TITLE 

2011 PM2.5 Mid-Course Review 

DRAFT – March 2011 

2008 PM2.5 Plan 

Progress Report
San Joaquin Valley Unified Air Pollution Control District 

1990 E. Gettysburg Avenue 

Fresno, California 93726 

(559) 230-6100 

www.valleyair.org
Executive Summary iii 

2008 PM2.5 Plan Progress Report 

Executive Summary 

The San Joaquin Valley Air Pollution Control District (District) Governing Board adopted 

the 2008 PM2.5 Plan on April 30, 2008. This aggressive plan built upon the District’s 

public process, the comprehensive strategy adopted in the District’s 2007 Ozone Plan, 

and extensive science to bring the Valley into attainment of the 1997 National Ambient 

Air Quality Standards (NAAQS) for PM2.5 (particulate matter that is 2.5 microns or less 

in diameter). This Progress Report documents the District’s and stakeholders’ efforts to 

implement the PM2.5 plan strategy and evaluates resulting air quality improvements. 

Since the plan was adopted, the District has made significant progress implementing its 

multi-faceted control strategy, which affects a wide range of sources. The District has 

implemented innovative new rules, such as the Employer Based Trip Reduction rule, 

and further strengthened existing rules, such as the Agricultural Open Burning rule. In 

aggregate, the District’s adopted control measures surpass reduction commitments 

from the plan (see Section 2). These reductions come to fruition as a result of the 

significant investments made by Valley businesses to comply with District rules. The 

general public has also played an important role in bringing continued air quality 

improvements to the Valley through compliance with the District’s wood burning rule 

and wood burning prohibitions, and by participating in the District’s Healthy Air Living 

outreach program, which empowers individuals and organizations to make air quality a 

priority in daily decision making. 

The District’s voluntary incentive programs also play a critical role in the 2008 PM2.5 

Plan’s multi-faceted strategy by accelerating and achieving additional emissions 

reductions required for the Valley’s attainment. The District continues to actively pursue 

new funding sources and develop new incentive programs, such as the expedited 

Voucher Incentive Program (VIP), the Technology Advancement Program (TAP), and 

other programs. Since inception, the District has awarded more than $300 million in 

incentives, resulting in more than 75,000 tons of lifetime emissions reductions. 

The District has evaluated resulting PM2.5 concentrations through a variety of 

parameters to better understand areas of air quality improvement as well as issues that 

limited air quality improvements. In the months immediately following PM2.5 plan 

adoption, in the summer and fall of 2008, wildfires impacted much of California, burning 

over a million acres and causing unprecedented levels of PM2.5 and ozone throughout 

the state. The Valley’s annual average PM2.5 concentration was elevated in 2008 as a 

result. However, due to the District’s wood burning curtailments and the public’s 

compliance with these prohibitions, the Valley continues to experience cleaner winters, 

with more “Good” air quality index (AQI) days and fewer “Unhealthy” AQI days in each 

of the last three wood burning seasons. Wood burning prohibitions reduce emissions of 

some of the most health-impacting particles when and where these reductions are most 

needed. As a result, Valley residents are experiencing better air quality due to 

implementation of the 2008 PM2.5 Plan and due to the involvement of the general 

public. 
iv DRAFT SJVAPCD PM2.5 Progress Report 

Challenges still remain to bring the Valley into attainment of the 1997 NAAQS by 2015. 

Past successes like the wood burning rule give us confidence that future efforts will 

continue to be effective. There are more opportunities to improve the Valley’s PM2.5 

levels, as the California Air Resources Board (ARB) implements recent rules and as the 

District and ARB continues laying the groundwork to develop the District’s 2012 PM2.5 

Attainment Plan (for the 2006 PM2.5 NAAQS, as described in Section 4). The progress 

documented in this report is to be continued.
Table of Contents v 

2008 PM2.5 Plan Progress Report 

Table of Contents 

Section 1 - Introduction & Background ........................................................................1-1

1.1 PM2.5 in the San Joaquin Valley.......................................................................1-1

1.2 The 2008 PM2.5 Plan........................................................................................1-1

Section 2 - District Strategy ...........................................................................................2-1

2.1 A Summary of Adopted District Control Measures ............................................2-1

2.2 Feasibility Studies .............................................................................................2-2

2.3 Incentives ..........................................................................................................2-3

2.4 Other Innovative Strategies & Programs ...........................................................2-6

2.4.1 Healthy Air Living..................................................................................2-7

2.4.2 Fast Track Measures ............................................................................2-7

2.4.3 Technology Advancement Program (TAP) ...........................................2-7

Section 3 - Air Quality Analysis.....................................................................................3-1

3.1 PM2.5 Trends....................................................................................................3-1

3.1.1 Winter PM2.5 trends .............................................................................3-1

3.1.2 Daily PM2.5 Trends ..............................................................................3-2

3.1.3 Annual Trends ......................................................................................3-3

3.2 Design values....................................................................................................3-3

3.2.1 Wildfires................................................................................................3-5

3.3 Summary...........................................................................................................3-5

Section 4 - Ongoing Challenges....................................................................................4-1

