2008 PM2.5 Plan

Chapter 8 

 

Reasonable Further Progress 
2008 PM2.5 Plan

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San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Chapter 8: Reasonable Further Progress 

2008 PM2.5 Plan

8-1 

Chapter 8: Reasonable Further Progress 

8.1 INTRODUCTION 

This chapter explains and demonstrates reasonable further progress (RFP) by 

achieving incremental emission reductions required until the SJVAB reaches attainment 

of the federal PM2.5 air quality standard. The data in this chapter is based on 

information that has been provided in other chapters and appendices of this plan. 

8.2 REASONABLE FURTHER PROGRESS REQUIREMENTS 

The Clean Air Act (Act) requires attainment plans to meet RFP by achieving incremental 

emission reductions to ensure attainment of National Ambient Air Quality Standards 

(NAAQS) by the attainment date (Section 171(1)). The Act does not identify specific 

emission reduction benchmarks that must be met for PM attainment plans. 

EPA’s interpretation of the Act’s RFP requirement in the Implementation Rule for the 

PM2.5 NAAQS identifies the concept of achieving generally linear progress 

(72 FR 20633). According to 40 CFR 51 Subpart Z Section 51.1000 (Definitions): 

• The RFP benchmark plan is the RFP plan that shows generally linear progress 

from the baseline emissions year through the milestone inventory years. 

• The baseline year inventory for RFP is the inventory for the year used as the 

base year for the attainment demonstration (for this plan, the baseline year 

inventory is 2005). 

• Milestone year inventories occur in 2009 and 2012. 

• Full implementation inventory is the level of emissions that demonstrates 

attainment. In the San Joaquin Valley the full implementation inventory is 2014. 

Determination of RFP milestones involves several steps: 

1. Determining the total reductions that must be achieved to reach 

attainment. 

 The 2008 PM2.5 Plan satisfies this in Chapter 3. 

 2. Determine the attainment year that is as expeditious as practicable. This plan 

 identifies 2014 as the most expeditious attainment date practicable in the San 

 Joaquin Valley. 

 3. Determining the fraction of reductions that are achieved in each milestone 

 year. 

The Implementation Rule recognizes that the attainment demonstration will identify the 

pollutants to be included in the RFP demonstration, the relative reductions needed for 

each of these pollutants, and the attainment year. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Chapter 8: Reasonable Further Progress 

2008 PM2.5 Plan

8-2 

8.3 REASONABLE FURTHER PROGRESS CALCULATIONS 

Tables 8-1, 8-2, and 8-3 show benchmark calculations specified in EPA’s 

Implementation Rule. 

Table 8-1 Emissions Inventory Adjusted for Plan Control Strategy 

(in tons per day) 

Description 2005 2009 2012 2014

 Direct PM2.5 

Baseline Inventory (Table B-1) 86.0 79.8 77.0 75.0

 Subtract District CM Reductions (Table 6-3) 0.00 1.60 6.69 6.70

 Subtract ARB CM Reductions (Chapter 9) 0.00 0.00 0.00 5.00

Direct PM2.5 Inventory After Plan Control 

Strategy 86.0 78.2 70.3 63.3

 NOx 

Baseline Inventory (Table B-2) 575.4 500.9 424.4 376.2

 Subtract District CM Reductions (Table 6-3) 0.00 2.43 8.56 8.97

 Subtract ARB CM Reductions (Chapter 9) 0.00 0.00 0.00 76.00

NOx Inventory After Plan Control Strategy 575.4 498.5 415.8 291.2

 SOx 

Baseline Inventory (Table B-3) 26.4 23.0 23.8 24.5

 Subtract District CM Reductions (Table 6-3) 0.00 0.06 0.92 0.92

 Subtract ARB CM Reductions (Chapter 9) 0.00 0.00 0.00 0.00

SOx Inventory After Plan Control Strategy 26.4 22.9 22.9 23.6

Table 8-2 Determining Benchmark Milestones as Tons per Day of Reductions 

(Calculation described in footnotes)) 

Column no. 2 3 4 5 6 7 8 9 

Pollutant 

2005 

Emissions 

Inventory 1

Attainment 

Benchmark, 

tpd 2 

Number of 

tons to be 

reduced 3

Tons to be 

reduced by 

2009 4

(relative to 

2005)

2009 EI 

Benchmark 5

tpd 

Tons to be 

reduced by 

2012 6 

(relative to 

2005)

