GOVERNING BOARD

William O’Brien , Chair Supervisor, Stanislaus County

Skip Barwick, Vice Chair Vice Mayor, City of Tulare

Oliver L. Baines III Councilmember, City of Fresno

Tony Barba Supervisor, Kings County

Sally J. Bomprezzi Councilmember, City of Madera

Judith G. Case Supervisor, Fresno County

Ronn Dominici Supervisor, Madera County

Henry Jay Forman, Ph.D. Appointed by Governor

Harold Hanson Councilmember, City of Bakersfield

Leroy Ornella s Supervisor, San Joaquin County

Alexander C. Sherriffs, M.D. Appointed by Governor

Chris Vierra Mayor , City of Ceres

Hub Walsh Supervisor, Merced County

Raymond A. Watson Supervisor, Kern 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: December 20, 2012

TO: SJV UAP CD G overning B oard

FROM: Seyed Sadredin, Executive Director/APCO

Project Coordinator s : Samir Sheikh /Errol Villegas

RE: ADOPT THE PROPOSED 2012 PM2.5 PLAN

RECOMMENDATION:

1. Adopt the Negative Declaration , and

2. Adopt the Proposed 2012 PM2.5 Plan , and

3. Authorize the Chair to sign the resolution adopting the Proposed

2012 PM2.5 Plan , and

4. Authorize the Chair to sign the Notice of Determination and direct staff to file the Notice of Determination within 5 days , and

5. Direct staff to forward the adopted 2012 PM2.5 Plan and the attached resolution to the California Air Resources Board (ARB) for approval and submittal to the U.S. Environme ntal Protection Agency (EPA).

BACKGROUND :

T he U.S. Environmental Protection Agency (EPA) set the first

standard s for fine particulate matter (PM2.5) in 1997 , and t he District ’s

2008 PM2.5 Plan demonstrate d how the San Joaquin Valley (Valley)

wo uld attain the 1997 standard by April 2015. EPA lowered the 24

- hour PM2.5 standard to 35 μg/m3 in 2006

. This 2012 PM2.5 Plan meets applicable federal requirements and demonstrates that all areas of the Valley will attain EPA’s 2006 PM2.5 standard by 2019, with the majority of the Valley meeting the standard earlier

. A ll feasible measures and strategies have been considered to accomplish this goal.SJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

2 DISCUSSION :

The 2012 PM2.5 Plan is the latest effort in the District’s ongoing mis sion to improve the Valley’s air quality and protect the health of Valley residents. Through the adoption of numerous plans and strategies over the past several decades, emissions in the Valley have been significantly reduced, resulting in real and positi ve air quality benefits throughout the Valley. Although air quality has improved, the Valley continues to experie nce unique and significant air quality challenges in attaining EPA’s increasingly stringent air quality standards.

T his 2012 PM2.5 Plan specifically addresses EPA’s 2006 standard ( National Ambient Air Quality Standard , or NAAQS) for PM2.5 , and builds up on long

- term and aggressive strategies adopted by your Board, including the 2007 Ozone Plan and 2008 PM2.5

Plan . Utilizing the Guiding Pr inciples adopted by y our Board, this plan relies on the

latest science and best available information as its foundation, and was developed through an extensive public process . The resulting comprehensive, multi

- faceted
strategy achieves significant emissi ons reductions that will bring the Valley into attainment by 2019

, with the majority of Valley residents seeing attainment well ahead

of the 2019 deadline (see Figure 1 )

.

Figure 1 Valley Population Living in Attainment Areas through 2012 PM2.5 Plan

The District’s control strategies have significantly reduced emissions and have improved the Valley’s air quality

The District has implemented comprehensive regulatory control strateg ies over the past couple of decades. Since 1992, the District has adopted over 500 new rules and amendments to implement this aggressive control strategy. In addition, ARB has 0% 20% 40% 60% 80% 100%

2015 2016 2017 2018 2019



### % of Valley Residents in Areas

that Meet Federal StandardSJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2 .5 PLAN December 20, 2012

3 adopted stringent regulations for heavy

- duty trucks, off

- road equipment, and othe r mobile sources. Measured air quality improvements in the Valley document the

success of these innovative and effective rules. Table 1 summarize s some of the recently adopted District rules achieving emissions reductions in the coming years

.

Table 1 R ecently Adopted District Rules

District Rule Adoption/

Amendment Date(s) Emissions

Reduced (tons per day)

Rule 4103 Open Burning 05/19/2005

05/17/2007

04/15/2010 0.12 tpd NOx

0.34 tpd PM2.5

Rule 4106 Prescribed Burning and Hazard Reduction Burning 1/21/2001 NQ

Rule 4204 Cotton Gins 2/17/2005 0.79 tpd PM

Rule 4307 Boilers, Steam Generators, and Process Heaters 2 to 5

MMBtu/hr 12/15/2005

04/20/2006

10/16/2008

05/19/2011 3.36 tpd NOx

Rule 4308 Boilers, Steam Generators, and Process Heaters 0.075 to

<2 MMBtu/hr 10/20/2005

12/17/2009 3.30 tpd NOx

Rule 4309 Dryers, Dehydrators, and Ovens 12/15/2005 0.65 tpd NOx

Rule 4311 Flares 06/15/2006

06/18/2009 0.06 tpd SOx

Rules 4306 & 4320 Boilers, Steam Generators, and Process Heaters

>5 MMBtu/hr 03/17/2005

10/16/2008 3.50 tpd NOx

3.60 tpd SOx

Rule 4352 Solid Fuel Fired Boilers, Steam Generators and Process

Heaters 05/18/2006

12/15/2011 NQ

Rule 4354 Glass Melting Furnaces 08/17/2006

10/16/2008

09/16/2010

05/19/2011 3.37 tpd NOx

1.70 tpd SOx 0.11 tpd PM2.5

Rule 4550 Conservation Management Practices 08/19/2004 34.2 tpd PM

Rule 4692 Commercial Charbroiling 09/17/2009 0.08 tpd PM2.5

Rule 4702 Internal Combustion Engines 6/16/2005

04/20/2006

01/18/2007

08/18/2011 22.43 tpd NOx

Rule 4703 Stationary Gas Turbines 08/17/2006

09/20/2007 2.20 tpd NOx

Rule 4901 Wood Burning Fireplaces and Wood Burning Heaters 10/16/2008 2.40 tpd PM2.5 *