4.1 Risk-based Strategy to Maximize Public Health Benefits..................................4-1

Appendix A Analysis of Ambient Air Quality 

Appendix B District and ARB Comment Letters on Proposed EPA Plan 

Disapproval 

Appendix C District Control Measures 
vi DRAFT SJVAPCD PM2.5 Progress Report 

2008 PM2.5 Plan Progress Report 

List of Tables 

Table 2-1 Regulatory Control Measure Commitments from the 2008 PM2.5 Plan......2-2

Table 2-2 Reductions Achieved by Adopted 2008 PM2.5 Plan Rules.........................2-2

Table 2-3 2008 PM2.5 Plan Feasibility Studies, Revised Schedule ............................2-3

Table 2-4 Incentive Program Totals, 1998 - 2010 .......................................................2-5

Table 2-5 Total Annual Incentive Funding 1998 - 2010...............................................2-6

Table 4-1 Summary of PM2.5 NAAQS........................................................................4-1

List of Figures 

Figure 3-1 Valley Air Quality Improvements during Wood Burning Season ................3-2

Figure 3-2 Average Annual PM2.5 Diurnal Profiles by Year at Fresno-First Monitoring 

Site........................................................................................................................3-3

Figure 3-3 PM2.5 24-hour Design Value Comparison, 2002 (2000-2002 Average) and 

2010 (2008-2010 Average) ...................................................................................3-4

Figure 3-4 Annual PM2.5 Design Value Comparison, 2002 (2000-2002 Average) and 

2010 (2008-2010 Average) ...................................................................................3-4
Introduction & Background 1-1

Section 1 - Introduction & Background 

The San Joaquin Valley Air Pollution Control District (District) prepared this 2008 PM2.5 

Plan Progress Report (Progress Report) to demonstrate to EPA and to the public that 

the District has met its 2008 PM2.5 Plan commitments and that the San Joaquin 

Valley’s (Valley) air quality for PM2.5 (particulate matter that is 2.5 microns or less in 

diameter) is improving under plan implementation. This Progress Report demonstrates 

that the District’s efforts, along with the Valley’s business and resident efforts, have 

reduced direct PM2.5 and PM2.5 precursor emissions. These reductions correspond to 

a continued downward trend of ambient PM2.5 concentrations. 

This report is to be forwarded to the California Air Resources Board (ARB) for submittal 

to the United States Environmental Protection Agency (EPA). In addition, in April 2011, 

ARB will update the state strategy, also to be submitted to EPA. 

1.1 PM2.5 in the San Joaquin Valley 

Under current regulations, particulate matter (PM) is differentiated by particle size. 

PM2.5 can be inhaled deep into the lungs, where it can be absorbed into the 

bloodstream or remain embedded for long periods of time without being exhaled. 

Numerous studies link PM2.5 to a variety of health effects, including (but not limited to) 

aggravated asthma, coughing, decreased lung function in children, chronic bronchitis, 

and premature death. The chemical species of PM2.5 can be a factor in the type and 

severity of health impacts. However, the U.S. Environmental Protection Agency’s (EPA) 

health-based standards are currently mass-based standards. The National Ambient Air 

Quality Standards (NAAQS) for PM2.5, as set in 1997, are 65 μg/m3 for 24-hour 

average concentrations and 15 μg/m3 for annual average concentrations. EPA 

designated the Valley as nonattainment of the 1997 PM2.5 NAAQS in 2005. 

PM2.5 can be emitted directly, or secondary PM2.5 can form in the atmosphere through 

the reactions of precursors, such as oxides of nitrogen (NOx), sulfur dioxide (SO2), and, 

in some areas, volatile organic compounds (VOCs) and ammonia. The San Joaquin 

Valley’s topography and meteorological conditions create an environment that naturally 

exacerbates the formation and retention of PM2.5. The Valley’s population growth and 

the District’s jurisdictional limits also add to the Valley’s PM2.5 challenges. 

1.2 The 2008 PM2.5 Plan

The District Governing Board adopted the 2008 PM2.5 Plan on April 30, 2008. This 

aggressive plan built on the far-reaching strategy developed for the District’s 2007 

Ozone Plan and is a continuation of the District’s comprehensive strategy to improve 

the air quality in the San Joaquin Valley. The 2008 PM2.5 Plan addressed directlyemitted PM2.5 as well as precursors found to significantly contribute to PM2.5 

concentrations in the Valley. Due to the Valley’s wintertime ambient conditions and 

atmospheric chemistry, and because of the magnitude of the Valley’s NOx inventory, 

NOx reductions are especially critical to the Valley’s PM2.5 attainment. 
1-2 DRAFT SJVAPCD PM2.5 Progress Report 

The California Regional Particulate Air Quality Study (CRPAQS) provided the scientific 

foundation for 2008 PM2.5 Plan modeling and analysis. This $30 million study program 

has been an inter-agency effort with involvement from the California Air Resources 

Board (ARB), EPA, the District, other air districts, research institutions, and independent 

researchers, and it has generated dozens of presentations, reports, and peer-reviewed 

papers. CRPAQS confirmed that NOx and SO2 are significant PM2.5 precursors in the 

Valley, while reductions in VOC and ammonia are not effective for significantly reducing 

the Valley’s PM2.5 concentrations. CRPAQS results incorporated into the 2008 PM2.5 

Plan’s thorough weight-of-evidence analysis confirmed the effectiveness of the District’s 

and ARB’s control strategy, which emphasizes NOx reductions while also achieving 

reductions of SO2 and directly emitted PM2.5. 

