# San 

# loaqu¡n Valley 

# t

HEALTHY 

# AIR LIVINGAIR PflLLUTI(lI{ CflI{TRflL DISTRICT



### September 

### 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 

## oSeptember 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, EPAGOVERNING 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: SJV UAP CD G overning B oard

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

RECOMMENDATION S :

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. D irect 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 S erious

nonattainment area for the 1997 PM2.5 standard.

3. Direct the Executive Director/APCO to develop a n ew State Implementation Plan for the 1997 PM2.5 standard under the

S erious 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 deadlin e 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 , s tagnation , strong inversions, andSJV

U APCD 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 th e 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 impa cts 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, t he D.C. Circuit Court recently ruled that EPA erred by using Clean Air Act subpart 1 instead of su bpart 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 μ g/m 3



### . 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. E ach individual annua l 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 μ g/m 3 

### , below t he standard of

15.0 μ g/m 3



### . 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, d ue to the exceptional weather conditions experienced durin g the winter of

2013

- 20 14, exceedingly high PM2.5 concentrations were experienced, causing a 2013 annual average of 22.8 μ g/m 3 

### for the Bakersfield

- Planz site.

As detailed further below, due to the extreme weather and high values already experienced at this site in the 1 st 

### quarter of 2014, the averages for the 2 nd 

### , 3 rd 

### , and 4 th


### quarters of 2014 would need to be zero for Bakersfield

- Planz to reach attainment for the

2012

- 20 14 period. The following discusses the magnitude of the weather conditions experie nced during the winter of 2013

- 14, and its impact on the Valley’s ability to attain

the 1997 annual PM2.5 standard.SJV

U APCD 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

- 20 14

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 t he 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 Ma rch 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/m 3 )



### Stockton Fresno BakersfieldSJV

U APCD 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 p ersistent, strong high pressure ridge over the eastern Pacific that effectively blocked weather

distur bances from entering California, which inhibited dispersion during November, December, and January of this last winter season.

Figure 2: Average Atmospheric Stability per Wint er 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 ha s 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

1999-2000 2000-2001 2001-2002 2002-2003 2003-2004 2004-2005 2005-2006 2006-2007 2007-2008 2008-2009 2009-2010 2010-2011 2011-2012 2012-2013 2013-2014 T850MB Stability Parameter ( ̊C)SJV

U APCD 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.

Furthermo re, 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/m 3 

### , the following analysis shows what average values would need to be recorded in the yea r 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 a verages 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 annua l 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

ha ve a design value of 15.0 μg/m 3 

### (which demonstrates attainment) for the three year attainment period of 2012

- 2014.SJV

U APCD 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

- 20 14

Site 2012

Measured Actuals 2013

Measured Actuals 2 014

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 4 th 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 t hree 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

- 20 14

Site 2012 2013 2014 2012

- 14

DV Q1 (actual) Q2 Q3 Q4 Avg

Bakersfield

- Planz 14.7 22.8 29.7 0 0 0 7.4 14.9



### Legislative Efforts Regarding Recent Exceptional Weather Conditions

T he 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 di rection, 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.SJV

U APCD Governing Board

ITEM NUMBER 9: REVIEW AND APPROVE ACTIONS TO ADDRESS AI R 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 th e 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 re quest

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 th e 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 convi nce 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 s tandards 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 agains t 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

deadl ine 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 2 015 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 deadlineSJV

U APCD 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. F or 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

R eclassification to Serious initially provides just one year more than the current

attainment deadline. With the extreme winter of 2013

- 20 14 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 1 st 

### 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 project ing

2 nd 

### , 3 rd 

### , and 4 th 

### quarter averages under more normal conditions. The maximum annual

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

- 20 15 period can then subsequently be calculated. These results are shown below in Tabl e 5.SJV

U APCD 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 Augu st 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/m 3 

### , while Bakersfield

- Planz would need to average 3.3 μg/m 3 

### for the entire year. The historical data noted above demonstrates that the Valley is not likely to achieve these annual averages for 2015.

Base d 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

ramificatio ns 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, bef ore an EPA finding of failure to attain. U nder 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 suppor ting 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 sprin g 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.SJV

U APCD Governing Board
ITEM NUMBER 9: REVIEW AND APPROVE ACTIONS TO ADDRESS AIR QUALITY IMPACTS

RES ULTING 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

dif ficult 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 standa rd of 12.0 μg/m3 by 2020, and that attaining this lower standard by 2020 would cost the entire nation just $69 million 1



### .

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.pdfSan 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)