Rule 4902 Residential Water Heaters 03/19/2009 1.03 tpd NOx

Rule 4905 Natural Gas

- Fired, Fan

- Type Residential Central Furnaces 10/20/2005 2.6 tpd NOx

Regulation VIII Rules Fugitive PM10 Prohibitions 08/19/2004 20.4 tpd PM

Rule 9310 School Bus Fleets 09/21/2006 0.8 tpd NOx 0.03 tpd of PM2.5

Rule 9410 Employer

- based Trip Reduction 12/17/2009 0.6 tpd NOx

Rule 9510 Indirect Source Review 12/12/2005 2.2 tpd NOx 1.4 tpd PM

* As an average for November

– April; the reductions on any given “No Burn” day are much higher.SJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

4 These innovative strategies, such as the first

- of

- its

- kind Indirect Source Review regulation that reduces emissions from residential and commercial development, have proven to be highly effective, as evidenced by the steady rate of improvement in the

Valle y’s air quality. The District’s incentive program has become an increasingly important and effective strategy for reducing mobile source emissions that the District does not have direct regulatory authority over, with an expenditure of $481 million

reduci ng over 94,000 tons of emissions since 1992.

Through these efforts, from 1990 through 2005, the Valley saw NOx emissions reduced by 41%, VOC emissions reduced by 38%, and SOx emissions reduced by 75% (see Figure 2 ). In addition to reducing emissions fr om the Valley’s various industries and businesses, significant emissions reductions have also been achieved by the general public, with the District’s residential wood burning curtailment program critical in reducing PM2.5 concentrations during periods whe n they are most impactful to Valley

residents

.

Figure 2 San Joaquin Valley Emissions Reductions, 1990

– 2005

Furthermore, many rules recently adopted by the District and ARB include upcoming implementation deadlines that will continue to significant ly reduce emissions over the coming years in the course of implementing the 2012 PM2.5 Plan . These adopted regulations will achieve 247.8 tons per day (tpd) of NOx emi s sions reductions and 15.7 tpd of PM2.5 emissions reductions , greatly contributing to the Valley’s progress toward

the 2006 PM2.5 standard.

-80% -70% -60% -50% -40% -30% -20% -10% 0% 1990 1995 2000 2005
Percent Decrease

NOx

SOx

VOCSJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

5 These efforts to reduce emissions in the Valley have resulted in real and significant improvements in the Valley’s air quality. The District’s residential wood burning

curtailments and landmark Cons ervation Management Practice s rule both proved critical in assisting the Valley to eliminate exceedances of the federal PM10 standard

and reach attainment of the standard in 200 5 (see Figure 3 ). The Valley’s 24

- hour PM2.5 “design values

, ” used to measure progress relative to the federal standard

, have dropped by 40% since 2001, and are now below the 1997 federal 24

- hour PM2.5 standard of 65 μg/m 3 (see Figure 4 ).

Figure 3 Exceedances of PM10 Standard Eliminated

Figure 4 San Joaquin Valley PM2.5 Design Value Trends 0 1 2 3 4 5 6 7 8 9 10

1992 1999 2004 2011 PM10 Exceedances

Zero exceedances

- in attainment

0 20 40 60 80 100 120

Design Value ( μg/m 3 ) Basin San Joaquin Stanislaus Merced

Fresno Kings Tulare KernSJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

6 Exceedances of the 1997 and 2008 federal 8

- hour ozone standards have dropped by 42% and 30% since 1992, respectively (see Figure 5 ). With respect to the Air Quality Index (AQI), in the winter season, during wh ich the Valley sees its highest PM2.5 concentrations, the number of “good” AQI days has increased by 18%, while the number of “unhealthy” AQI days has decreased by 80% since 2000 (see Figure 6 ).

Figure 5 San Joaquin Valley Ozone Trends

Figure 6 San Joaquin Valley Air Quality Index Trends -45% -40% -35% -30% -25% -20% -15% -10% -5% 0% 1992 1999 2004 2011 Percent Decrease 1997 Standard
(84 ppb)

2008 Standard
(75 ppb)

0 50 100 150 200 250 300 350 400 Number of County - Days Good Unhealthy and AboveSJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

7 Guiding Principles

This 2012 PM2.5 Plan establishes the District ’s strategy for attaining the 2006 PM2.5

standard as expeditiously as possible, and synthesizes the District’s strategies for improving air quality and public health in the Valley. T o provide overall strategic direction in developing this 2012 PM2.5 Plan , the District Governing Board adopted the following Guiding Principles at its February 2012 pub lic hearing:

1. With public health as our number one priority, meet the national ambient air quality standards as expeditiously as practicable.

2. Use sound science as the plan’s foundation. This includes efforts to assess public health impacts, predict futur e air quality, determine the extent of emissions reductions needed, and evaluate the availability, effectiveness, and feasibility of emission control measures.

3. Consider the Valley’s unique challenges and develop cost

- effective strategies that provide ade quate operational flexibility and minimize costs to Valley

businesses.