NOx reductions in the Valley contribute to both PM2.5 and ozone air quality 

improvements. However, more than 80% of the Valley’s NOx emissions are generated 

by mobile sources, which are beyond the District’s direct jurisdiction. The District’s NOx 

strategy has thus been a multi-faceted approach coupling both regulatory and nonregulatory strategies. This approach maximizes emissions reductions to expedite 

attainment of health-based air quality standards for both PM2.5 and ozone. 

With its extensive science and far-reaching control strategy, the 2008 PM2.5 Plan

ensures continuous progress towards the EPA’s health-based air quality standards and 

expeditious attainment of the 1997 PM2.5 NAAQS by April 5, 2015, based on 2012, 

2013, and 2014 data. 

On November 30, 2010 (75 Federal Register 74518-74543), EPA proposed a limited 

approval and limited disapproval of the 2008 PM2.5 Plan. The District and ARB 

submitted extensive documentation and comments to EPA regarding the disapproval 

issues raised. The District believes that the collective comments from the District and 

the State of California (available in Appendix B) fully address the issues EPA identified 

in its proposed disapproval. 

.
District Strategy 2-1

Section 2 - District Strategy 

The District has committed to one of the nation’s the most aggressive rule development 

schedules to meet its 2007 Ozone Plan and 2008 PM2.5 Plan attainment goals. The 

District’s four-faceted control strategy, as discussed in the 2007 Ozone Plan and 2008 

PM2.5 Plan, includes: 

• Regulatory control measures 

• Incentive-based strategies 

• Innovative Strategies and Programs 

• Local, State, and Federal Sources/Partnerships 

This section discusses the District’s progress in implementing control measure 

commitments of the 2008 PM2.5 Plan and shows that in aggregate, District control 

measures achieve more emissions reductions than were anticipated at the time of the 

2008 PM2.5 Plan. This section also discusses the incentive-based strategies and other 

innovative programs that supplement the District’s traditional regulatory efforts and 

generate more emissions reductions than could otherwise be reasonably obtained. 

2.1 A Summary of Adopted District Control Measures 

The 2008 PM2.5 Plan adopted by the District Governing Board was a robust and 

comprehensive attainment plan that included a combination of technologically feasible 

and technology forcing measures. Of the thirteen District regulatory control measure 

commitments in the plan, the District has adopted eleven to date (Table 2-1). 

The 2008 PM2.5 Plan identifies control measures, expected emissions reductions, and 

a schedule for the implementation of such measures. During control measure 

development, District staff works closely with stakeholders, ARB, EPA, and other 

interested parties to discuss concerns, examine possible impacts, and uncover 

mitigation strategies that will protect both the health and economic strength of the 

Valley. During this process, the scope and structure of control measures can evolve 

from their original plan commitments. Table 2-2 summarizes District rules adopted or 

amended consistent with the 2008 PM2.5 Plan along with corresponding emission 

reductions. Table 2-2 shows that the District’s adopted control measures achieve more 

PM2.5 equivalent reductions than committed to in the 2008 PM2.5 Plan. More details 

on each control measure are available in Appendix C of this Progress Report. 
2-2 DRAFT SJVAPCD PM2.5 Progress Report 

Table 2-1 Regulatory Control Measure Commitments from the 2008 PM2.5 Plan

Control 

Measure # Control Measure Rule # Completion

Completed Rules

S-COM-5 Stationary Gas Turbines 4703 2007 

S-COM-1 Large Boilers 4306/4320 2008 

S-COM-2 Medium Boilers 4307 2008 

S-COM-7 Glass Melting Furnaces 4354 2008 

S-COM-9 Residential Water Heaters 4902 2009 

S-IND-9 Commercial Charbroiling 4692 2009 

S-COM-11 Wood Burning Fireplaces and Heaters 4901 2009 

S-COM-3 Small Boilers 4308 2009 

M-TRAN-1 Employer-Based Trip Reduction 9410 2009 

S-AGR-1 Open Burning 4103 2010 

Remaining Rule Commitments

S-COM-6 Reciprocating Internal Combustion 

Engines 4702 2011 

S-COM-10 Natural, gas-Fired, Fan-Type Residential 

Central Furnaces 4905 2014 

Table 2-2 Reductions Achieved by Adopted 2008 PM2.5 Plan Rules 

2008 PM2.5 Plan Projections (tons per 

day) Actual Reductions (tons per day) 

