San loaqu¡n Valley t

AIR PflLLUTI(lI{ CflI{TRflL DISTRICT HEALTHY AIR LIVINGSeptember 25,2014

Jared Blumenfeld

U.S. EPA Region lX

75 Hawthorne Street

San Francisco, CA 94105

RE: San Joaquin Valley Unified Air Pollution Control District Request for

Reclassification of the San Joaquin Valley as a Serious PM2.5

Nonattainment Area for the Federal 1997 PM2.5 Standard

Dear Jared Blumenfeld,

As the local agency in charge of cleaning the air within the eight county region of the

San Joaquin Valley Air Basin (San Joaquin, Stanislaus, Merced, Madera, Fresno,

Tulare, Kings, and the central and western portions of Kern County), the District is

committed to improving the Valley's air quality and protecting the health of Valley

residents. ln achieving cleaner air, the challenges that the San Joaquin Valley faces

are unmatched by any other region in the nation. Surrounding mountains, stagnant

weather patterns, and strong inversions make the formation of particulate air pollution in

the Valley inevitable and prevent air pollutants from dispersing,

Due to the extreme drought (which has not been seen in the last 119 years) and the

related weather conditions for just a few months in 2013-14 which caused historically

high stagnation and strong inversions combined with extreme dry conditions

experienced over the winter of 2013-2014, it is now impossible for the Valley to show

attainment of the federal 1997 Pl\Az.5 standard by the 2014 attainment date projected in

the District's 2008 PM2.5 Plan. Prior to the recent extreme drought conditions, the

Valley was making significant progress and was on the verge of attaining the 1997

annual PM2.5 standard.

As you know, the recent D.C, Circuit Court ruling in 2013 now requires EPA to

implement CAA subpart 4 requirements for implementation of federal PM2.5 standards,

Given the significant air quality impacts associated with the extreme drought, this

provides the District with an opporlunity to seek additional time for attainment and avoid

a finding of failure to attain the 1997 PM2.5 standard by the current 2014 Moderate area

attainment date, Under Section 188(b) of subpart 4, the District formally requests that

the Valley be reclassified to Serious since demonstrating attainment by the current 2014

attainment date is impracticable (see attached documentation).

Seyed Sadredin

Executive Director/Air Pollution Control 0fficer

lllorthern Region

4800 Entetprise Way

Modesto, CA 95356.8718

Tel: (209) 557-6400 FAX: {209) 557-6475

Contral Bogion (M¡in 0ffice)

1 990 E. Gettysburg Avenue

Fresno, CA 53726.0244

Tel: {559) 230-6000 FAX: (559) 230.6081

Southern Eegion

34946 Flyover Court

Baksrsfield, CA 93308.9725

Tel: ô61-392.5500 FAX: 661.392.5585

www.valleyair.org www.healthyairliving.com Prinred m úcvclsd p¿p€t o
September 25,2014

Page 2 of 2

With the extreme drought conditions of 2013-2014 factored into the Valley's attainment

status for years to come, this initial reclassification request would not by itself provide an

attainment deadline the Valley can meet. Because both 2013 and 2014 were influenced

2015 averages would have to be impossibly low in the southern portion of the Valley in

order to reach attainment, By reclassifying the Valley as Serious and providing a one

year attainment deadline extension to 2015, the District would work with the State Air

Resources Board and EPA to prepare and adopt a new PM2.5 Plan (anticipated by

spring of 2015), ahead of an EPA finding of failure to attain. The extreme drought will

add difficulty to the planning process for the new PM2.5 plan, and will likely drive the

need for additional control measures, Given the stringent control measures already in

place in the Valley, it will be extremely difficult to identify sufficient additional emissions

reductions as a result,

The District thanks you for EPA's time and effort in considering our request, Follow-up

inquiries can be directed to Mr. Sheraz Gill, Director of Strategies and lncentives, at

(559) 230-5800 or at Sheraz.Gill@valleyair,org. We look forward to working closely with

EPA staff as the proposed request is finalized.