4. Consider all opportunities for timely, innovative, and cost

- effective emission reductions. Consider traditional regulations, but look beyond traditional regulations to incorporate mo netary incentives, policy initiatives, guidance documents, and outreach, including working with cities and counties to incorporate 2012 PM2.5 Plan principles into their general plans.

5. Given that 80% of the Valley’s NOx emissions originate from mobile sour ces, provide a balanced approach to reducing mobile and stationary source

emissions.

6. Devise and implement reasonable strategies that involve the public in reducing

emissions.

7. Prioritize strategies that contribute to the District’s Risk

- based Strategy by achieving the greatest public health benefits.

8. Prioritize strategies that contribute to attainment of multiple air quality standards.

9. Recognize that there is no “silver bull et” for attainment. In this plan and upcoming attainment plans, every sector

— from the public through all levels of government, businesses, and industry

— must continue to reduce emissions.

10. Compel s tate and f ederal agencies to provide adequate resources an d regulatory assistance to reduce emissions from sources under their jurisdiction.

11. Address air pollutant transport issues with air districts neighboring the Valley.

12. Provide ample opportunity for public participation and feedback in the design and imple mentation of these plans. Utilize the planning process to also inform participants of the Valley’s air quality challenges and successes as well as actions that can be taken to improve Valley air quality.SJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

8 13. Build off of the successes of the District’s Tech nology Advancement Program by identifying further opportunities to continue fostering technology advancement, thus paving the way for new emissions control devices to be increasingly used in the San Joaquin Valley.

Plan includes comprehensive strategy t hat builds on existing strategies and involves all Valley sectors

The District’s 2012 PM2.5 Plan is a multifaceted strategy that utilizes a combination of conventional and innovative control strategies to reduce emissions of PM2.5 and other pollutants that form PM2.5

. The Valley’s successes in adopting regulations and other strategies that have improved the Valley’s air quality provide the foundation for this plan. In developing this plan, the Distric t has left “no stone unturned” in evaluating all sources

of emission s for potential strategies to reduce emissions (see Appendix D ). In addition to reducing direct emissions of PM2.5, this plan focuses on reducing oxides of nitrogen (NOx) emissions, which is not only a predominant pollutant in the formation of PM2.5 in the Valley, but is also the focus of the District’s ozone reduction strategies. Due to t his overlapping significance

, NOx emissions reductions help to address both of the Valley’s biggest a ir quality challenges : PM2.5 and ozone. Along with comprehensive efforts at the local level to reduce emissions, reducing mobile source emissions that are not under the direct authority of the District is critical to attaining the standard, and this plan includes state and federal measures that will provide significant new emissions reductions in the coming years. As outlined below, this plan’s comprehensive control strategy includes regulatory actions, incentive programs, technology advancement, policy a nd legislative positions, public outreach, participation and communication, and additional strategies (see Chapter 10 ).

Overview of 2012 PM2.5 Plan Strategy

Local (District) Strategy:

 Wide

- ranging regulations that reduce emissions from various Valley industries (stationary sources) and the general public. These regulations address stationary source emissions from boilers and steam generators, internal combustion engines, glass melting furnaces, turbines, and other sources. Additionally, the general p ublic, employers, and small businesses are also involved in reducing emissions by complying with regulations that focus on residential wood burning, employe e commuting, commercial cooking, and other

sources.

 Risk

- based approach that prioritizes measures th at expedite attainment of the standard and provide the greatest public health benefits.

 Incentive programs that target cost

- effective mobile sources not under the direct jurisdiction of the District, including on and off

- road vehicles and equipment.

 Technology advancement efforts that assist in the development of new zero and

near zero

- emissions technologies critical to addressing increasingly difficult air quality standards.SJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

9  Research/Further studies that will continue to develop policy

- relevant air quality science and additional potential opportunities for clean air strategies.

 Policy and legislative efforts that assist in shaping new legislation and policies at the local, state, and federal levels that promote emission reduction efforts.

 Outreach ef forts that assist in educating and empowering the public in getting involved in efforts to reduce emissions and improve the Valley’s air quality.

State/Federal Strategy:

 Regulations that reduce emissions from the variety of mobile and other sources

under state and federal jurisdiction, including on

- road sources such as passenger vehicles and heavy duty trucks, and off

- road sources such as construction equipment.

 Incentive funding and programs that assist the District in our effort to accelerate

reduction s from mobile sources.

 Technology advancement efforts including funding and collaborative support in the development of new zero and near zero

- emissions technologies.

Through this comprehensive attainment strategy, the Valley will achieve attainment of

th e federal PM2.5 standard by 2019 (see Figure 7 ), reducing NOx emissions, the predominant pollutant leading to the formation of PM2.5, by 55% over this period. 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 fast as possible, but also reduce the PM2.5 emissions that pose the greatest health impacts to Valley residents. These strategies, including new measures to further reduce

emissions from residential wood burning and commercial charbroilers, 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.SJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

10 Figure 7 San Jo aquin Valley Emissions Reductions, 2012 PM2.5 Plan

Despite the extensive and innovative regulations already in place, t he District evaluated the technological feasibility and cost

- effectiveness of all potential control technologies that might be available to further reduce emissions. The District also sought to maximize public health improvements resulting from its attainment strategies through

the Risk

- based Strategy. This thorough analysis, presented in Appendices C and D of the plan, resulted in numerous commitments for future District actions, not all of which are regulatory actions , such as new incentive programs and technology advancement efforts (summarized in Chapter 10)

. The following table (Table 2) outlines the new proposed regulatory strategies included in the 2012 PM2.5 Plan

.