Control Measure Rule #

PM2.5 NOx1

 SOx2 PM2.5 

Equivalent1, 2 PM2.5 NOx1 SOx2 PM2.5 Equivalent1, 2

Stationary Gas Turbines 4703 0 2.21 0 0.25 0 2.20 0 0.24 

Large Boilers 4306/ 

4320 0.24 1.52 0.76 1.17 0.24 1.60 1.92 2.34 

Medium Boilers 4307 0 0 0 0.00 0 1.29 0 0.14 

Glass Melting Furnaces 4354 0 1.58 0 0.18 0 3.64 1.62 2.02 

Residential Water 

Heaters 4902 0 0.40 0 0.04 0 0.50 0 0.06 

Commercial Charbroiling 4692 2.28 0 0 2.28 0.87 0 0 0.87 

Wood Burning Fireplaces 

and Heaters 4901 0.69 0.06 0.02 0.72 1.08 0.12 0.02 1.11 

Small Boilers 4308 0 0.55 0 0.06 0 1.45 0 0.16 

Employer-Based Trip 

Reduction 9410 0 0 0 0.00 0.03 0.33 0 0.07 

Open Burning 4103 3.49 2.65 0.14 3.92 2.91 1.87 0.05 3.17 

Totals as PM2.5 equivalent --- 8.62 --- 10.18 

PM2.5 equivalent reductions 

achieved beyond Plan commitment 1.57 tons per day 1

 9.0 tons of NOx per ton of PM2.5. Based on the worst-case annual average interpollutant ratio provided by ARB. The ratios 

used for permitting acts can be lower during PM2.5 season when NOx predominantly acts as a PM2.5 precursor. 2

 1.0 ton of SOx per ton of PM2.5 

2.2 Feasibility Studies 

The 2008 PM2.5 Plan included commitments to conduct several Feasibility Studies in 

cases where there was insufficient information available to determine the feasibility or 

effectiveness the potential control measures at the time of plan adoption. The goal of a 

Feasibility Study is to determine whether an emissions source is significant enough to 
District Strategy 2-3

warrant a control measure and whether there are technically and economically sound 

control technologies or practices available. The Feasibility Study will help determine 

whether a regulation, incentive program, or new advocacy program would reduce 

pollutant emissions and contribute towards attainment. 

The District has completed many of the Feasibility Studies committed to in the 2008 

PM2.5 Plan. The District is continuing work on a few of the studies to allow for more 

information gathering and analysis. Studies that point toward possible emission 

reduction opportunities will be included in future attainment plans with specific 

development schedules and emission reduction commitments. Prior to implementation 

of any of the preliminary recommendations, the District will undertake a public process, 

solicit stakeholder input, and take the implementation recommendations to the District’s 

Governing Board in a public meeting for consideration and approval. Table 2-3 

summarizes completed Feasibility Studies as well as continuing studies for which the 

District is establishing a revised completion date. Summaries of each Feasibility Study 

effort follow. 

Table 2-3 2008 PM2.5 Plan Feasibility Studies, Revised Schedule 

Control 

Measure 

Number 

Control Measure Name 

Completed Feasibility Studies 

S-COM-6A Small Spark-Ignited Engines & Agricultural Spark Ignited Engines 

S-GOV-6 Prescribed Burning 

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

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

S-COM-8 Lime Kilns 

Continuing Feasibility Studies Projected 

Completion Date 

S-IND-4 Fugitive PM10 Prohibitions (Regulation VIII) 2011 

S-AGR-2 Conservation Management Practices 2011 

S-COM-11 Dryers 2011 

S-IND-8 Cotton Gins 2012 

M-OTH-10 Fireworks 2012 

2.3 Incentives 

The District’s highly successful incentive program expedites emissions reductions and 

helps the District achieve emissions reductions from sources that may be beyond the 

District’s regulatory control. Since adoption of the 2008 PM2.5 Plan, the District has 

expanded its incentive opportunities even further. New incentive programs include: the 

California Proposition 1B Goods Movement Emission Reduction Program (Prop 1B); the 

Lower-Emission School Bus Program; the Diesel Emissions Reduction Act (DERA) 

National Clean Diesel School Bus Replacement Program; the Technology 

Advancement Program (TAP); and the Charbroiler Incentive Program. In 2008 through 

2010, the District secured more than $117 million to support the implementation of 

these programs. 
2-4 DRAFT SJVAPCD PM2.5 Progress Report 

Table 2-4 identifies the District-administered incentive programs, including the total 

funding amount for each program, the number of projects and vehicles or engines that 

were funded for each program, and the applicable NOx, PM, and VOC emissions 

reductions attributable to each program. Table 2-5 itemizes the total funding received 

each year from 1998 through 2010 and the associated surplus emissions reductions 

each year. 

In addition to applying for various funding sources, the District is working with ARB to 

make the Carl Moyer and the Prop 1B Programs more flexible and streamlined to attract 

a greater pool of potential projects to fund. Over the last few years, ARB has adopted 

new rules and regulations that claim emission reductions from sources that participate 

in the District’s incentive programs. As these sources approach compliance deadlines, 

the opportunities for awarding incentive funds for these projects are reduced. The 

District and ARB are committed to working within the framework of these regulations to 

identify opportunities for continued funding. In addition, the District is working with ARB 

staff to identify new sources and project types for funding consideration. 

The District relies on a combination of funding sources to support its comprehensive 

incentive program. The annual amount of funding available to the District is currently 

more than $112 million for the 2010-2011 fiscal year. The primary sources of these 

funds includes expected revenue from the District’s Indirect Source Review Rule, 

voluntary development mitigation agreements, local DMV surcharge fees, the state’s 

Carl Moyer Program, Prop 1B, and various federal funding sources. 

