENDMENTS TO DISTRICT RULES THAT MAY 

PROVIDE ADDITIONAL FEASIBLE REDUCTIONS; APPROVE COMMITMENTS TO ACHIEVE 

FURTHER REDUCTIONS IN PARTICULATE EMISSIONS AND ITS PRECURSORS THROUGH 

INCENTIVE-BASED STRATEGIES TO REPLACE HEAVY DUTY TRUCKS AND RESIDENTIAL WOOD 

BURNING DEVICES; APPROVE RESOLUTION 15-4-7B TO AMEND RESOLUTION 10-10-14 TO 

CONTINUE NECESSARY AB 2522 DMV FUNDING FOR INCENTIVE-BASED COMMITMENTS IN THE 

PLAN TO REDUCE MOBILE SOURCE EMISSIONS

April 16, 2015

DISCUSSION:

In 2012, after implementing much of the commitments in the 2008 PM2.5 Plan to 

address the 1997 standard, the Valley was on the verge of attaining the standard with 

an average annual concentration of 14.7 μg/m3 and an average 24-hour concentration 

of 56.4 μg/m3 at the Valley’s historic peak PM2.5 sites in Bakersfield. However, due to 

the extreme drought, stagnation, strong inversions, and historically dry conditions 

experienced over the winter of 2013-2014, attainment was impossible even if the Valley 

experienced zero PM2.5 pollution for the last three quarters of 2014. The CAA includes 

provisions for excluding uncontrollable “exceptional events” from a region’s attainment 

determination, but the current EPA framework specifically excludes stagnation and 

drought conditions from qualifying as “exceptional events.” Given that attaining the 

standard in 2015 is physically impossible, the District was compelled to submit a formal 

request for reclassification to Serious nonattainment. This reclassification extended the 

attainment date by eight months to December 31, 2015. Unfortunately, the exceptional 

weather conditions experienced in 2013-2014 also make it impossible to meet the new 

attainment deadline of December 31, 2015. For that reason, this plan is accompanied 

by a request for a one-time extension of the attainment deadline for the 24-hour PM2.5 

standard to 2018 and the annual PM2.5 standard to 2020. 

Adding further confusion, in accordance with federal mandates, in December 2012, your 

Board adopted the 2012 PM2.5 Plan to address the 2006 federal PM2.5 standard. This 

plan was also adopted under Subpart 1 of the CAA following EPA’s guidance at the 

time. To further complicate matters, a few days before your Board adopted the 2012 

PM2.5 Plan, EPA proposed a new PM2.5 standard, which was finalized in the Federal 

Register in January 2013 (2012 PM2.5 Standard, 12 μg/m3 annual). 

The above actions trigger additional federal mandates that can best be described as 

chaotic, with multiple attainment plans required for the same pollutant with each 

standard requiring a separate attainment plan, leading to multiple overlapping 

requirements and deadlines. These mandates are summarized in the table below:

3
SJVUAPCD Governing Board

ADOPT 2015 PLAN FOR THE 1997 PM2.5 STANDARD, INCLUDING REQUEST TO EXTEND 

ATTAINMENT DEADLINE; APPROVE ASSOCIATED COMMITMENTS TO CONTINUE TO LEAVE NO 

STONE UNTURNED IN ASSESSING FUTURE AMENDMENTS TO DISTRICT RULES THAT MAY 

PROVIDE ADDITIONAL FEASIBLE REDUCTIONS; APPROVE COMMITMENTS TO ACHIEVE 

FURTHER REDUCTIONS IN PARTICULATE EMISSIONS AND ITS PRECURSORS THROUGH 

INCENTIVE-BASED STRATEGIES TO REPLACE HEAVY DUTY TRUCKS AND RESIDENTIAL WOOD 

BURNING DEVICES; APPROVE RESOLUTION 15-4-7B TO AMEND RESOLUTION 10-10-14 TO 

CONTINUE NECESSARY AB 2522 DMV FUNDING FOR INCENTIVE-BASED COMMITMENTS IN THE 

PLAN TO REDUCE MOBILE SOURCE EMISSIONS

April 16, 2015

Table 1 Mandated Actions for the 2006 and 2012 PM2.5 Standards

December 2012 District adopted the 2012 PM2.5 Plan to address the 2006 federal 

PM2.5 standard

June 2014 EPA classified the District as a Moderate nonattainment area under 

Subpart 4 for the 2006 federal PM2.5 standard

January 2015 EPA proposed approval of the District’s 2012 PM2.5 Plan as a 

Moderate area plan under Subpart 4

January 2015 EPA proposed to reclassify the District as a Serious nonattainment area 