Table 2 New Proposed Regulatory Control Strategies

Proposed Regulatory Control Strategies Adoption

Date

Adopt new Rule 9610 (SIP

- Credi ta bility of Incentives) : This will provide the District with a mechanism to claim SIP credit for emissions reductions through certain incentive programs. 2013

Amend Rule 4905 (Natural Gas

- fired, Fan

- type Residential Central Furnaces) 2015

Amend Rule 4308 (Boilers, Steam Generators, and Process Heaters 0.075 to <2 MMBtu/hr) 2015

Amend Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters) to lower the burning curtailment level to prevent PM2.5 buildup that may lead to a potential exceedance day. 2016

Amend Rule 4692 (Commercial Charbroiling) to reduce under

- fired charbroiler

emissions. 2017

0 50 100 150 200 250 300 350 400 450 500

2007 2014 2017 2019 Emissions (tons per day)

NOx Emissions PM2.5 Emissions SOx EmissionsSJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

11 Commitment to Strengthen Wood Burning Curtailment Program (Rule 4901)

Rule 4901 is currently one of the most cost

- effective and health

- protective District rules, reducing PM2.5 when and where reductions are most needed. Photochemical

m odeling for the 2012 PM2.5 Plan has shown that achieving additional emissions

reductions f rom residential wood combustion is critical for the Valley (specifically the

Bakersfield and Corcoran area s ) to reach attainment of EPA’s 2006 PM2.5 standard by

2019 . The proposed amendment to lower the curtailment level to 20 μg/m3 will help

minimize PM2 .5 emissions buildup during multi

- day periods of stagnation. Furthermore, reducing emissions from residential wood combustion achieves significant health benefits. Lowering the wood burning curtailment threshold would increase the number of “no burn” day s in the Valley, though air quality improvements that are projected to occur between now and implementation of a strengthened Rule 4901 will affect the magnitude of the increase in “no burn” days.

The commitment to amend Rule 4901 under this 2012 PM2.5 Pl an will not enact immediate changes on how the Residential Wood B urning Curtailment Program ( Check

Before You Burn ) is currently being implemented. Adoption of this PM2.5 plan would

not automatically amend Rule 4901 , but obligates the District to amend Rule 4901 at a

later date

. At that time, the rule will be amended through a full public process where the

District will evaluate all options and the economic impacts of reducing the wood burning curtailment level for Valley residents. During the rule ame ndment process, the District will consider all feasible options for strengthening Rule 4901 while also allowing flexibility for compliance with rule requirements

.

For example, the District will consider expanding the wood burning season to include March, April, and/or October. Expanding the curtailment season would potentially increase the number of curtailment days in each wood burning season, based on recent air quality data. However, PM2.5 concentrations associated with wood burning are not nearly as high in October as they are during the current November through February season, and extending the season may yield little overall benefit

.

As part of any future amendment to Rule 4901, the District w ill explore the feasibility of allowing the use of EP A certified wood

- burning devices during certain curtailment day s

. The District values the cleaner burning technology that has been developed in recent years, as demonstrated by the implementation of the District’s Burn Cleaner Program

, which was implemented to help Valley residents upgrade their current wood

- burning devices and open fireplaces to natural gas or propane devices, or clean pellet devices to alleviate the problem of particulates. Enforcing this added flexibility would be difficult gi ven the challenge in distinguishing wood smoke emissions from various wood burning devices, and the District would explore various options during the rule development process for ensuring that this issue is addressed

.SJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

12 Commitment to Reduce Emissions from Commercial Under

- fired Charbroilers (Rule 4692)

Amending Rule 4692 to include commercial under

- fired charbroilers would reduce about 0.4 tons per day of directly

- emitted PM2.5 Valley

- wide. Due to the location of these emissions reductions, and because t he proposed amendments would reduce directly

emitted PM2.5, there would be a significant benefit to ambient PM2.5 concentrations as a result of this amendment: 0.6 μg/m3 reduction in the PM2.5 concentration for

Bakersfield. Similar to Rule 4901 above, m od eling for this plan has shown that these reductions are important for assuring attainment in the Bakersfield area. In addition, the PM2.5 species and location of emissions reduced would achieve relatively large health benefits, consistent with the Distric t’s Risk

- based Strategy. Thus, the commitment to amend Rule 4692 is a very important component of this PM2.5 plan.

Promising prototype technologies are being demonstrated through South Coast AQMD’s charbroiler demonstration project, which the District ha s been actively participating in. However, time is still needed to prove the technologies in actual restaurant conditions (whereas the South Coast project is being conducted in a research facility) and for the technologies to become commercially available . Given the current state of technology, a compliance date of 2017 would accelerate the development and demonstration of new technology. The District will utilize its Charbroiler Incentive Program (ChIP) to assist in the demonstration and implementation of the technologies in anticipation of the 2017 compliance date. Furthermore, the

amendment of District Rule 4692 would go through an extensive public process, during which the District will address the cost effectiveness of installing the new technologie s and the socio

- economic impacts of the proposed regulation.

Incentive Programs and New Rule 9610 (SIP Creditability of Incentive s )

The above traditional regulatory controls are one component of the District’s comprehensive and multi

- faceted strategy. I n addition, the District’s incentive programs will continue to be an integral part of the District’s emissions reductions efforts, accelerating emissions reductions and encouraging technology advancements, particularly in the mobile source sector, which is not directly under the Distr ict’s regulatory jurisdiction.