In light of past successes and the ongoing need for additional emissions reductions, the 

District continues to develop new avenues for incentive funding opportunities. 
District Strategy 2-5

Table 2-4 Incentive Program Totals, 1998 - 2010 

Program # of 

Projects

# of 

Vehicles/ 

Engines

NOx 

(tons)

VOC 

(tons)

PM 

(tons) 

District 

Grant 

Amount 

Agricultural Engine 2,563 5,954 46,436 2,130 1,719 $100,349,917

Agricultural Utility Terrain Vehicle 20 20 NC NC NC $46,681

Alternative Fuel/Hybrid Vehicle Rebate 3 3 NC NC NC $23,665

Bicycle Infrastructure 14 16 11 17 5 $761,433

Car Crushing 203 593 24 37 0 $2,384,022

Commuter Subsidy 186 198 34 41 112 $1,619,630

E-Mobility 9 9 5 5 1 $606,412

Electric Forklift 7 35 30 2 1 $323,213

Infrastructure 15 15 NC NC NC $2,931,913

Lawn Mower 1,338 1,338 NC NC NC $334,500

Light and Medium Duty 38 206 58 102 NC $421,275

Locomotive 5 29 1,151 64 24 $13,093,912

Off-Road Heavy Duty 651 1,239 8,232 407 263 $43,013,552

Off-Road Forklift 1 5 13 NC NC $32,625

On-Road Heavy Duty 247 1,430 5,213 6 473 $33,147,000

On-Road Heavy Duty Prop1B 356 926 8,071 NC 376 $44,765,902

On-Road Heavy Duty VIP 46 46 NC NC NC $1,655,000

School Bus Program 237 1,487 26 NC NC $53,563,503

Truck Electrification 1 202 2,634 NC 6 $1,795,000

Wood Stove Change Out 1,164 1,168 NC NC 276 $735,350

Totals 7,104 14,919 71,939 2,810 3,258 $301,604,505

*NC – not calculated 
2-6 DRAFT SJVAPCD PM2.5 Progress Report 

Table 2-5 Total Annual Incentive Funding 1998 - 2010 

Year # of 

Projects 

# of 

Vehicles/ 

Engines 

NOx 

(tons) 

VOC 

(tons) 

PM 

(tons)

Total District 

Grant 

Amount 

1998 25 126 722 NC NC $3,552,537 

1999 95 373 3,198 NC NC $4,606,091 

2000 159 377 3,427 NC NC $4,869,698 

2001 447 1,099 7,148 NC 682 $13,926,978 

2002 398 827 4,656 NC 321 $12,813,174 

2003 309 675 5,769 NC 322 $10,018,459 

2004 284 913 8,189 NC 282 $11,718,105 

2005 286 601 5,171 57 189 $13,096,278 

2006 467 1,400 6,643 559 230 $43,377,859 

2007 340 1,552 5,914 617 179 $35,154,933 

2008 460 1,143 5,035 770 203 $30,536,239 

2009 708 1,188 6,245 471 169 $31,824,151 

2010 3,126 4,645 9,824 334 683 $86,110,003 

Totals 7,104 14,919 71,939 2,810 3,259 $301,604,505 

*NC – Not calculated 

2.4 Other Innovative Strategies & Programs 

Past attainment plans primarily relied on regulatory controls, but new regulatory controls 

have become increasingly unavailable or cost-prohibitive. The District’s need for further 

reductions must be balanced with the economic sustainability of the Valley. Reaching 

beyond traditional regulations and incentive programs, the District has been developing 

innovative strategies and programs to expedite the Valley’s air quality improvements 

and achieve potential “black box” reductions for 8-hour ozone attainment. These 

innovative strategies are designed to enlist the public, local governments, businesses, 

and industry as willing contributors to a successful clean air strategy. In many 

instances, such as reducing energy use and reducing vehicle miles traveled, Valley 

businesses and residents can also reduce their costs – a “win-win” for the District and 

the Valley. 

Most of the innovative strategies are not yet creditable in the State Implementation Plan 

(SIP) because they rely on voluntary participation. The implementation of such 

innovative strategies has led to increased public awareness of air quality issues, 

increased public participation towards air pollution solutions, and improvement in Valley 

air quality. This broad spectrum of involvement will be critical in helping the District 

reach attainment of current and future air quality standards, including attainment of the 

current 8-hour ozone standard by 2024. 
District Strategy 2-7

2.4.1 Healthy Air Living 

Healthy Air Living is a comprehensive, year-round 

outreach initiative that provides tools to help individuals 

and businesses make air quality a priority in their day-today choices. Healthy Air Living aims to reduce emissions 

through a variety of individual and organizational levels: 

reducing the number of vehicle miles traveled each day 

through the Valley; reducing emissions during peak smog episodes; reducing emissions 

created by equipment and processes; and encouraging higher energy efficiency and the 

development of cleaner energy sources. Healthy Air Living has produced several highprofile, high-participation campaigns, including the Kids for Clean Air pledge card 

contest and an annual hybrid vehicle giveaway. 

2.4.2 Fast Track Measures 

The District’s 2007 Fast Track Action Plan identified several Fast Track Measures to 

accelerate the Valley’s attainment. These Fast Track Measures include: 

• Advanced Emission Reduction Options (AERO) 

• Alternative Energy 

• Energy Conservation 

• Episodic & Regionally-Focused Controls 

• Green Contracting 

• Green Fleets 

• Heat Island Mitigation 

• High Speed Rail 

• Inland Ports and Short Sea Shipping 

• Truck Replacement and Retrofit 

See Appendix C for summaries of Fast Track Measure development and 

implementation. 