Respectfully,

Seye a tn

Executive Director/Air Pollution Control Officer

Attached:

SJVUAPCD Board ltem Number 9: Review and Approve Actions to Address Air

Quality lmpacts Resulting from the Exceptional Weather Conditions Caused by

the Recent Drought

cc

Lynn Terry, ARB

Karen Magliano, ARB

Deborah Jordan, EPA

Kerry Drake, EPA
GOVERNING BOARD

Hub Walsh, Chair

Supervisor, Merced County

Tom Wheeler, Vice Chair

Supervisor, Madera County

Oliver L. Baines III

Councilmember, City of Fresno

Tony Barba

Supervisor, Kings County

Skip Barwick 

Councilmember, City of Tulare 

Sally J. Bomprezzi

Councilmember, City of Madera

Dennis Brazil

Mayor, City of 

John Capitman, Ph.D.

Appointed by Governor

Judith G. Case McNairy

Supervisor, Fresno County 

David Couch

Supervisor, Kern County 

Bob Elliott

Supervisor, San Joaquin County

Harold Hanson

Councilmember, City of Bakersfield

William O’Brien

Supervisor, Stanislaus County

Alexander C. Sherriffs, M.D.

Appointed by Governor

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: August 21, 2014

TO: SJVUAPCD Governing Board

FROM: Seyed Sadredin, Executive Director/APCO

Project Coordinator: Sheraz Gill

RE: ITEM NUMBER 9: REVIEW AND APPROVE 

ACTIONS TO ADDRESS AIR QUALITY IMPACTS 

RESULTING FROM THE EXCEPTIONAL 

WEATHER CONDITIONS CAUSED BY THE 

RECENT DROUGHT

RECOMMENDATIONS:

1. Pursue legislative and administrative remedies to obtain legal 

designation as Exceptional Events under the federal Clean Air 

Act for weather conditions experienced due to drought.

2. Direct the Executive Director/APCO to submit a formal request

including supporting documentation as detailed in this 

memorandum to the U.S. Environmental Protection Agency 

(EPA) to reclassify the San Joaquin Valley as a Serious 

nonattainment area for the 1997 PM2.5 standard.

3. Direct the Executive Director/APCO to develop a new State 

Implementation Plan for the 1997 PM2.5 standard under the 

Serious nonattainment classification for the Governing Board’s 

consideration in the spring of 2015.

BACKGROUND:

Until the exceptional weather conditions experienced due to the recent 

drought, the District was on track to attain the 1997 annual PM2.5 

standard before the federally mandated deadline of December 2014. 

The District’s 2008 PM2.5 Plan satisfied all federal implementation 

requirements for the 1997 PM2.5 standard at the time of adoption and 

demonstrated attainment based on projected 2012-2014 PM2.5 levels. 

All emission reduction commitments under that plan have been fulfilled. 

Due to the extreme drought, stagnation, strong inversions, and
SJVUAPCD Governing Board

ITEM NUMBER 9: REVIEW AND APPROVE ACTIONS TO ADDRESS AIR QUALITY IMPACTS 

RESULTING FROM THE EXCEPTIONAL WEATHER CONDITIONS CAUSED BY THE RECENT 

DROUGHT

August 21, 2014

2

historically dry conditions experienced over the winter of 2013-2014, the Valley cannot 

show attainment even if the Valley experienced zero PM2.5 pollution for the last three 

quarters of 2014.

The Clean Air Act includes provisions for excluding uncontrollable “exceptional events” 

from a region’s attainment determination, but the current EPA framework specifically 

excludes stagnation and drought conditions. Given the significant air quality impacts in 

2013-2014 due to the extreme weather conditions, attainment of the 1997 annual PM2.5 

standard based on 2012-2014 data is impossible. 

Additionally, the D.C. Circuit Court recently ruled that EPA erred by using Clean Air Act

subpart 1 instead of subpart 4 in establishing its PM2.5 implementation rule, upon which 

the District’s and other PM2.5 plans nationwide had been based. This item describes 

the recommended path provided under the Clean Air Act subpart 4 for addressing the 

detrimental air quality impacts associated with the recent extreme weather conditions 

and extending the Valley’s attainment deadline for the 1997 annual PM2.5 standard.