Historically, states and local agencies have not been able to obtain credit in an attainment plan (state implementation plan, or SIP) for incentive

- based reductions. However, when given SIP credit, incentive

- based emissions reductions can be used alongside traditional regulatory

- based emissions reductions to meet federal Clean Air Act requirements. The District has conferred with EPA regarding the process for documenting and submitting the information necessary to receive SIP credit for

incentive

- based emi ssions reductions. The framework for establishing this SIP credit will be new District Rule 9610, which will establish the documentation, reporting, and public review process for the District to take credit for incentive

- based emissions

reductions in a SI P.SJV

U APCD Governing Board

ADOP T THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

13 Further Study Measures and Research

In the 2012 PM2.5 Plan , the District documents the importance of policy and legislative efforts as well as continued public outreach to its long

- range strategies. The District also notes the importance of technol ogy advancement efforts, continued research, and further study to continue to develop air quality science and evaluate new opportunities for clean air strategies. As further study measures are completed and opportunities for

additional emissions reduction s are identified, the District will implement feasible and effective control strategies, as appropriate. Table 3 summarizes the District’s further study measures and research commitments contained in the 2012 PM2.5 Plan

.

Table 3 Further Study Measures and Research

Further Study Measures and Research Study Completion

Date

Rule 4106 (Prescribed Burning): Examine feasibility of a biomass removal program. 2013

Rule 4311 (Flares): Review flare minimization plans and annual reports for further emissions reductions opportunities. 2013

SC 001 (Lawn Care Equipment): Emissions inventory evaluation and technology

demonstration. 2013

SC 005 (Asphalt/Concrete Operations): E xamine feasibility of warm mix asphalt. 2013

Rule 4550 (Conservation Management Plans): Analyze existing studies and support new studies to establish a more accurate inventory of PM2.5 emissions and identify potential additional emission reduction oppor tunities. 2014

Rule 4103 (Open Burning): Evaluate the feasibility of postponed burning activities every 5 years, as outlined in current rule. 2015

Rule 4570 (Confined Animal Facilities): Analyze existing studies on ammonia at dairies and evaluate potential ammonia controls for their effectiveness in reducing PM2.5 concentrations in the Valley. 2017

Ongoing Study and Research. Conduct and support going research that continues

to enhance the District’s understanding of PM2.5 concentrations and formation, including further health research in support of the District’s Risk

- Based Strategy. Ongoing

Transportation Conformity

Transportation conformity requirements are intended to ensure that transportation activities as planned by city and county agencies do not interfere with air quality progress. The Clean Air Act Section 176 requires that transportation plans, programs,

and projects conform to applicable air quality plans before being approved by a Metropolitan Planning Organization (MPO). Motor vehicle emissions budgets are the mechanism for assuring that transportation planning activities conform with the SIP.

The Distri ct, ARB, and the eight MPOs collaborated in the development of the 2012

PM2.5 Plan to include motor vehicle budgets based on the latest available motor vehicle activity and emissions data

.SJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

14 Why does the Valley face such unique air quality challenge s ?

The Valley’s geography and meteorology exacerbate the formation and retention of high levels of air pollution. Surrounding mountains and consistently stagnant weather patterns prevent the dispersal of pollutants that accumulate within the Valley. Temperature inversions, while present to some degree throughout the year, can last for days during the winter, holding in nighttime accumulations of pollutants, including wood smoke. It is during the winter that these days of stagnant weather lead to most of the Valley ’s PM2.5 ex ceedance day s.

The Valley’s natural challenge in cleaning out accumulated pollutants requires that the District and Valley industry and residents take greater efforts to meet the challenging federal PM2.5 standard and reduce signi ficant amounts of wintertime emissions. The episodic and seasonal nature of high PM2.5 concentrations may help to narrow the focus of emissions reductions, but also limits the number of months that strategies are most effective in reducing peak PM2.5 conc entrations. This overall complexity due to the Valley’s geography, meteorology, and nature of PM2.5 formation makes it difficult to predict and model PM2.5 concentrations.

Due to these unique circumstances, no other region in California faces the enormou s degree of difficulty that the Valley faces in meeting the ambient air quality standards for ozone and particulates. This is illustrated by the fact that the San Joaquin Valley has far fewer pollutant emissions per square mile (“emission density”) than o ther regions in California that have equivalent or even better air quality. The Valley has reduced its emissions at the same rate or better than other areas in California. Nonetheless, despite the Bay Area having six times more emissions per square mile than the Valley, that region enjoys good air quality most of the time because of the sea breezes that disperse its emissions. The South Coast air basin, which has more favorable meteorology and topography than the Valley, is already nearly in attainment o f the same PM2.5 standard being addressed through this plan.

Plan is supported by strong scientific foundation and extensive modeling

The Valley is one of the most studied airsheds in the world in terms of the number of publications in peer

- reviewed sc ientific journals and other major reports. Such scientific analyses, and the field studies providing the data for these analyses, are the foundation of the modeling efforts for this plan. Public and private sector partnership through the San Joaquin Vall ey Air Pollution Study Agency (Study Agency) provided funding and coordination for many of these efforts. In particular, the Study Agency’s $28 million, ongoing California Regional Particulate Air Quality Study (CRPAQS) efforts have improved understanding of the Valley’s PM emissions, composition, and the dynamic atmospheric processes surrounding them. Through CRPAQS and the establishment of a strong scientific foundation about PM2.5 in the San Joaquin Valley , researchers have developed methods to identif y the most efficient and cost

- effective emissions control strategies to reduce PM2.5 concentrations in Central California.SJV

U APCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2 012

15 Photochemical modeling and other technical analyses conducted for this plan provide a weight

- of

- evidence for predicting future PM2 .5 concentrations throughout the Valley. Using the vast body of knowledge regarding formation of PM2.5 in the Valley, ARB performed extensive modeling to predict future PM2.5 concentrations throughout the Valley. This modeling was performed consistent wi th EPA guidance, and involved thousands of hours of sophistica ted computer modeling and review by a team of technical staff, including close coordination with the District. In addition to the modeling by ARB, the District has also performed extensive analysis that provides additional supporting evidence that the plan will effectively bring the Valley into attainment. These

efforts demonstrate that the emissions reductions ac hieved through the plan’s control strategy bring the enti re Valley into attainment of EPA’s 2006 PM2.5 standard

. Bakersfield is predicted to be the last area of the Valley to attain the standard, requiring

more emissions reductions and an attainment deadl ine of 2019. However , all areas of the Valley (Bakersfield included) should experience ongoing air quality improvements,

and most areas of the Valley will reach attainment earlier than 2019

.