under Subpart 4 for the 2006 federal PM2.5 standard

Effective 

April 15, 2015

EPA designates the Valley as a Moderate nonattainment area for the 

2012 federal PM2.5 standard

Late 2016

District must submit a new attainment plan under a Serious 

classification for the 2006 federal PM2.5 standard (18 months after 

reclassification)

October 2016

District must submit a Moderate plan for the 2012 federal PM2.5 

standard to justify and request reclassification to Serious nonattainment 

classification

Mid-2018

District must then submit a new attainment plan under a Serious 

classification for the 2012 federal PM2.5 standard (18 months after 

reclassification)

For each of the standards, the District would have federally mandated attainment 

deadlines of 6 years from designation as a Moderate nonattainment area, or 10 years 

from designation as a Serious nonattainment area, and may need to request an 

extension depending on the timing of actions by EPA and mandated deadlines.

Continuous Reductions in Emissions 

Through the comprehensive attainment strategy included in this 2015 PM2.5 Plan, the 

Valley will reduce NOx emissions by 38% between 2012 and 2020 (see Figure 1). In 

addition to these much-needed NOx reductions, the District’s strategy also reduces 

direct PM2.5 emissions that not only assist the Valley in attaining the standard as 

expeditiously as possible, but also reduce the PM2.5 emissions that pose the greatest 

health impacts to Valley residents. These strategies reduce highly health-impactful 

PM2.5 emissions where and when they matter most in Valley neighborhoods, and 

provide health benefits beyond simply attaining the federal standard. 

4
SJVUAPCD Governing Board

ADOPT 2015 PLAN FOR THE 1997 PM2.5 STANDARD, INCLUDING REQUEST TO EXTEND 

ATTAINMENT DEADLINE; APPROVE ASSOCIATED COMMITMENTS TO CONTINUE TO LEAVE NO 

STONE UNTURNED IN ASSESSING FUTURE AMENDMENTS TO DISTRICT RULES THAT MAY 

PROVIDE ADDITIONAL FEASIBLE REDUCTIONS; APPROVE COMMITMENTS TO ACHIEVE 

FURTHER REDUCTIONS IN PARTICULATE EMISSIONS AND ITS PRECURSORS THROUGH 

INCENTIVE-BASED STRATEGIES TO REPLACE HEAVY DUTY TRUCKS AND RESIDENTIAL WOOD 

BURNING DEVICES; APPROVE RESOLUTION 15-4-7B TO AMEND RESOLUTION 10-10-14 TO 

CONTINUE NECESSARY AB 2522 DMV FUNDING FOR INCENTIVE-BASED COMMITMENTS IN THE 

PLAN TO REDUCE MOBILE SOURCE EMISSIONS

April 16, 2015

Figure 1 San Joaquin Valley Emissions Reductions, 2015 PM2.5 Plan

Plan Based on Extensive Scientific Research 

In developing this plan, the District and ARB took full advantage of the extensive 

scientific research and knowledge that has been developed to characterize the Valley’s 

unique air quality chemistry and challenges. The District, through the San Joaquin 

Valley-wide Air Pollution Study Agency, participated in and contributed to the 

expenditure of nearly $30 million to support the California Regional Particulate Air 

Quality Study (CRPAQS). This study, and the subsequent research built on its 

foundation, has shed light on the complexity of PM2.5 in the Valley. Additionally, recent 

health studies highlight the associated risks inherent in the complex components of 

PM2.5. Acknowledgement and understanding of this complexity is central to this 2015 

PM2.5 Plan and was used to form its scientific foundation.