DISCUSSION:

The 1997 annual PM2.5 standard was set at 15.0 μg/m3. The design value (DV) for the 

annual PM2.5 standard, which is the official EPA metric used to determine whether an 

area is in attainment of a standard, is defined as the 3-year average of annual averages 

over three consecutive years. Each individual annual average is calculated as the 

average among the four quarterly averages throughout the year. For example, the 2014 

design value would be calculated as the average among the annual averages for the 

years 2012, 2013, and 2014, where the average of each of these individual years is 

calculated as the average among their respective quarterly averages.

In 2012 the Bakersfield-Planz air monitoring site, which is the current peak PM2.5 site in 

the District, recorded an annual average value of 14.7 μg/m3, below the standard of 

15.0 μg/m3. This site, along with the rest of the District’s PM2.5 air monitoring sites, 

was making significant progress towards attaining the 1997 annual PM2.5 standard. 

However, due to the exceptional weather conditions experienced during the winter of 

2013-2014, exceedingly high PM2.5 concentrations were experienced, causing a 2013 

annual average of 22.8 μg/m3for the Bakersfield-Planz site.

As detailed further below, due to the extreme weather and high values already 

experienced at this site in the 1st quarter of 2014, the averages for the 2nd, 3rd, and 4th

quarters of 2014 would need to be zero for Bakersfield-Planz to reach attainment for the 

2012-2014 period. The following discusses the magnitude of the weather conditions 

experienced during the winter of 2013-14, and its impact on the Valley’s ability to attain 

the 1997 annual PM2.5 standard.
SJVUAPCD Governing Board

ITEM NUMBER 9: REVIEW AND APPROVE ACTIONS TO ADDRESS AIR QUALITY IMPACTS 

RESULTING FROM THE EXCEPTIONAL WEATHER CONDITIONS CAUSED BY THE RECENT 

DROUGHT

August 21, 2014

3

Meteorology during the Winter Season of 2013-2014

This past winter, California Governor Jerry Brown declared a state of emergency due to 

extreme drought conditions in the state. This emergency declaration was based on 

record-low precipitation in 2013 and snow pack levels at only 20 percent of the normal 

amount of snow to provide water for the year. Specifically in the San Joaquin Valley, 

2013 represented the driest year since the start of record keeping in 1895. The Valley 

is currently experiencing an exceptional level of drought not seen in at least 119 years.

Although the Valley has experienced reductions in PM2.5 concentrations over the last 

15 years since the pollutant first began to be measured, the winter months of November 

through February continue to record the peak levels of each year. The following Figure 

1 displays the relative comparison between the lower concentrations in March through 

October, and the higher concentrations experienced during the winter.

Figure 1: Average PM2.5 by Month in 2013 in Stockton, Fresno, Bakersfield

Stable meteorology during the winter season can increase PM2.5 concentrations to high 

levels by providing strong temperature inversions and low wind speeds. When this 

occurs, the PM2.5 concentrations during the winter months of November to February 

can climb to very high levels. As seen in Figure 2, the winter of 2013-2014 experienced 

the strongest average atmospheric stability over the last 15 years (period during which 

0

10

20

30

40

50

60

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Average PM2.5 (μg/m3

)

Stockton Fresno Bakersfield
SJVUAPCD Governing Board

ITEM NUMBER 9: REVIEW AND APPROVE ACTIONS TO ADDRESS AIR QUALITY IMPACTS 

RESULTING FROM THE EXCEPTIONAL WEATHER CONDITIONS CAUSED BY THE RECENT 

DROUGHT

August 21, 2014

4

PM2.5 concentrations have been recorded), creating conducive conditions for the 

formation and retention of high PM2.5 concentrations. This was a result of a persistent, 

strong high pressure ridge over the eastern Pacific that effectively blocked weather 

disturbances from entering California, which inhibited dispersion during November, 

December, and January of this last winter season.