2.4.3 Technology Advancement Program (TAP) 

On March 18, 2010, the District’s Governing Board approved the Technology 

Advancement Program to identify, solicit, and support opportunities to advance and 

accelerate the deployment of innovative clean air technologies. The District has 

implemented TAP through a coordinated and collaborative process to engage 

technology developers and potential end-users. 

The District initially allocated $900,000 for the first competitive TAP request for 

proposals (RFP), then allocated an additional $300,000 to make $1.2 million available. 

From the proposals submitted, the District selected six projects to demonstrate and 

accelerate deployment of technologies to reduce directly emitted PM and/or NOX. The 

projects funded by the program include: 

• Solar thermal energy storage technology to enable zero emission agricultural 

pumps in remote locations unserved by electrical infrastructure; 
2-8 DRAFT SJVAPCD PM2.5 Progress Report 

• Retrofit drive train systems to upgrade existing refuse trucks to hydraulic hybrid 

technology; 

• Plug-in electric hybrid off-road equipment; 

• NOx-reducing catalyst utilizing an 85 percent renewable ethanol blend (E85) as 

reductant for off-road engines allowing for wider adoption of the technology 

without diesel emission fluid [urea] infrastructure; 

• Advanced selective catalytic reduction system for use on dairy biogas; and 

• Innovative gas turbine system with high tolerance for low quality gas, enabling 

the use of mildly treated landfill gas and biogas. 

The District has been working to identify additional funding for technology advancement 

through available grant and partnership opportunities. The District has been working 

closely with EPA in developing the Clean Air Technology Initiative, an interagency 

partnership focused on the development of advanced emission reduction technologies. 

This partnership has resulted in an additional $400,000 of EPA funding opportunity for 

of technology advancement. The District has allocated an additional $1 million of local 

funds in the 2010-11 Budget that may be used for technology advancement projects. 

With these funds, the District plans to open a second competitive RFP for new projects 

in early 2011. Successful outreach during the past year in the course of launching the 

TAP has considerably expanded awareness of the program with potential technology 

partners and other agencies. This upcoming funding opportunity is expected to attract 

significant interest from potential partners. 

Through TAP, the District is also active in establishing partnerships and collaborations 

to leverage the experience and resources of the District into regional technology efforts. 

The District is collaborating in the Clean Air Technology Initiative, a partnership with the 

ARB, EPA Region 9, and the South Coast AQMD, to identify technology advancement 

opportunities and goals. The District is actively forming partnerships with regional 

universities to build and expand local capacity for research and development in the San 

Joaquin Valley. The District has also worked in collaboration with South Coast AQMD to 

co-fund projects to develop prototype natural gas-fired, fan-type central furnaces with 

reduced NOX emissions. 
Air Quality Analysis 3-1

Section 3 - Air Quality Analysis 

This Progress Report evaluates the Valley’s ambient PM2.5 concentrations since the 

adoption of the 2008 PM2.5 Plan. Under many metrics, Valley PM2.5 data has shown 

significant improvements. The District conducted extensive analysis of ambient air 

quality data to better understand the nature of observed improvements and to better 

understand areas within the data set that have been more resistant to improvement. 

The Valley’s ambient PM2.5 concentrations are influenced by a number of factors, 

including pollutant emissions, natural or exceptional events, and meteorology. The 

Valley’s direct PM2.5 and NOx emissions have decreased significantly since PM2.5 

monitoring began in 1999. Many more emissions reductions will be achieved between 

2011 and 2015. Emissions decreases achieved thus far are contributing to lower 24-

hour and annual average ambient PM2.5 concentrations, indicating general 

improvement in air quality. The degree of improvement in ambient PM2.5 

concentrations varies by site, year, time of year, and time of day. This section is a 

summary of the District’s thorough analysis, which is presented in Appendix A. 

3.1 PM2.5 Trends 

3.1.1 Winter PM2.5 trends 

The Valley’s PM2.5 concentrations vary throughout the year. PM2.5 levels are typically 

highest during the winter months as a result of low-level inversion layers that trap 

pollution in the atmosphere and increased PM2.5 emissions from residential wood 

burning and other sources. However, since the 2008 PM2.5 Plan was adopted, the 

Valley has experienced some of the cleanest winters on record, thanks in part to District 

Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters) and associated 

residential wood burning curtailment days between November 1 and February 28. 

