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 Ornellas

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: SJVUAPCD Governing Board

FROM: Seyed Sadredin, Executive Director/APCO

Project Coordinators: 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. Environmental Protection 

Agency (EPA).

BACKGROUND:

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

standards for fine particulate matter (PM2.5) in 1997, and the District’s 

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

would 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. All feasible 

measures and strategies have been considered to accomplish this 

goal.
SJVUAPCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN

December 20, 2012

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DISCUSSION:

The 2012 PM2.5 Plan is the latest effort in the District’s ongoing mission 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 positive air quality benefits 

throughout the Valley. Although air quality has improved, the Valley continues to 

experience unique and significant air quality challenges in attaining EPA’s increasingly 

stringent air quality standards. 

This 2012 PM2.5 Plan specifically addresses EPA’s 2006 standard (National Ambient 

Air Quality Standard, or NAAQS) for PM2.5, and builds upon long-term and aggressive 

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

Plan. Utilizing the Guiding Principles adopted by your 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 emissions 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 strategies 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 Standard
SJVUAPCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN

December 20, 2012

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adopted stringent regulations for heavy-duty trucks, off-road equipment, and other 

mobile sources. Measured air quality improvements in the Valley document the 

success of these innovative and effective rules. Table 1 summarizes some of the 

recently adopted District rules achieving emissions reductions in the coming years.

Table 1 Recently 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.
SJVUAPCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN

December 20, 2012

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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 

Valley’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 

reducing 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 from 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 when 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 significantly 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 emissions 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

VOC
SJVUAPCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN

December 20, 2012

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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 Conservation Management Practices rule both proved 

critical in assisting the Valley to eliminate exceedances of the federal PM10 standard 

and reach attainment of the standard in 2005 (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/m3(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/m3

)

Basin San Joaquin Stanislaus Merced

Fresno Kings Tulare Kern
SJVUAPCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN

December 20, 2012

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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 which 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 Above
SJVUAPCD Governing Board

ADOPT THE PROPOSED 2012 PM2.5 PLAN

December 20, 2012

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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. To provide overall strategic 

direction in developing this 2012 PM2.5 Plan, the District Governing Board adopted the 

following Guiding Principles at its February 2012 public 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 future 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 adequate 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 monetary 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 sources, 

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 bullet” 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 state and federal agencies to provide adequate resources and 

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 implementation 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. 
SJVUAPCD Governing Board

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13. Build off of the successes of the District’s Technology 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 that 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 District has left “no stone unturned” in evaluating all sources 

of emissions 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 this 

overlapping significance, NOx emissions reductions help to address both of the Valley’s 

biggest air 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 and 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 public, employers, and small businesses are also 

involved in reducing emissions by complying with regulations that focus on 

residential wood burning, employee commuting, commercial cooking, and other 

sources.

 Risk-based approach that prioritizes measures that 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.
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 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 efforts 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 

reductions 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 

the 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. 
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Figure 7 San Joaquin Valley Emissions Reductions, 2012 PM2.5 Plan

Despite the extensive and innovative regulations already in place, the 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-Creditability 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 Emissions
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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 

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

reductions from residential wood combustion is critical for the Valley (specifically the 

Bakersfield and Corcoran areas) 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” days 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 Plan will not enact 

immediate changes on how the Residential Wood Burning 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 amendment 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 will explore the feasibility of 

allowing the use of EPA certified wood-burning devices during certain curtailment days. 

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 

given 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.
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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 the proposed amendments would reduce directlyemitted 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, modeling 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 District’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 has 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 technologies 

and the socio-economic impacts of the proposed regulation.

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

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

comprehensive and multi-faceted strategy. In 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 District’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 emissions 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 SIP. 
SJVUAPCD Governing Board

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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 technology 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 reductions 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): Examine 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 opportunities. 

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 District, 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.
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Why does the Valley face such unique air quality challenges?

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 exceedance days.