Figure 2: Average Atmospheric Stability per Winter Season

In addition to the historically strong atmospheric stability, the winter of 2013-2014 also 

experienced record low precipitation totals, with some locations breaking records over 

100 years old (see Table 2). These unprecedented dry conditions exacerbated the air 

quality challenge during the winter of 2013-2014. As a result of the extreme 

meteorology experienced in the Valley this last winter, PM2.5 concentrations reached 

peak levels that had not been recorded in over a decade, which in turn has increased 

the Valley’s federal PM2.5 design values, making the journey to attainment of the 

PM2.5 standards even more difficult.

-1.5

-1

-0.5

0

0.5

1

1.5

2

2.5

3

3.5

1999-20002000-20012001-20022002-20032003-20042004-20052005-20062006-20072007-20082008-20092009-20102010-20112011-20122012-20132013-2014

T850MB Stability Parameter ( ̊C)
SJVUAPCD Governing Board

ITEM NUMBER 9: REVIEW AND APPROVE ACTIONS TO ADDRESS AIR QUALITY IMPACTS 

RESULTING FROM THE EXCEPTIONAL WEATHER CONDITIONS CAUSED BY THE RECENT 

DROUGHT

August 21, 2014

5

Table 2: Calendar Year Rainfall Totals for Select California Cities

City 1981-2010 

Average (inches)

2013 Total

(inches)

Previous Record 

Low (inches)

Previous 

Record Year

Modesto 13.11 4.70 5.70 1929

Merced 12.50 3.79 6.00 2007

Fresno 11.50 3.01 3.55 1947

Visalia 10.93 3.47 4.10 1910

Bakersfield 6.47 3.43 1.87 1959

Sacramento 18.52 5.81 6.67 1976

San Francisco 23.65 5.59 9.00 1917

San Jose 14.90 3.80 6.04 1929

Los Angeles 12.82 3.65 4.08 1953

San Diego 10.34 5.57 3.41 1953

Impracticability of Attainment in 2014 due to Extreme Weather

As noted above, extreme weather conditions over the winter of 2013-2014 overwhelmed 

emissions controls and led to abnormally high PM2.5 levels. Because of this, 

attainment of the 1997 annual PM2.5 standard based on 2012-2014 data is impossible. 

Furthermore, reclassification to serious will not initially provide an attainment deadline 

the Valley can meet, since the serious deadline is based on 2013-2015 data, which is 

also heavily affected by the high PM2.5 values recorded during the winter period of 

2013-2014. 

To illustrate the impact of the 2013-2014 winter season’s extreme weather conditions on 

the Valley’s ability to attain the 1997 annual PM2.5 standard of 15.0 μg/m3, the following 

analysis shows what average values would need to be recorded in the year 2014 to 

reach attainment during the 2012-2014 period.

The design value (DV) for the annual PM2.5 standard, which is the official EPA metric 

used to determine whether an area is in attainment of a standard, is defined as the 3-

year average of annual averages over three consecutive years. In more detail, each 

individual annual average is calculated as the average among the four quarterly 

averages throughout the year. For example, the 2014 design value would be calculated 

as the average among the annual averages for the years 2012, 2013, and 2014, where 

the average of each of these individual years is calculated as the average among their 

respective quarterly averages.

Table 3 below shows the greatest value the 2014 annual average can be in order to 

have a design value of 15.0 μg/m3(which demonstrates attainment) for the three year 