Contribution of Ammonia Emissions Reductions Towards Attainmen t

While the 2012 PM2.5 P lan demonstrates expeditious attainment and includes all

reasonable controls for directly emitted PM2.5 and significant PM2.5 precursors (NOx, SOx, and PM2.5) , the District and ARB explored the effectiveness of ammonia

reductions f or PM2.5 attainment. Modeling sensitivity analysis shows that reductions in ammonia emissions achieve insignificant reductions in PM2.5 design values. One ton

of reduced ammonia emissions would reduce the Bakersfield

- California PM2.5 design value by just 0.008 μg/m 3

. NOx and directly emitted PM2.5 emissions reductions, on the other hand, are orders of magnitude more effective in reducing PM2.5 concentrations, with relative benefits of 0.08 μg/m 3 and 0.34 μg/m 3 , respectively, per ton

of emissions reduced.

That said, the Valley’s largest source s of ammonia emissions, confined animal facilities

, are already regulated under Rule 4570. District Rule 4570 is among the most stringent

rules in the nation and has already reduced 100 tons per day of ammonia emiss ions in the Valley. Despite the low PM2.5 benefit associated with ammonia reductions in the Valley, the District explored additional potential ammonia controls, including the possibility of applying sodium bisulfate (SBS) in dairies

, as identified as a po tential control measure in the South Coast Air Quality Management District’s (SCAQMD) 2012

Air Quality Management Plan (AQMP). The District determined that this control strategy would be ineffective, extremely costly, has potential detrimental unintended

consequences (such as water quality impacts) , and is likely infeasible for dairies within the San Joaquin Valley.

Overall, the District and ARB have concluded th at ammonia is not a significant precursor to PM2.5, and that there are currently no feasible ammonia control measures that would help expedite attainment in the Valley

. Despite this conclusion , the District added a further study commitment to the plan to continue to analyze and support studies regarding ammonia emissions from confined animal facilities, for the purpose ofSJV

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16 evaluating the potential effectiveness of ammonia controls in reducing PM2.5 concentrations in the Valley

.

Plan brings the Valley into attainme nt as expeditiously as possible

Attaining federal health

- based standards is an important milestone for improving public

health. The modeling conducted for this plan shows that, t hrough implementation of th is plan’s emissions control strategy , all areas in the Valley will attain the federal 24

- hour

PM2.5 standard of 35.4 μg/m 3 by 2019 , with the majority of Valley residents actually seeing attainment much sooner than the projected date of 2019 in Bakersfield. Figure 1 illustrates the Valley’s journey to attainment under this plan. As emissions are reduced through the plan’s control strategy, over 70 % of the Valley’s population quickly experienc e PM2.5 concentrations below the federal standard by 201 5

, with 94% of the population seeing attainment by 2017. Even where areas have not yet attained the standard, there will be continuous air quality improvements.

Attaining the federal standard by 2019 is extremely challenging, particularly in the southern Valley, and will r equire tremendous reductions in emissions. Given the significant contribution of ammonium nitrate to the Valley’s PM2.5 concentrations, reductions in NOx emissions are particularly important. To achieve the NOx reductions critical for reaching attainment in the Valley (see Figure 8) , ARB has adopted regulations that will significantly reduce NOx emissions from various mobile sources. Achieving this level of emissions reductions requires adequate time and carr ies a tremendous cost. These reductions are u ltimately achieved in time to bring most of the Valley into attainment well before 2019, with the exception of Bakersfield.

To illustrate, in order for Bakersfield to attain a year earlier by 2018, a n additional 2.4 tons per day of NOx reductions would b e needed in Kern County. To put this in perspective, achieving this level of emissions reductions is equivalent to virtually eliminating all passenger vehicles in Kern County

. T he District’s “no stone unturned”

evaluation of emissions sources and emissio ns controls did not reveal any additional reasonably available emissions reductions opportunities that could expedite attainment, with all new control strategies proposed for implementation by 2017. T here are no unused control strategies available that co uld achieve the reductions necessary to accelerate attainment, because every reasonable control measure is already included in the plan. Thus, the modeled emissions targets cannot be achieved before 2019, and 2019 is the most expeditious attainment year a vailable.SJV

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17

Figure 8 Bakersfield PM2.5 Design Values

Plan achieves significant health benefits for Valley residents

T he District has also estimated the fundamental metric associated with implementation

of the 2012 PM2.5 Plan

– the health benefits . T he District utilized an EPA

- developed

model (BenMAP) to estimate the annual reductions in morbidity (disease) and mortality (premature death) attributable to improved air quality due to the 2012 PM2.5 Plan in the attainment year o f 2019.