Using the extensive body of knowledge regarding formation of PM2.5 in the Valley, ARB 

performed Relative Response Factor (RRF) modeling to predict future PM2.5 

concentrations throughout the Valley based on previous modeling methodologies used 

in developing the 2008 PM2.5 Plan. This modeling was performed consistent with EPA 

guidance, and involved sophisticated computer modeling and review by a team of 

0

50

100

150

200

250

300

350

2012 2014 2017 2020

Emissions (tons per day)

NOx Emissions PM2.5 Emissions SOx Emissions

5
SJVUAPCD Governing Board

ADOPT 2015 PLAN FOR THE 1997 PM2.5 STANDARD, INCLUDING REQUEST TO EXTEND 

ATTAINMENT DEADLINE; APPROVE ASSOCIATED COMMITMENTS TO CONTINUE TO LEAVE NO 

STONE UNTURNED IN ASSESSING FUTURE AMENDMENTS TO DISTRICT RULES THAT MAY 

PROVIDE ADDITIONAL FEASIBLE REDUCTIONS; APPROVE COMMITMENTS TO ACHIEVE 

FURTHER REDUCTIONS IN PARTICULATE EMISSIONS AND ITS PRECURSORS THROUGH 

INCENTIVE-BASED STRATEGIES TO REPLACE HEAVY DUTY TRUCKS AND RESIDENTIAL WOOD 

BURNING DEVICES; APPROVE RESOLUTION 15-4-7B TO AMEND RESOLUTION 10-10-14 TO 

CONTINUE NECESSARY AB 2522 DMV FUNDING FOR INCENTIVE-BASED COMMITMENTS IN THE 

PLAN TO REDUCE MOBILE SOURCE EMISSIONS

April 16, 2015

technical staff, including close coordination with the District. In addition to the modeling 

by ARB, the District has also performed extensive analyses that provide additional 

supporting evidence that the plan will effectively bring the Valley into attainment. 

Overall, the modeling and supporting technical analysis demonstrates that the 

emissions reductions achieved through the plan’s control strategy bring the entire Valley 

into attainment of the 1997 federal 24-hour PM2.5 standard by 2018 and annual PM2.5 

standard by 2020.

Request for Extension of Attainment Deadline 

As a Serious nonattainment area, the Valley would have until December 31, 2015 to 

attain the 1997 PM2.5 standard as determined using air monitoring data collected in 

calendar years 2013 through 2015. Under Section 188(e) of the federal CAA, EPA 

may grant a one-time extension of the attainment date of up to five years for a Serious 

nonattainment area beyond the attainment deadline specified in Section 188(c)(2). To 

be granted an extension, an area must show that it cannot attain by December 2015, 

but will attain as expeditiously as possible, and no later than 2020. In this plan, the 

District requests an extension of the attainment deadline for the 24-hour standard to 

2018 and the annual standard to 2020, based on the following findings:

• Attainment by the December 31, 2015 deadline is impracticable 

• All requirements and commitments in the implementation plan have been met

• The 2015 PM2.5 Plan contains Most Stringent Measures (MSM) and Best 

Available Control Measures (BACM) 

• The 2015 PM2.5 Plan includes a demonstration of attainment by the most 

expeditious alternative dates practicable for both the annual and 24-hour 

standards.

Commitment to Achieve Extra Reductions in Emissions

As discussed earlier, the 2015 PM2.5 Plan contains Most Stringent Measures, Best 

Available Control Measures, and ensures expeditious attainment. However, the District 

and the ARB are committed to leaving no stone unturned to ensure attainment as 

rapidly as possible. Towards that end, this plan contains commitments for the following 

additional reductions in emissions:

Replace Heavy Duty Trucks – Using motor vehicle surcharge funds generated by the 

District under AB 2522, the District commits to allocating $10,000,000, for the period of 

2016 through 2020 to replace between 152 to 200 heavy duty trucks in the Valley and 

reduce up to 0.33 tpd NOx. These funds will be expended through the District’s truck 