Under these wood burning prohibitions, and with the public’s compliance with these 

prohibitions, the Valley continues to experience more “Good” air quality index (AQI) 

days and fewer “Unhealthy” AQI days in the November to February time period (Figure 

3-1). Wood burning prohibitions reduce emissions of some of the most health-impacting 

particles when and where these reductions are most needed. As a result, Valley 

residents are experiencing better air quality due to implementation of the 2008 PM2.5 

Plan and due to the involvement of the general public. 
3-2 DRAFT SJVAPCD PM2.5 Progress Report 

Figure 3-1 Valley Air Quality Improvements during Wood Burning Season 

Wood Burning Season (Nov 1 - Feb. 28) AQI

Good AQI

Unhealthy 

AQI

0

50

100

150

200

250

300

350

400

450

2005-2006 2006-2007 2007-2008 2008-2009 2009-2010 2010-2011

Total days in each AQI category in each county

3.1.2 Daily PM2.5 Trends 

Many of the Valley’s air monitoring sites use real-time PM2.5 monitors, which produce 

hourly PM2.5 measurements. The District uses this data every day to produce daily air 

quality forecasting, wood burning prohibitions, public health notifications, and Real-time 

Air Advisory Network (RAAN) notifications for schools. For this Progress Report, the 

District compiled long-term diurnal profiles to analyze how PM2.5 concentrations vary 

throughout the day at each Valley monitoring site. The District found that PM2.5 

concentrations generally peak in the early morning and late evening, with lower 

concentrations during the middle of the day. From year to year, this general pattern has 

remained consistent for most sites, but the magnitude of peaks have generally 

decreased to lower PM2.5 concentrations overall. 

Two notable exceptions to this typical pattern are sites in Fresno and Corcoran. Data 

from the Fresno 1st Street site, as shown in Figure 3-2, shows more evening 

improvement, “flattening” the evening peak. Rule 4901 wood burning prohibitions are 

most likely generating this progress in evening PM2.5 levels in Fresno. 

The profile of measurements from Corcoran, on the other hand, shows the development 

of a mid-day peak, which is higher than the evening peak in 2009 (see Appendix A). 

The District will continue to analyze this finding as more data becomes available to 

determine if there could be new source activity that may be impacting these daily 

patterns. 
District Strategy 3-3

 Figure 3-2 Average Annual PM2.5 Diurnal Profiles by Year at Fresno-First 

Monitoring Site 

Fresno-First

0

5

10

15

20

25

30

35

40

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23

Hour

Annual Avg Hourly Concentration (μg/m3)

2002 2003 2004 2005 2006 2007 2008 2009 2010

2010 data is preliminary and has not yet been fully reviewed for quality assurance and control.

3.1.3 Annual Trends 

The District evaluated single-year annual average trends to assess PM2.5 progress and 

potential issues. Overall, despite some year-to-year variation, the Valley’s annual 

average PM2.5 concentrations are decreasing. In 2010, only two Valley monitoring 

sites had annual average PM2.5 concentrations above the level of the annual NAAQS 

of 15 μg/m3. In contrast, in 2005, eight Valley monitoring sites had annual average 

PM2.5 concentrations above the NAAQS, and in 2000, all Valley monitoring sites had 

annual averages PM2.5 concentrations above the NAAQS. See Appendix A for more 

information on annual averages. 

3.2 Design values 

Design values are one metric for assessing air quality improvements. Design value 

calculations are three-year averages that follow EPA protocols for rounding, averaging 

conventions, determining sufficiency in the number of samples, etc. The results provide 

consistency and transparency to determine basin-wide attainment for both components 

of the federal PM2.5 NAAQS: the 24-hour PM2.5 standard of 65 μg/m3, and the annual 

PM2.5 standard of 15 μg/m3. 

Figures 3-3 and 3-4 show improvement in Valley design values. These figures also 

demonstrate that average ambient PM2.5 concentrations vary by monitoring site within 

the Valley. In general, monitoring sites in the northern part of the Valley continue to 

record the lowest ambient PM2.5 concentrations. 
3-4 DRAFT SJVAPCD PM2.5 Progress Report 

Figure 3-3 PM2.5 24-hour Design Value Comparison, 2002 (2000-2002 Average) 

and 2010 (2008-2010 Average) 

Figure 3-4 Annual PM2.5 Design Value Comparison, 2002 (2000-2002 Average) 

and 2010 (2008-2010 Average) 
District Strategy 3-5

Some recent design values do not reflect the expected PM2.5 progress, but design 

values alone do not necessarily provide for the best or most complete understanding of 

air quality trends. Analysis shows that a few unusual issues overwhelmed the Valley’s 

significant emissions reductions to impact certain design values. The purpose of this 

analysis is not to excuse the Valley from additional work to improve air quality, but to 

better inform the District on what types of additional work will be most effective. 

3.2.1 Wildfires 

In the summer of 2008, just months after adoption of the 2008 PM2.5 Plan, California 

experienced a record number of wildfires, with 5,812 fires burning 1,339,839 acres. The 

resulting emissions, most from outside the Valley, caused serious public health impacts 

and unprecedented levels of PM2.5 and ozone in the Valley and throughout the state. 

These wildfires were natural events, not reasonably preventable or controllable, so it is 

inappropriate to use 2008 data without recognition of these circumstances. These fires 

might ordinarily be excluded from official calculations per EPA’s Exceptional Events 

policy, with proper documentation. The District and ARB limit the submittal of 

documentation for these events, and EPA generally reviews only those requests that 

will directly affect an area’s attainment status. 

 

In its effort to more accurately characterize ambient PM2.5 concentrations for this 

Progress Report, the District evaluated the Valley’s PM2.5 data with careful 

consideration of exceptional events, including those not formally submitted to EPA. 

Official design value calculations otherwise include measurements from these events. 

In annual averages, data influenced by wildfires can mask improvements in PM2.5 

concentrations during other times of the year. 

