2008 PM2.5 Plan 

# Chapter 8

Reasonable Further Progress2008 PM2.5 Plan 

### This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 8: Reasonable Further Progress 2008 PM2.5 Plan 

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# Chapter 8: Reasonable Further Progress

8.1 INTRODUCTION

This chapter explains and demonstrate s reasonable further progress (RFP) by achieving incremental emission reductions r equired until the SJVAB reaches attainment of the federal PM2.5 air qua lity 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 pl ans 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 require ment 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 sh ows generally linear progress from the baseline emissions year thr ough the milestone inventory years.

• The baseline year inventory for RFP is the inventory for the year used as the base year for the attainment demonstrati on (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 t he 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 reducti ons that are achieved in each milestone year.

The Implementation Rule recognizes that t he attainment demonstration will identify the pollutants to be included in the RFP demonstr ation, the relative reductions needed for each of these pollutants, and the attainment year.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 8: Reasonable Further Progress 2008 PM2.5 Plan 

### 8-2 8.3 REASONABLE FURTHE R PROGRESS CALCULATIONS

Tables 8-1, 8-2, and 8-3 show benchma rk calculations specified in EPA’s Implementation Rule.
Table 8-1 Emissions Inventory Adju sted 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 Reduct ions (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 Reduct ions (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 Reduct ions (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 Mil estones as Tons per Day of Reductions (Calculation described in footnotes))

Column no. 2 3 4 5 6 7 8 9

Pollutant2005EmissionsInventory1AttainmentBenchmark,tpd2Number oftons to bereduced3Tons to bereduced by20094(relative to2005)2009 EIBenchmark5tpdTons to bereduced by20126(relative to2005)2012 EIBenchmark,tpd72014 EIBenchmark8tpd

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 SO 2 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 3San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Chapter 8: Reasonable Further Progress 2008 PM2.5 Plan 

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

Direct PM2.5 NOx SO 2 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 emissi ons 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 ar e 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 em issions; 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 re ductions held for contingency.

Table 8-4 Fraction of Reductions Ac hieved 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 1San Joaquin Valley Unified Air Polluti on 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 Pl an meets RFP requirement s, with continuous and generally linear progress towards attainment by achieving between 2% and 5% per year of emission reductions from dire ct PM2.5 and NOx. Emissions from SO 2 

### in both milestone years are below the attainment le vel. 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 t he Valley by 2009 and 2012, ensuring continuous progress towards attainment in 2014. Extr aordinary 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 reduc tions ensure that no stone has been left unturned. ARB’s baseline mobile source stra tegy is likewise achieving significant ongoing reductions from both on- and off-ro ad mobile sources between now and 2014. Due to the innovative nature of ARB’s new m easures and the technical complexities of implementation, the final in crement of the emission redu ctions needed for attainment will not occur until 2014.

In summary:

• Reductions in direct PM2.5 and prec ursor 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.