2012 EI 

Benchmark, 

tpd 7

2014 EI 

Benchmark 8 

tpd

Direct 

PM2.5 86 63.3 22.7 10.1 75.9 17.7 68.3 63.3 

NOx 575.4 291.2 284.2 126.3 449.1 221.0 354.4 291.2 

SO2 26.4 23.6 2.8 1.2 25.2 2.2 24.2 23.6 

1 Column 2 shows the baseline inventories from Table B-2 

2 Column 3 comes from Chapter 3, which shows that the 2014 inventory with plan controls will bring the 

Valley into attainment (see also Chapter 9) 

3 Column 4 = Column 2 – Column 3 

4 Column 5 = 44.4% of Column 4; 

5 Column 6 = Column 2 – Column 5 

6 Column 7 = 77.8% of Column 4; 

7 Column 8 = Column 2 – Column 7 

8 Column 9 = Column 3
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Chapter 8: Reasonable Further Progress 

2008 PM2.5 Plan

8-3 

Table 8-3 Comparison of 2009 and 2012 RFP Benchmarks and Projected Levels 

Direct PM2.5 NOx SO2

Year Benchmark 1 Projected 

Level 2 Benchmark 1 Projected Level 2 Benchmark 1 Projected Level 2 

2009 75.9 78.2 449.1 498.5 25.2 22.9 

2012 68.3 70.3 354.4 415.8 24.2 22.9 

1 From Table 8-3, Columns 6 and 8 

2

 From Table 8-2, shaded rows

As discussed earlier, EPA’s Implementation Rule specifies that generally linear 

progress should be achieved and that emissions in the milestone years should be at 

levels that are roughly equivalent to the benchmark emission levels. The 2009 and 

2012 projected levels shown in Table 8-3 are the milestone year emission levels for 

RFP. Table 8-4 presents calculations that demonstrate that the emission reductions 

achieved meet the RFP requirements. Cumulative emission reductions are the 

reductions achieved from the 2005 baseline emissions; they include the reductions from 

the on-going control programs as well as new reductions from the control measures in 

the plan, minus the emission reductions held for contingency. 

Table 8-4 Fraction of Reductions Achieved in Each Milestone Year 

PM2.5 

Milestone 

Year 

Baseline 

Emissions 

(tpd) 

Cumulative 

Emission 

Reductions (tpd) 

Percent of Emission 

Reductions Needed 

for Attainment 

Percent 

per year 

2005 86.0 

2009 79.8 7.1 32 2 

2012 77.0 15 68 2 

2014 75.0 22 100 3 

NOx 

Milestone 

Year 

Baseline 

Emissions 

(tpd) 

Cumulative 

Emission 

Reductions (tpd) 

Percent of Emission 

Reductions Needed 

for Attainment 

Percent 

per year 

2005 575.4 

2009 500.9 59.6 22 3 

2012 424.4 142.3 53 4 

2014 376.2 266.9 100 5 

SOx 

Milestone 

Year 

Baseline 

Emissions 

(tpd) 

Cumulative 

Emission 

Reductions (tpd) 

Percent of Emission 

Reductions for 

Attainment 

Percent 

per year 

2005 26.4 

2009 23.0 3.5 125 3 

2012 23.8 3.5 125 2 

2014 24.5 2.8 100 1 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Chapter 8: Reasonable Further Progress 

2008 PM2.5 Plan

8-4 

As shown in the above table, the PM2.5 Plan meets RFP requirements, with continuous 

and generally linear progress towards attainment by achieving between 2% and 5% per 

year of emission reductions from direct PM2.5 and NOx. Emissions from SO2 in both 

milestone years are below the attainment level. In terms of cumulative progress 

towards attainment, there is steady progress for each pollutant as shown in Table 8-5, 

so that 100% of the necessary reductions are achieved by the attainment date. 

Vast reductions will be achieved in the Valley by 2009 and 2012, ensuring continuous 

progress towards attainment in 2014. Extraordinary progress has been made thus far 

and will continue to be made. Attainment by 2014 requires a sizable magnitude of 

reductions. NOx alone must be reduced by 50% between 2005 and 2014. The District’s 

far-reaching stationary and area source reductions ensure that no stone has been left 

unturned. ARB’s baseline mobile source strategy is likewise achieving significant 

ongoing reductions from both on- and off-road mobile sources between now and 2014. 

Due to the innovative nature of ARB’s new measures and the technical complexities of 

implementation, the final increment of the emission reductions needed for attainment 

will not occur until 2014. 

In summary: 

• Reductions in direct PM2.5 and precursor emissions are being achieved as 

quickly as possible; 

• There is a downward trend in emissions between 2009 and 2012 at a rate of 

2% to 5% per year; 

• The Valley will reach attainment as expeditiously as practicable.