Through implementation of the comprehensive control strategy included in this plan and the resulting reductions in PM2.5 concentrations throughout the Valley, the District estimates the following health benefits (Table 5 ) : 0 10 20 30 40 50 60 70 80

0 50 100 150 200 250 300 350 400 450 500

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Design Value (ug/m 3 ) NOx tons/day Design Value: 66 ug/m 3 Design Value: 35.4 ug/m 3
(Attainment) NOx EmissionsSJV

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18 Table 4 Health Benefits Achieved through Implementation of the 2012 PM2.5 Plan

Health Impact Health Benefit (reduction in health impact)

Premature Death 671 Acute Myocardial Infarction, Hospital

Admissions 93

Asthma Age 0

- 19, Hospital Admissions 131 Cardiovascular, Hospital Admissions 175 Asthma Age 20

- 99, Hospital Admissions 246 Asthma Age 20

- 99, Emergency Room

Visits 407

Asthma Age 0

- 19, Emergency Room

Visits 699

Acute Bronchitis 1,498 Upper Respiratory Symptoms 15,523 Lower Respiratory Symptoms 19,011

Asthma Exacerbation 114,376 Work Loss Days 125,138

In addition to quantifying reductions in the number of disease s and premature death s based on improvements in county

- level PM 2.5 concentrations, the economic value

associated with heal th benefits can also be quantified . While assigning economic values to health impacts is difficult given the tremendous social values associated with these impacts, an existing body of literature attempts to connect health impacts to hard

costs such as lo st wages, or, in the case of premature death, a social value of $7.99 million per incidence. Using this model, the District estimates that implementation of the plan will achieve an annual Valley

- wide savings of $102 million in health costs in 2019.

Addi tionally, and more significantly, a social benefit of $5.36 billion is estimated for the 671 avoided premature deaths.

Plan prepared with extensive public input

The 2012 PM2.5 Plan was prepared through an extensive public process that provided

numero us opportunities for the public to offer suggestions for improving the plan over the past year. The District has worked closely with various stakeholders, including its partner agencies ARB and EPA, environmental and community advocacy groups, and industry r epresentatives to share information regarding the plan, and to receive comments and suggestions.

The District and ARB co

- hosted public workshops in April, June, and October 2012, at District offices and via webcast, to outline and receive comments on 2012 PM2.5 Plan

elements and potential strategies for reducing the Valley’s PM2.5 concentrations.

Discussions were also held almost monthly during the District’s public Governing BoardSJV

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19 hearings

, where the public was invited to provide feedback. The plan was frequently discussed with the District’s Citizen’s Advisory Committee and Environmental Justice Advisory Group. The District also met with interested stakeholders (including the Central Valley Air Quality Coalition, or CVAQ ) upon request.

The comment s and questions received during workshops and associated written comment periods have been integral to development of this plan. All significant comments and responses are summarized and posted on the District’s website.

Some of the key issues raised d uring development of the 2012 PM2.5 Plan are summarized below:

Amending Rule 4901, Wood Burning Fireplaces and Wood Burning Heaters

Comments: The District received many comments related to its commitment to amend Rule 4901 to lower the wood burning curtailment threshold. Many commenters were in favor of amending the rule, due to the health benefits and PM2.5 benefits associated

with the rule. Some commenters were against amending the rule, stating that firewood is an inexpensive heating source a nd further limiting its use would place a greater

economic burden on families i n already

- tough economic times. Some commenters suggested expanding the wood burning curtailment season to include March, April, and/or October, or placing greater restrictions on the installation of wood burning devices in new residential developments. Other commenters suggested that residents

be allowed to use certified woo d burning devices during certain wood burning

curtailments

. The District also received comments asking the District to impose a total ban on all residential wood burning.

Response: Reducing wood burning emissions under Rule 4901 has proven to be the

most cost

- effective control strategy for improving the Valley’s air quality, and is essential to attaining the federal standard addressed by the 2012 PM2.5 Plan

. The proposed

amendment t o lower the curtailment level to 20 μg/m3 would help minimize PM2.5 emissions buildup during the Valley’s multi

- day stagnation periods

. While l owering the wood burning curtailment threshold would increase the number of “no burn” days in the Valley, emissi ons reductions and air quality improvements expected in the coming years will help to reduce the potential impact on the number of “no burn” days.

A number of issues associated with lowering the curtailment threshold would need to be addressed in the pr ocess of amending Rule 4901, including the economic impact to Valley residents, and how clean certified devices would be treated under a lower

threshold

. The District would amend Rule 4901 under a full public process where all options would be evaluated, and public comments would be taken and considered.SJV

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ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

20 Amending Rule 4692 to reduce emissions from under

- fired commercial charbroiling

Comment s : The plan commits to amend the rule to reduce emissions from under

- fired commercial charbroilers, with implementation by 2017. Some commenters asked if this was as expeditious as possible. Other commenters asked if there was adequate assurance of emissions reductions technologies to support the commitment to amend the rule and to support the emissions red uctions accounted for in the plan.

Response: Reducing PM2.5 emissions from commercial under

- fired charbroiling operations is essential for attaining the federal standard. Furthermore, due to the nature and location of these PM2.5 emissions, this proposed control strategy would achieve relatively large health benefits consistent with the District’s Risk

- based Strategy. Thus, the commitment to amend Rule 4692 is a very important component of this PM2.5 plan.

While there are p romising technology demonstration efforts underway, time is still needed to prove the technologies in actual restaurant conditi ons and for the technologies to become commercially available. Given the current state of technology, considerable time, investment, and effort will be needed in order to develop viable technologies. A compliance date of 2017 would accelerate technology development

and demonstration efforts. An amendment t o District Rule 4692 would go through an extensive public process , during which the District would work closely with stakeholders to evaluate the feasibility and cost effectiveness of installing the new technologies and potential socio

- economic impacts.

The potential for ammonia emissions reductions to assist with attainment

Comment s : Some commenters raised qu estions about ammonia emissions and their potential role in assisting the Valley in attain ing the federal PM2.5 standard. These

commenters mistakenly believed that ammonia reductions could assist the Valley in attaining the standard earlier than proposed in the plan.