6
SJVUAPCD Governing Board

ADOPT 2015 PLAN FOR THE 1997 PM2.5 STANDARD, INCLUDING REQUEST TO EXTEND 

ATTAINMENT DEADLINE; APPROVE ASSOCIATED COMMITMENTS TO CONTINUE TO LEAVE NO 

STONE UNTURNED IN ASSESSING FUTURE AMENDMENTS TO DISTRICT RULES THAT MAY 

PROVIDE ADDITIONAL FEASIBLE REDUCTIONS; APPROVE COMMITMENTS TO ACHIEVE 

FURTHER REDUCTIONS IN PARTICULATE EMISSIONS AND ITS PRECURSORS THROUGH 

INCENTIVE-BASED STRATEGIES TO REPLACE HEAVY DUTY TRUCKS AND RESIDENTIAL WOOD 

BURNING DEVICES; APPROVE RESOLUTION 15-4-7B TO AMEND RESOLUTION 10-10-14 TO 

CONTINUE NECESSARY AB 2522 DMV FUNDING FOR INCENTIVE-BASED COMMITMENTS IN THE 

PLAN TO REDUCE MOBILE SOURCE EMISSIONS

April 16, 2015

replacement incentive program and reductions in emissions will be surplus to the State 

Truck and Bus Regulation. 

Despite achieving over 80% reductions in emissions and lowering the number of days 

exceeding the 1-hour ozone standard from 56 days in 1996 to only 7 days, in 2010 the 

Valley faced the imposition of federal nonattainment penalties under Section 185 of the 

federal CAA. Absent action by the District at that time, EPA would have been required 

by federal law to collect $29 million per year of penalties plus interest from Valley 

businesses. Federal laws would have also required that any fees collected under 

Section 185 be deposited in the United States Treasury with no return or benefit to the 

Valley. Instead, in October 2010, the Governing Board pursued a more creative option 

to satisfy the federal CAA in a manner that fairly distributed the responsibility amongst 

stationary and mobile sources and allowed the District to retain funds for investment in 

the Valley rather than surrendering those revenues to the federal government. AB 2522 

(Arambula, 2008) granted the District the authority to impose surcharge fees of up to 

$24 per motor vehicle for the purpose of meeting federal mandates. To fulfill this 

federal mandate, the District acted on this authority and adopted a $12 per motor 

vehicle surcharge with a commitment for reinvestment of all revenues in the San 

Joaquin Valley for voluntary emission reduction projects. The authority under AB 2522 

sunsets in 2024 and the District has submitted a request to federal EPA to lift the 

Section 185 nonattainment penalties. The AB 2522 revenues are being used to 

address the Valley’s unmatched challenges in meeting ever-tightening federal 

standards as well as providing a more equitable manner to satisfy the federal mandates 

for ozone nonattainment penalties under Section 185. Formal action by EPA to lift the 

Section 185 penalties will return local control over the need and magnitude of necessary 

DMV revenues. Today’s recommendation if approved by your Board will support 

commitments for further reductions in emissions required by EPA to grant a one-time 

five year extension of the attainment deadline, and will enable your Board to revoke 

imposition of the DMV surcharge fees under AB 2522 upon a finding by your Board that 

such revenues are no longer necessary to fulfill mandates under the federal CAA.

Replace Residential Wood Burning Devices – Through the use of locally-generated 

funding, the District commits to allocating $7,500,000, for the period of 2016 through 

2020 to replace between 4,000 to 7,500 older higher polluting residential wood burning 

devices in the Valley with cleaner alternatives. These funds will be expended through 

the District’s Burn Cleaner Incentive Program and are expected to reduce up to 0.4 tpd 

direct PM2.5 emissions, surplus to District Rule 4901. 