attainment period of 2012-2014.
SJVUAPCD Governing Board

ITEM NUMBER 9: REVIEW AND APPROVE ACTIONS TO ADDRESS AIR QUALITY IMPACTS 

RESULTING FROM THE EXCEPTIONAL WEATHER CONDITIONS CAUSED BY THE RECENT 

DROUGHT

August 21, 2014

6

Table 3: Maximum Allowable PM2.5 Annual Averages in 2014 to Reach Attainment 

of Annual Standard in 2012-2014

Site 2012

Measured Actuals

2013

Measured Actuals

2014

Max Allowable 

for Attainment

Stockton-Hazelton 12.4 17.7 14.9

Manteca 8.1 11.6 25.3

Modesto 11.9 14.3 18.8

Turlock 14.8 15.0 15.2

Merced-M 9.5 13.5 22.0

Merced-Coffee 11.0 13.3 20.7

Madera-City 16.0 17.8 11.2

Clovis 15.4 15.9 13.7

Fresno-Garland 14.1 16.8 14.1

Fresno-Pacific 12.7 15.9 16.4

Tranquility 7.0 8.3 29.7

Corcoran 16.5* 15.6 12.9

Hanford 14.8 18.2 12.0

Visalia-Church 14.8 18.9 11.3

Bakersfield-California 13.0 20.0 12.0

Bakersfield-Planz 14.7 22.8 7.5

*Corcoran had a partial year in 2012 for PM2.5, data in 4th quarter only.

Under the federal regulations, attainment must be demonstrated at the design value 

monitoring site for the Valley, which is the Bakersfield-Planz monitoring station. Based 

on the actual air quality readings for the first quarter of 2014, which were severely 

impacted by the exceptional weather events caused by the extraordinary drought, the 

only way the Valley can reach attainment is for the last three quarters in 2014 to have 

zero PM2.5 concentrations. Therefore, actual data already demonstrates that reaching 

attainment in 2014 is impossible. 

Table 4: Scenario for Bakersfield-Planz to Reach Attainment in 2012-2014

Site 2012 2013 2014 2012-14 

Q1 (actual) Q2 Q3 Q4 Avg DV

Bakersfield-Planz 14.7 22.8 29.7 0 0 0 7.4 14.9

Legislative Efforts Regarding Recent Exceptional Weather Conditions

The extraordinary drought conditions which have not been seen in at least 119 years 

have led to weather conditions leading to excess air pollution concentrations. Your 

Board has concluded that these extraordinary weather conditions constitute exceptional 

events and should not skew the Valley’s attainment demonstration for PM2.5. Pursuant 

to your Board’s direction, a delegation of Board members and other Valley stakeholders 

traveled to Washington D.C. and advocated this position to the U.S. EPA and 

congressional representatives. 
SJVUAPCD Governing Board

ITEM NUMBER 9: REVIEW AND APPROVE ACTIONS TO ADDRESS AIR QUALITY IMPACTS 

RESULTING FROM THE EXCEPTIONAL WEATHER CONDITIONS CAUSED BY THE RECENT 

DROUGHT

August 21, 2014

7

Under current EPA policy the weather conditions that the Valley experienced this past 

winter are not eligible to be declared “exceptional events” since stagnation and lack of 

precipitation are not considered eligible events. This past spring members of the 

District Governing Board and staff met with high level EPA staff to discuss the possibility 

to declare the weather conditions experienced by the Valley this past winter as an 

exceptional event. EPA indicated that while short duration stagnation and lack of 

precipitation weren’t considered exceptional, the prolonged duration of the drought 

experienced in California may be eligible. At the request of your Board’s delegation, 

Valley Congressional representatives sent a letter to the EPA Administrator to request 

that EPA’s Exceptional Events Policy be revised to include drought conditions like those 

faced in the Valley as exceptional events (Attachment). Alternatively, the Congressional 

representatives were to pursue legislative changes to better clarify the treatment of 

prolonged drought conditions as potential Exceptional Events under the Clean Air Act. 

Subsequently, two pieces of legislation relative to EPA’s exceptional events policy, 

S.2526 (Flake)/H.R.4957 (Olson, McCarthy and 22 additional members of Congress), 

Commonsense Legislative Exceptional Events Reform (CLEER) Act of 2014 were 

introduced. As initially drafted, the bills dealt primarily with streamlining EPA’s 

exceptional events approval and appeal process, but the District was able to convince 

the authors to include language that clarified that the prolonged and extraordinary 

drought and related weather conditions faced by the Valley this past winter should be 

considered Exceptional Events. Although this legislation has the potential to aid the 

District in meeting the federal PM2.5 standards, it is not anticipated that these efforts 

will be successful before the regulatory attainment deadline of 2014.