Response: T he proposed plan control strategy achieves the emissions necessary to bring the Valley into attainment , primarily through PM2. 5 and NOx emissions

reductions. Most areas of the Valley will reach attainment before 2019, with all proposed new measures achieving reductions by no later than 2017 , and remaining

NOx reductions needed to bring Bakersfield into attainment onl y being achieved by

2019. Of course, 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, t he District and ARB explored the effectiveness of ammonia reductions in reducing PM2.5

concentrations

. The review of extensive science on this subject and new modelingSJV

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21 conducted for this plan 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. Additionally, the District has already reduced

ammonia emissions from confined animal facilities, the largest source of ammonia emissions under its jurisdiction, by 100 tons per day through adoption of Rule 4570, the most stringent rule of its kind in the nation . The District has not found additional feasible measures that could significantly reduce ammonia emissions. Despite this current understanding of ammonia’s relative insignificance as a precursor, t he District added a further study commitment to t he plan to continue to analyze and support studies regarding ammonia emissions from confined animal facilities, for the purpose of evaluating the potential effectiveness of ammonia controls in reducing PM2.5 concentrations in the Valley

.

SIP

- creditability of incentive p rograms and new District Rule 9610

Comment s : Many commenters spoke in support of the District’s incentive programs and the role these programs plan in reducing emissions in the Valley. However, some commenters had questions about how these emissions reductions were to be credited in this plan and f uture plans through new District Rule 9610, SIP

- Creditability of

Incentives.

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

the District. These programs have reduced over 93,000 tons of NOx, VOC, and PM2.5

emissi ons 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

pro ject equipment inspections, monitoring

, and reporting. The development of Rule 9610 will provide the mechanism for the District to take credit for these surplus, quantifiable, and enforceable emissions reductions.

Indirect Source Review (ISR) Requirement s (Rule 9510)

Comment: A few commenters suggested that the District should consider amending the Indirect Source Review (ISR) Rule to expand its applicability and require additional

emissions reductions

.

Response: The District is the first air agency to adopt an indirect source rule regulating new development projects. The District’s rule is recognized as the benchmark, or best available control, for regulating indirect sources. The legal issues associated with adopting and implementing indirect sour ce regulations are numerous and complex, as is evidenced by the fact that the District has spent over five years successfully defending its existing rule in state and federal court.

Given the existing stringent requirements, e xpanding rule applicability t o increase emissions reductions required would not be reasonable or cost

- effective. Requiring minimum emissions reductions before mitigating through payment would have no netSJV

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22 benefit on emissions reductions. For the mobile sources targeted under ISR, the PM10 emissions involved are almost all PM2.5 emissions, so the current PM10 limits are largely PM2.5 limits. More specific recommendations regarding what, in particular, could be expanded in the rule would assist the District to more fully consider this

comment in the future.

Flare Requirements (Rule 4311)

Comment: A few commenters suggested that the District should consider amending the flare rule (Rule 4311) . A commenter claimed that Santa Barbara has a stronger flare rule than the San Joaquin Valley

.

Response: The District did a thorough analysis of flare rules adopted by other air districts in California during both this plan development process and the 2009 rule

amending project and determined that District Rule 4311 is as stringent or more stringent than flares rules in other air districts. EPA concurs with this assess ment as illustrated by the approval of the rule as a SIP revision in 2011. The District has committed to a further study of the flare rules to continue to evaluate potential opportunities for additional emission reductions from these sources

.

Public Fl eet Requirements

C omment: A commenter suggested that the District should consider adopting a public

fleet rule like South Coast rule.

Response: ARB has adopted a Solid Waste Collection rule that, similar to South Coast’s rule, reduces emissions from sol id waste collection vehicles (SWCV)

. South Coast Air Quality Management District’s fleet rule requires that SWCV fleets transition to operating entirely on alternative fuel beginning in 2011. ARB’s Solid Waste Collection Vehicles Rule gives fleet operato rs several options to meet Best Available Control Technology requirements for particulate emissions by the end of 2010. One compliance option under the ARB rule is the use of alternative fuel. Many of the District’s SWCV fleets have already converted to alternative fuels

. Transitioning a fleet from diesel to alternative fuel can be costly and ma y not be economically feasible

. Additionally, the emissions benefit associated with such a transition is minimal given the stringent particulate matter requireme nts under ARB’s rule , and the relatively small difference in NOx emissions, if any, between diesel and alternative fuel vehicles . The District will continue to advance the turnover of SWCVs through the use of incentive

funds.SJV

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ADOPT THE PROPOSED 2012 PM2.5 PLAN December 20, 2012

23 Public Review Process for the Proposed 2012 PM2.5 Plan

The Proposed 2012 PM2.5 Plan was made available 30 days prior to the public hearing on November 20, 2012, with an associated 14

- day public comment period. Comments received on the proposed plan have been summarized and responded to and are included with this package as Attachment D.

After the plan is adopted, the public will have additional opportunities for involvement as the individual strategies, programs, and r egulations in the plan are develope d over the coming years.

California Environmental Quality Act (CEQA)

The 2012 PM2.5 Plan underwent environmental review in accordance with the requirements of CEQA. A proposed negative declaration has been issued by the District and made available for public review and comment. The public review period ended on December 8, 2012. No comment letters were received.

FISCAL IMPACT :

This 2012 PM2.5 Plan describes a major air quality management strategy that will be implemented in the future over a period of several years. While the workload implications will likely be significant and will affect several District departments, the

extent of th e fiscal impact on future budgets is uncertain. As the fiscal impacts of the

2012 PM2.5 Plan become more defined, staff will request the needed resources from your Board either through annual budget req uests or mid

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

Attachments:

Attachment A: 2012 PM2.5 Plan Resolution ( 6 p ages)

Attachment B: Proposed 2012 PM2.5 Plan ( 1, 120 pages)

Attach ment C: Initial Study and Proposed Negative Declaration ( 4 3 pages)

Attachment D : Notice of Determination (9 pages)