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 significant 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 concentrations. 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 enormous 

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

ozone and particulates. This is illustrated by the fact that the San Joaquin Valley has 

far fewer pollutant emissions per square mile (“emission density”) than other regions in 

California that have equivalent or even better air quality. 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 of 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 scientific 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 Valley 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 identify the most efficient and cost-effective emissions control 

strategies to reduce PM2.5 concentrations in Central California. 
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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 with EPA guidance, and involved 

thousands of hours of sophisticated 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 achieved through the plan’s control 

strategy bring the entire 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 deadline 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 Attainment

While the 2012 PM2.5 Plan 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 for 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/m3. 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/m3and 0.34 μg/m3, respectively, per ton 

of emissions reduced.

That said, the Valley’s largest sources 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 emissions 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 potential 

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 that 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 of 
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evaluating the potential effectiveness of ammonia controls in reducing PM2.5 

concentrations in the Valley. 

Plan brings the Valley into attainment 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, through implementation of this 

plan’s emissions control strategy, all areas in the Valley will attain the federal 24-hour 

PM2.5 standard of 35.4 μg/m3by 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 

experience PM2.5 concentrations below the federal standard by 2015, 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 require 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 carries a 

tremendous cost. These reductions are ultimately 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, an additional 2.4 

tons per day of NOx reductions would be 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. The District’s “no stone unturned” 

evaluation of emissions sources and emissions 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. There are no 

unused control strategies available that could 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 available.
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Figure 8 Bakersfield PM2.5 Design Values 

Plan achieves significant health benefits for Valley residents

The District has also estimated the fundamental metric associated with implementation 

of the 2012 PM2.5 Plan – the health benefits. The 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 of 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/m3

)

NOx tons/day

Design Value:

66 ug/m3

Design Value: 

35.4 ug/m3

(Attainment)

NOx Emissions
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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 diseases and premature deaths

based on improvements in county-level PM 2.5 concentrations, the economic value 

associated with health 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 lost 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. 

Additionally, 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 

numerous 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 representatives 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 Board 
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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 comments 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 during 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 and further limiting its use would place a greater 

economic burden on families in 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 wood 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 to lower the curtailment level to 20 μg/m3 would help minimize PM2.5 

emissions buildup during the Valley’s multi-day stagnation periods. While lowering the 

wood burning curtailment threshold would increase the number of “no burn” days in the 

Valley, emissions 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 process 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. 
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Amending Rule 4692 to reduce emissions from under-fired commercial 

charbroiling

Comments: 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 reductions 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 promising technology demonstration efforts underway, time is still 

needed to prove the technologies in actual restaurant conditions 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 to 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

Comments: Some commenters raised questions about ammonia emissions and their 

potential role in assisting the Valley in attaining 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: The 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 only 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, the District and 

ARB explored the effectiveness of ammonia reductions in reducing PM2.5 

concentrations. The review of extensive science on this subject and new modeling 
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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, 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 of 

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

concentrations in the Valley.

SIP-creditability of incentive programs and new District Rule 9610

Comments: 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 future 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 

emissions since 1992. District incentive programs have been modeled on effective 

state incentive programs like the Carl Moyer Program. Enforceability has already been 

built into the District incentive programs through requirements that include pre and postproject 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) Requirements (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 source 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, expanding rule applicability to increase 

emissions reductions required would not be reasonable or cost-effective. Requiring 

minimum emissions reductions before mitigating through payment would have no net 
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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 ruleamending project and determined that District Rule 4311 is as stringent or more 

stringent than flares rules in other air districts. EPA concurs with this assessment 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 Fleet Requirements

Comment: 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 solid 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 operators 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 may not be economically feasible. 

Additionally, the emissions benefit associated with such a transition is minimal given the 

stringent particulate matter requirements 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.
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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 regulations in the plan are developed 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 the 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 requests 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 pages)

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

Attachment C: Initial Study and Proposed Negative Declaration (43 pages) 

Attachment D: Notice of Determination (9 pages)