Recent Litigation and the Path for Reclassification

EPA had been implementing its PM2.5 standards under the general provisions of CAA 

subpart 1. However, the Natural Resources Defense Council (NRDC), Sierra Club, the 

American Lung Association, and Medical Advocates for Healthy Air, represented by 

Earthjustice, brought a legal challenge against EPA (NRDC v. EPA) for not 

implementing the PM2.5 standard under the PM10-specific subpart 4. In January 2013, 

the D.C. Circuit Court agreed with these groups and required EPA to now implement the 

PM2.5 standards under CAA subpart 4. 

While the District continues to believe that the Valley should not be penalized for high 

PM2.5 values recorded as a result of exceptional weather conditions, as explained 

earlier, reaching a reasonable legislative or administrative remedy before the attainment 

deadline of 2014 is impossible and more time is needed. The above sited court ruling 

now provides a legal opportunity through subpart 4 for the District to seek additional 

time for attainment and avoid a finding of failure to attain it would have received in 2015 

under subpart 1.

Unlike subpart 1, subpart 4 requires nonattainment areas to be classified as either 

“moderate” or “serious.” An area’s classification determines the attainment deadline 
SJVUAPCD Governing Board

ITEM NUMBER 9: REVIEW AND APPROVE ACTIONS TO ADDRESS AIR QUALITY IMPACTS 

RESULTING FROM THE EXCEPTIONAL WEATHER CONDITIONS CAUSED BY THE RECENT 

DROUGHT

August 21, 2014

8

and other planning requirements. Accordingly, on June 2, 2014, EPA classified all 

areas as moderate for the 1997 PM2.5 standard, but not retroactively. For approved 

plans like the Valley’s 2008 PM2.5 Plan, the existing attainment date of 2014 stands, 

even though the moderate area attainment year would have been 2011 if subpart 4 had 

been used all along, not starting in 2013. Under Section 188(b) of subpart 4, the District 

can now request reclassification to Serious, which would set the attainment deadline to 

2015, based on a three year average of 2013-2015 data. To do so, the District must 

demonstrate that attainment by the 2014 deadline under the current Moderate 

classification is impracticable. As demonstrated earlier, based on actual readings to 

date, it is impossible for the Valley to attain the standard in 2014, even if the last three 

quarters of 2014 record zero PM2.5 concentrations.

New 2015 Plan for the 1997 PM2.5 Standard

Reclassification to Serious initially provides just one year more than the current 

attainment deadline. With the extreme winter of 2013-2014 still factored into the new 

attainment deadline, this initial reclassification request would not by itself provide an 

attainment deadline the Valley can meet. 

Despite the high PM2.5 concentrations that were recorded in the 1st quarter of 2014,

there is a possibility that the remainder of the year could record quarterly averages 

closer to the expected norm. Based on this conservative assumption, an annual PM2.5 

average value for each site can be calculated for the entire year of 2014 by projecting

2

nd, 3rd, and 4th quarter averages under more normal conditions. The maximum annual 

PM2.5 average in 2015 needed to bring each site into attainment during the 2013-2015 

period can then subsequently be calculated. These results are shown below in Table 5.
SJVUAPCD Governing Board