3.3 Summary 

Design values summarize a site’s large amounts of data with just two concentrations: an 

annual average, and a value representing 24-hour peaks. These parameters are 

important for attainment determinations, but alone will not reveal all relevant PM2.5 

trends. Appendix A to this Progress Report presents the District's analysis of the 

Valley’s ambient PM2.5 data in greater detail. 
3-6 DRAFT SJVAPCD PM2.5 Progress Report 

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Ongoing Challenges 4-1 

Section 4 - Ongoing Challenges 

This Progress Report documents the District’s significant progress in implementing the 

2008 PM2.5 Plan and its control strategies. The District’s efforts and the efforts of 

Valley businesses and residences are reducing emissions of directly emitted PM2.5 and 

PM2.5 precursors, and this corresponds to improvements in ambient PM2.5 

concentrations. These past successes give us confidence that future efforts will 

continue to be effective. However, PM2.5 challenges remain. EPA revised the PM2.5 

NAAQS in 2006 while retaining the 1997 NAAQS and its requirements. The 2008 

PM2.5 Plan strategy is contributing to the Valley’s progress towards both standards by 

their respective attainment dates. EPA is expected to issue another revised PM2.5 

NAAQS in 2011. These parallel PM2.5 NAAQS are summarized in Table 4-1. 

Table 4-1 Summary of PM2.5 NAAQS 

PM2.5 NAAQS thresholds 

NAAQS 24-hour Annual 

Attainment 

Plan to EPA 

Latest 

Attainment Date 

1997 

NAAQS 65 μg/m3 15 μg/m3 2008 2015 

2006 

NAAQS 35 μg/m3 15 μg/m3 2012 2019 

2011 

NAAQS EPA anticipates proposing a revised PM2.5 NAAQS in 2011. 

4.1 Risk-based Strategy to Maximize Public Health Benefits 

The District has already implemented several generations of emissions control 

measures on stationary sources, and there are not many available or foreseeable 

opportunities remaining for new control measure commitments. Health-based NAAQS 

are becoming increasingly stringent, yet remain as mass-based standards that do not 

account for particle speciation, even though PM health effects vary by species. Taking 

these factors into account, the District is now pursuing a risk-based strategy to 

maximize public health benefits while concurrently contributing to the Valley’s progress 

towards the mass-based standards. 

Through a risk-based strategy, the District can prioritize control measures and programs 

that reduce the most health-impacting PM2.5 species while reducing overall PM2.5 

concentrations. For example, the Valley's ambient PM2.5 concentrations are 

predominately secondary ammonium nitrate, which does not impact public health as 

much as other types of PM2.5. In contrast, directly emitted PM associated with urban 

areas and roadways seem to be the most health-impacting. 

As the risk-based approach is implemented, the District will continue to review existing 

health studies and support new studies to identify the most health-impacting PM 

species. The District will be increasingly better equipped to develop regulatory and 

incentives strategies that place higher priority on reducing pollutant species that most 
4-2 DRAFT SJVAPCD PM2.5 Progress Report 

impact public health. The District may also be able to dedicate Technology 

Advancement Program (see Section 2.5.3) funds toward efforts that will decrease the 

most health-impacting emissions. 

Several of the District’s rules already reduce emissions reductions from more healthimpacting pollutant sources. As discussed in Section 3 and Appendix C of this Progress 

Report, District Rule 4901, Wood Burning Fireplaces and Wood Burning Heaters, has 

been reducing harmful species of PM2.5 when and where those reductions are most 

needed: in urbanized areas when air quality is forecast to limit PM dispersion. District 

Rule 9310, School Bus Fleets, is decreasing emissions from older school buses, 

reducing children’s exposure to these particles and reducing PM concentrations in 

urban areas. 

District incentive programs also contribute to a risk-based approach. The Fireplace 

Change-out Program and the School Bus Grant Program have accelerated or 

supplemented emissions reductions associated with their respective rules. Through the 

District’s popular Clean Green Yard Machine grant program, the District has replaced 

over 2,000 high-polluting gas-powered lawn mowers with cleaner electric mowers, 

decreasing the localized health risks associated with the use of gas-powered lawn and 

garden equipment, particularly in urban areas where use of this equipment is pervasive. 

The District’s information and educational programs also contribute to the risk-based 

strategy. The Air Quality Flag Program provides daily county-by-county air quality 

notification to participating schools throughout the Valley. In 2010, the District 

developed the Real-Time Air Quality Advisory Network (RAAN) as an innovative new 

tool to provide hourly air-quality information to Valley schools. RAAN alerts subscribing 

school staff, parents, and other interested parties via email when the hourly ozone or 

PM levels increase or decrease significantly, based on monitors closest to their school, 

enabling schools to modify sports and physical activities in light of current local air 

quality as appropriate. 

As PM2.5 standards become increasingly stringent, the District’s multi-faceted, riskbased approach can help the Valley maximize health benefits while assuring 

expeditious attainment. This Progress Report shows that the Valley continues to make 

progress towards EPA’s health-based air quality standards for PM2.5. There are more 

opportunities to improve the Valley’s PM2.5 levels, as ARB and the District implement 

recent control measures and continue laying the groundwork to develop the District’s 

2012 PM2.5 Attainment Plan (for the 2006 PM2.5 NAAQS). The progress documented 

in this report is to be continued.