7
SJVUAPCD Governing Board

ADOPT 2015 PLAN FOR THE 1997 PM2.5 STANDARD, INCLUDING REQUEST TO EXTEND 

ATTAINMENT DEADLINE; APPROVE ASSOCIATED COMMITMENTS TO CONTINUE TO LEAVE NO 

STONE UNTURNED IN ASSESSING FUTURE AMENDMENTS TO DISTRICT RULES THAT MAY 

PROVIDE ADDITIONAL FEASIBLE REDUCTIONS; APPROVE COMMITMENTS TO ACHIEVE 

FURTHER REDUCTIONS IN PARTICULATE EMISSIONS AND ITS PRECURSORS THROUGH 

INCENTIVE-BASED STRATEGIES TO REPLACE HEAVY DUTY TRUCKS AND RESIDENTIAL WOOD 

BURNING DEVICES; APPROVE RESOLUTION 15-4-7B TO AMEND RESOLUTION 10-10-14 TO 

CONTINUE NECESSARY AB 2522 DMV FUNDING FOR INCENTIVE-BASED COMMITMENTS IN THE 

PLAN TO REDUCE MOBILE SOURCE EMISSIONS

April 16, 2015

ARB Commitments for Additional Reductions – In addition to the above 

commitments by the District for additional reductions in emissions, ARB has also 

committed to do their part by committing to provide additional reductions in emissions 

for sources under their control. ARB staff will propose a commitment on actions for key 

truck sectors in the Valley to better ensure benefits from the Truck and Bus regulation, 

and pursue opportunities for the replacement of trucks certified to the State’s optional 

low NOx standard.

Commitment to Evaluate Additional Opportunities Beyond the 2015 PM2.5 Plan

Despite the fact that this plan contains all the necessary elements for approval including 

BACM and MSM, the District is fully aware that meeting the tougher newer air quality 

standards require additional efforts and further reductions in emissions. Over the next 

year, the District must adopt SIPs to address the 2006 PM2.5 Standard (annual: 15 

μg/m3

, 24-hr: 35 μg/m3) and the 2012 PM2.5 Standard (annual: 12 μg/m3, 24-hr: 35 

μg/m3). Additionally, the District must also develop a SIP for the 2008 8-hour ozone 

Standard (75 ppb) by July 2016. 

As always, the District will leave no stone unturned to evaluate and identify further 

opportunities to advance attainment of the ever-tightening NAAQS. Of course, the 

opportunities identified to reduce emissions towards meeting these tougher standards 

may also help expedite attainment with the 1997 PM2.5 standard addressed by this 

plan. In developing these plans, the District will reevaluate all of its existing regulations 

and will explore all potential measures for all source categories. However, in the short 

term, the District commits to conduct the following evaluations and to include any 

identified feasible additional actions for reducing emissions with implementation 

schedules in the District’s SIP submission for the 2012 PM2.5 NAAQS in the fall of

2016.

Flares (Rule 4311) – As demonstrated in Appendix C of the 2015 PM2.5 Plan, District 

Rule 4311 already meets BACM and MSM requirements. However, due to the need to 

demonstrate attainment for multiple federal ozone and PM2.5 standards in the coming 

years and need to search for all available emissions reductions, the District commits to 

undertaking a comprehensive review of Flare Minimization Plans (FMPs) submitted 

under Rule 4311. The District commits to conduct the evaluation and have a draft 

report available for public review and commenting by December 1, 2015. After 

addressing public comments, the District commits to finalize this report by March 31, 

2016. This evaluation will be conducted in close coordination with flare operators in the 

Valley and will include the following elements:

8
SJVUAPCD Governing Board

ADOPT 2015 PLAN FOR THE 1997 PM2.5 STANDARD, INCLUDING REQUEST TO EXTEND 

ATTAINMENT DEADLINE; APPROVE ASSOCIATED COMMITMENTS TO CONTINUE TO LEAVE NO 

STONE UNTURNED IN ASSESSING FUTURE AMENDMENTS TO DISTRICT RULES THAT MAY 

PROVIDE ADDITIONAL FEASIBLE REDUCTIONS; APPROVE COMMITMENTS TO ACHIEVE 

FURTHER REDUCTIONS IN PARTICULATE EMISSIONS AND ITS PRECURSORS THROUGH 

INCENTIVE-BASED STRATEGIES TO REPLACE HEAVY DUTY TRUCKS AND RESIDENTIAL WOOD 

BURNING DEVICES; APPROVE RESOLUTION 15-4-7B TO AMEND RESOLUTION 10-10-14 TO 

CONTINUE NECESSARY AB 2522 DMV FUNDING FOR INCENTIVE-BASED COMMITMENTS IN THE 

PLAN TO REDUCE MOBILE SOURCE EMISSIONS

April 16, 2015

1. The District will review submitted FMPs to identify the most effective flare 

minimization practices utilized by operators to reduce flaring in various source 

categories and applications. Upon completion of review, the District commits to 

working closely with affected operators to evaluate and implement, when 

feasible, the most effective flare minimization practices through the FMP 

submittal and approval process under Rule 4311. 

2. The District will evaluate the technological achievability and economic feasibility 

of implementing new/additional minimization practices or technologies at affected 

facilities.

Warm Mix Asphalt (WMA) – Emissions from asphalt usage are extremely small and do 

not significantly contribute to elevated PM2.5 levels in the Valley. However, due to the 

need to demonstrate attainment for multiple federal ozone and PM2.5 standards in the 

coming years and need to search for all available emissions reductions, the District 

commits to a number of actions to evaluate and promote the use of WMA in the Valley. 

The District commits to conduct the evaluation and have a draft report available for 

public review and commenting by December 1, 2015. After addressing public 

comments, the District commits to finalize this report by March 31, 2016. This 

evaluation will be conducted in close coordination with stakeholders (asphalt plant 

operators, Caltrans, city and county planning departments, ARB, EPA, and others) and 

will include the following elements:

1. The District will evaluate opportunities to further encourage transportation and 

county agencies to continue transitioning from HMA to WMA as feasible. As part 

of this evaluation, the District will explore the potential feasibility of additional 

control measures and granting mitigation credits for WMA usage through the 

District’s Indirect Source Review (ISR) program.

2. The District will evaluate potential outreach and education opportunities for 

encouraging project developers/construction managers to increase their adoption 

and implementation of WMA.

Conservation Management Practices (Rule 4550) – As documented in Appendix C of 

the 2015 PM2.5 Plan, District Rule 4550 already meets BACM and MSM requirements. 

It is also questionable that further opportunities for reducing PM2.5 emissions exist. 

However, as stated earlier, in developing plans for the new and existing National 

Ambient Air Quality Standards, the District will reevaluate all existing regulations 

including Rule 4550 to evaluate all feasible opportunities for additional emissions 

9
SJVUAPCD Governing Board

ADOPT 2015 PLAN FOR THE 1997 PM2.5 STANDARD, INCLUDING REQUEST TO EXTEND 

ATTAINMENT DEADLINE; APPROVE ASSOCIATED COMMITMENTS TO CONTINUE TO LEAVE NO 

STONE UNTURNED IN ASSESSING FUTURE AMENDMENTS TO DISTRICT RULES THAT MAY 

PROVIDE ADDITIONAL FEASIBLE REDUCTIONS; APPROVE COMMITMENTS TO ACHIEVE 

FURTHER REDUCTIONS IN PARTICULATE EMISSIONS AND ITS PRECURSORS THROUGH 

INCENTIVE-BASED STRATEGIES TO REPLACE HEAVY DUTY TRUCKS AND RESIDENTIAL WOOD 

BURNING DEVICES; APPROVE RESOLUTION 15-4-7B TO AMEND RESOLUTION 10-10-14 TO 

CONTINUE NECESSARY AB 2522 DMV FUNDING FOR INCENTIVE-BASED COMMITMENTS IN THE 

PLAN TO REDUCE MOBILE SOURCE EMISSIONS

April 16, 2015

reductions, if any. The District commits to conduct the evaluation and have a draft 

report available for public review and commenting by May 31, 2016. After addressing 

public comments, the District commits to finalize this report by October 15, 2016. This 

evaluation will be conducted in close coordination with stakeholders (agricultural 

industry representatives, ARB, EPA, NRCS, farm bureaus, and others). 