ITEM NUMBER 9: REVIEW AND APPROVE ACTIONS TO ADDRESS AIR QUALITY IMPACTS 

RESULTING FROM THE EXCEPTIONAL WEATHER CONDITIONS CAUSED BY THE RECENT 

DROUGHT

August 21, 2014

9

Table 5: Maximum Allowable PM2.5 Annual Averages Needed in 2015 to Reach 

Attainment of Annual Standard in 2013-2015

Site 2013

Measured Actuals

2014

Estimated

2015

Max Allowable for Attainment

Stockton-Hazelton 17.7 14.4 12.9

Manteca 11.6 10.1 23.3

Modesto 14.3 12.6 18.1

Turlock 15.0 14.4 15.6

Merced-M 13.5 11.1 20.4

Merced-Coffee 13.3 11.0 20.7

Madera-City 17.8 14.9 12.3

Clovis 15.9 14.6 14.5

Fresno-Garland 16.8 15.9 12.3

Fresno-Pacific 15.9 14.2 14.9

Tranquility 8.3 7.6 29.1

Corcoran 15.6 14.2 15.2

Hanford 18.2 17.1 9.7

Visalia-Church 18.9 17.1 9.0

Bakersfield-California 20.0 17.6 7.4

Bakersfield-Planz 22.8 18.9 3.3

Because both 2013 and 2014 were influenced by the severe weather of this last winter 

season, the 2015 averages would have to be improbably low in the southern portion of 

the District. The sites of Hanford, Visalia-Church, and Bakersfield-California would all 

have to have a 2015 annual average under 10 μg/m3, while Bakersfield-Planz would 

need to average 3.3 μg/m3for the entire year. The historical data noted above 

demonstrates that the Valley is not likely to achieve these annual averages for 2015. 

Based on this improbability, the Valley cannot reach attainment of the annual average 

portion of the 1997 PM2.5 standard during the 2013-2015 period, but will rather reach 

attainment at a later year beyond 2015. This demonstrates the long reaching 

ramifications that one season of unusually high values can have on a region’s ability to 

reach attainment.

This first extension to 2015 is important because it gives the Valley time to set a new 

attainment deadline by adopting a new PM2.5 plan by spring of 2015, before an EPA 

finding of failure to attain. Under Section 188(e) of subpart 4, the District is allowed an 

additional 5 years to reach attainment if necessary. This new plan would need to 

include a new attainment demonstration, with modeling and other supporting technical 

analysis. This new attainment plan would also have to show that all commitments in the 

previous implementation plan were met, and that the most stringent measures are in 

place. The District could adopt this new attainment plan in the spring of 2015, so EPA 

can approve the plan and the new attainment date (up to 2020, based on 2018-2020 

data) before the initial serious attainment deadline has passed.
SJVUAPCD Governing Board

ITEM NUMBER 9: REVIEW AND APPROVE ACTIONS TO ADDRESS AIR QUALITY IMPACTS 

RESULTING FROM THE EXCEPTIONAL WEATHER CONDITIONS CAUSED BY THE RECENT 

DROUGHT

August 21, 2014

10

The winter of 2013-2014 also adds difficulty to the planning process for the 2015 Plan 

for the 1997 PM2.5 Standard, which the District intends to present to your Board in 

spring of 2015. The annual average PM2.5 concentration for 2013 and 2014 will drive 

the need for additional control measures for this plan, and it will likely be extremely 

difficult to identify sufficient additional emissions reductions as a result. This current 

PM2.5 attainment difficulty is a stark contrast against EPA’s optimism in 2012 that most 

areas would have no problem meeting the more stringent new annual PM2.5 standard 

of 12.0 μg/m3 by 2020, and that attaining this lower standard by 2020 would cost the 

entire nation just $69 million1. 

FISCAL IMPACT:

The development of the new plan will result in extensive added workload. No staffing 

increase is recommended to accommodate this increased workload. 

Attachment: Congressional Drought-Related Exceptional Event Letter, June 10, 2014 ( 2 pages)

 

1

EPA’s Regulatory Impact Analysis for the Proposed Revisions to the NAAQS for Particulate Matter. June 2012. See 

page ES-13 and 7-12. http://www.epa.gov/ttn/ecas/regdata/RIAs/PMRIACombinedFile_Bookmarked.pdf 
San Joaquin Valley Unified Air Pollution Control District

Meeting of the Governing Board

August 21, 2014

REVIEW AND APPROVE ACTIONS TO ADDRESS AIR QUALITY IMPACTS 

RESULTING FROM THE EXCEPTIONAL WEATHER CONDITIONS CAUSED 

BY THE RECENT DROUGHT

Attachment:

Congressional Drought-Related Exceptional Event Letter, June 10, 2014 

(2 PAGES)