Public Review Process for the Proposed 2015 Plan for the 1997 PM2.5 Standard 

The 2015 PM2.5 Plan was prepared through an involved public process that provided 

multiple opportunities for the general public and interested stakeholders to offer 

suggestions and comments for improving and strengthening the plan. The District has 

worked closely with these various stakeholders, including its partner agencies ARB and 

EPA, environmental and community advocacy groups, and business representatives to 

share information regarding the plan and to receive comments and suggestions. 

Numerous opportunities were provided for public input in 2014 during District Governing 

Board public hearings, Citizen’s Advisory Committee public meetings and 

Environmental Justice Advisory Group public meetings. The District also met with 

interested advocacy and industry representatives throughout the plan development 

process to address specific questions and comments, and solicit further suggestions for 

control strategies. The District held a public workshop for this plan on March 4, 2015 

that outlined the air quality challenges faced by the Valley and potential strategies for 

responding to the challenges. The workshop was held at the District’s offices in 

Modesto, Fresno, and Bakersfield and by webcast, with many participants attending and 

providing feedback during the workshop. 

All of these meetings have provided opportunities for the public to provide verbal 

comments, and written comments have also been accepted throughout development of 

this plan. These comments have been integral to the development of this plan, and 

have been incorporated as appropriate. All significant comments and responses are 

summarized in Appendix H of this plan. 

Some of the key issues raised during development of the 2015 PM2.5 Plan are

summarized below:

10
SJVUAPCD Governing Board

ADOPT 2015 PLAN FOR THE 1997 PM2.5 STANDARD, INCLUDING REQUEST TO EXTEND 

ATTAINMENT DEADLINE; APPROVE ASSOCIATED COMMITMENTS TO CONTINUE TO LEAVE NO 

STONE UNTURNED IN ASSESSING FUTURE AMENDMENTS TO DISTRICT RULES THAT MAY 

PROVIDE ADDITIONAL FEASIBLE REDUCTIONS; APPROVE COMMITMENTS TO ACHIEVE 

FURTHER REDUCTIONS IN PARTICULATE EMISSIONS AND ITS PRECURSORS THROUGH 

INCENTIVE-BASED STRATEGIES TO REPLACE HEAVY DUTY TRUCKS AND RESIDENTIAL WOOD 

BURNING DEVICES; APPROVE RESOLUTION 15-4-7B TO AMEND RESOLUTION 10-10-14 TO 

CONTINUE NECESSARY AB 2522 DMV FUNDING FOR INCENTIVE-BASED COMMITMENTS IN THE 

PLAN TO REDUCE MOBILE SOURCE EMISSIONS

April 16, 2015

The potential for ammonia emissions reductions to assist with attainment

Comment: Commenters raised questions in regards to the District’s strategy in 

prioritizing NOx emission reductions and not focusing on ammonia emissions as playing 

a potential role in assisting the Valley with attaining the federal PM2.5 standard. 

(CVAQ)

Response: These commenters mistakenly believe that ammonia reductions could 

assist the Valley in attaining the standard earlier than proposed in the plan. The 

proposed plan control strategy achieves the emissions reductions necessary to bring 

the Valley into attainment, primarily through PM2.5 and NOx emissions reductions. 

Most areas of the Valley will reach attainment well before the proposed deadlines in the 

2015 PM2.5 Plan. The District’s incentive programs, public outreach, and other

innovative strategies will help expedite air quality improvements as this plan is

implemented. Although the plan shows expeditious attainment and includes a 

comprehensive control strategy for direct PM2.5 emissions and significant PM2.5 

precursors, the District and ARB explored the effectiveness of ammonia reductions in 

reducing PM2.5 concentrations. 

The review of extensive science on this subject and modeling conducted conclude that 

reducing ammonia emissions is orders of magnitude less effective in reducing PM2.5 

concentrations than reducing directly emitted PM2.5 or NOx emissions. There is a 

relative abundance of ammonia compared to nitric acid, and the amount of nitric acid 

drives the ultimate formation of ammonium nitrate. Because of this regional surplus in 

ammonia, even substantial ammonia emissions reductions yield a relatively small 

reduction in nitrate. Reductions in nitrate concentrations of 30% to 50% were realized 

through a 50% reduction in NOx. Modeling a 50% reduction in ammonia, while 

unrealistic and not technologically achievable, would only realize less than 5% 

reductions in nitrate concentrations. 

Despite the fact that ammonia is an insignificant PM2.5 precursor in the Valley, the 

District evaluated current ammonia controls in Appendix C (BACM and MSM for 

Stationary and Area Sources) of this plan. The analyses show that the Valley’s 

ammonia emissions have been significantly reduced through stringent District 

regulations and current regulations implement BACM and MSM in the Valley. For 

example, the District has already reduced ammonia emissions from confined animal 

facilities, the largest source of ammonia emissions under its jurisdiction, by over 100 

tons per day through adoption of Rule 4570 (Confined Animal Facilities), the most 

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SJVUAPCD Governing Board

ADOPT 2015 PLAN FOR THE 1997 PM2.5 STANDARD, INCLUDING REQUEST TO EXTEND 

ATTAINMENT DEADLINE; APPROVE ASSOCIATED COMMITMENTS TO CONTINUE TO LEAVE NO 

STONE UNTURNED IN ASSESSING FUTURE AMENDMENTS TO DISTRICT RULES THAT MAY 

PROVIDE ADDITIONAL FEASIBLE REDUCTIONS; APPROVE COMMITMENTS TO ACHIEVE 

FURTHER REDUCTIONS IN PARTICULATE EMISSIONS AND ITS PRECURSORS THROUGH 

INCENTIVE-BASED STRATEGIES TO REPLACE HEAVY DUTY TRUCKS AND RESIDENTIAL WOOD 

BURNING DEVICES; APPROVE RESOLUTION 15-4-7B TO AMEND RESOLUTION 10-10-14 TO 

CONTINUE NECESSARY AB 2522 DMV FUNDING FOR INCENTIVE-BASED COMMITMENTS IN THE 

PLAN TO REDUCE MOBILE SOURCE EMISSIONS

April 16, 2015

stringent rule of its kind in the nation. The District did not find any additional feasible 

measures that could significantly reduce ammonia emissions.

SIP-creditability of incentive Programs and District Rule 9610

Comment: Emission reductions that the District intends to use from incentive programs 

under Rule 9610 are not SIP-creditable. (CVAQ)

Response: Incentive programs are an integral part of the emission reduction efforts of 

the District. These programs have invested over $1 billion in public/private funding 

towards incentive-based emission reduction projects that have reduced over 100,000 

tons of NOx, VOC, and PM2.5 emissions since 1992. District incentive programs have 

been modeled on effective state incentive programs like the Carl Moyer Program. 

Enforceability has already been built into the District incentive programs through 

requirements that include pre and post project equipment inspections, monitoring, and 

reporting. Rule 9610 provides the mechanism for the District to take credit for these 

surplus, quantifiable, and enforceable emissions reductions. EPA approved Rule 9610

on February 26, 2015, finding that incentive-based emissions reductions are fully SIPcreditable.

FISCAL IMPACT:

This 2015 Plan for the 1997 PM2.5 Standard describes a major air quality strategy that 

will be implemented in the future over a period of several years. While the workload 

implications will likely be significant and affect several District departments, the extent of 

the fiscal impact on future budgets is uncertain. As the fiscal impacts of the 2015 Plan 

for the 1997 PM2.5 Standard become more defined, staff will request the needed 

resources from your Board either through annual budget requests or mid-year budget 

adjustments. Therefore, no modification of the District’s budget is necessary at this 

time. 

Attachments:

Attachment A: Resolution 15-4-7A: Adopting the San Joaquin Valley Unified Air Pollution 

Control District 2015 Plan for the 1997 PM2.5 Standard (8 pages)

Attachment B: Resolution 15-4-7B: Use of AB 2522 DMV fees to meet federal CAA mandates (5

pages)

Attachment C: Proposed 2015 Plan for the 1997 PM2.5 Standard (722 pages)

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