2007 Ozone Plan 

Chapter 8 

 

Innovative Strategies and Programs 
2007 Ozone Plan 

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Chapter 8: Innovative Strategies and Programs

8.1 INTRODUCTION 

Recognizing that no “silver bullet” exists and that every sector, from the public through 

all levels of government, business and industry, must reduce emissions (guiding 

principle number 3), Chapter 8 presents District proposals for innovative strategies and 

programs that will involve wide-ranging public and private participation. The list of 

innovative programs include the following: Green Contracting, expanded Spare the Air 

efforts, Employer Based Trip Reduction, Heat Island Mitigation, Alternative Energy 

Production, Energy Conservation, Enhanced Indirect Source Review, Episodic and 

Regionally Focused Control Measures, and Advanced Emission Reduction Options 

(AERO). These programs are being introduced in the San Joaquin Valley for their 

relevance in the reduction of ozone precursors, but many will generate secondary 

benefits including lower energy costs, energy independence, and less greenhouse gas 

emissions. The District’s implementation of innovative strategies and programs will lead 

to greater public awareness of air quality problems and increased public participation 

towards air pollution solutions. 

8.2 PROGRAM DESCRIPTIONS 

8.2.1 Green Contracting 

Green Contracting is a practice that may be used by public agencies, to encourage 

contractors to use low-emission vehicles, off-road equipment, and heavy-duty on-road 

fleets, and to actively promote ridesharing programs. Public agencies may encourage 

participation in these efforts by awarding extra points to contract bidders that 

incorporate the use of clean fleets of vehicles and equipment into their proposals. 

Additional points can be gained for ride sharing programs. Contracts awarded to 

companies with “green” practices could also contain clauses that require participation in 

Spare the Air activities. 

With the growing concern for global climate change, Green Contracting programs are 

gaining ground in cities and counties across the U.S.. Air districts do not have 

regulatory authority to require local government agencies to adopt these ordinances, but 

many have done so voluntarily. The District intends to initiate extensive Green 

Contracting as a practice in the San Joaquin Valley by taking the following steps: 

! Developing a model ordinance/policy and promoting its adoption by cities and 

counties. 

! Making Green Contracting an attractive option for contractors by awarding 

incentive funding for the retrofit of off road construction equipment, vehicle fleets, 

and other equipment. 
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! Issuing “Green Contractor Certification” to companies that fulfill certain criteria, 

such as meeting advanced fleet standards. 

! Exploring the possibility of increasing the District’s mandate for requiring Green 

Contracting practices in public projects, through legislative changes to public law. 

8.2.2 Expanded Spare-The-Air Efforts 

Spare the Air (STA) is the voluntary summertime effort aimed at reducing ozone 

precursor emissions. The program works by notifying Valley residents in advance of 

days when air quality is forecast to reach unhealthy levels. These are designated Spare 

the Air days. The District notifies the public via television, radio, newspaper, and at 

participating worksites. Daily air quality information is also available by dialing (800) 

SMOG-INFO (766-4463). When a STA day has been called, residents are asked to 

reduce or avoid activities that cause air pollution for 24 hours. Based on previous 

years, there are about 25 STA days per year. 

The District has partnered with approximately 750 public and private entities that 

receive advance notice of days when air quality is forecast to be unhealthy. With this 

knowledge, employees can take additional steps that will help in reducing emissions 

that lead to poor air quality. These can be in the form of carpooling, trip-linking, using 

alternative transportation, taking lunch at work, trip sharing among employees who run 

errands during lunchtime, and various other ways that decrease trips and vehicle miles 

driven. The District’s Public Information Department coordinates these valley-wide 

efforts and awards prizes and recognition to outstanding Spare the Air corporate and 

government partners. District employees enthusiastically participate in the STA 

program and the District’s in-house STA program provides an excellent model for other 

public and private entities to follow. 

The District believes that participation in STA activities can be increased with the 

following improvements: 

• Recruit more STA partners by assisting public and private agencies to organize 

and implement STA activities. 

• Promote voluntary curtailment of activities that produce NOx and VOC. 

• Explore ways to incentivize the voluntary participation of stationary sources in 

curtailing activities. 

• Design expanded STA projects to satisfy EPA criteria for SIP creditability.

8.2.3 Employer Based Trip Reduction 

Existing trip reduction programs, such as vanpools and employer based transportation 

trip reduction programs, exist but are limited in scope and have not resulted in 

significant reductions in vehicle miles traveled (VMT). These programs are currently 

implemented on a voluntary basis. Health and Safety Code Section 40601(d) 
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authorizes the District to adopt rules and regulations that require certain businesses 

employing at least 100 people to establish rideshare programs. 

A good model for an Employer-Based Trip Reduction program is the District’s in-house 

alternative transportation program. The District program incentivizes employees to use 

alternative transportation on 60% of work days, and gets 20% participation. This level 

of participation is two-thirds higher than the general working population’s use of 

alternative transportation (US Census 2000). Similar programs in other areas 

consistently show that incentivizing the use of alternative modes of transportation is an 

effective way of getting workers to forego the use of single occupancy vehicles. 

The District is proposing to adopt an Employer Based Trip Reduction rule will further 

decrease Valley VMT: 

• Adopt a rule requiring businesses with at least 100 employees, as defined in 

CH&SC 40601, to establish rideshare programs. 

• Schedule rule development and implementation as follows: adoption by the 4th

quarter 2009, compliance starts by 2010, and reductions begin by 2010. 

• Implement trip reduction programs following EPA guidelines for SIP reductions.

• Explore the applicability of state laws governing parking payout programs in 

California, and work to strengthen that law and its enforcement in the San 

Joaquin Valley. 

The following table (8-1) shows conservative emission reduction estimates, based on an 

approximate 16% increase in the use of alternative modes of transportation. 

Table 8-1 Projected Reductions for Employer-based 

Trip Reduction Program, 

tons per day 

 2008 2011 2012 2014 2017 2020 2023 

NOx 0.0 0.23 0.24 0.25 0.26 0.27 0.28 

VOC 0.0 0.61 0.62 0.64 0.65 0.66 0.68 

8.2.4 Heat Island Mitigation 

“Heat Islands” in urban areas are characterized by higher air and surface temperatures, 

which can be 10oF higher than rural areas. Higher temperatures increase ozone 

formation and lead to greater use of air conditioning units, fans, and evaporative 

coolers, which cause power companies to bring online extra generating stations or socalled peaker units. The addition of peaker units brings a corresponding increase in 

ozone precursor emissions. 

There is a growing body of scientific findings that shows substantial benefits from 

mitigating heat island effects. The Lawrence Berkeley National Laboratory (LBNL) Heat 

Islands Project found that lightly colored, high-reflectivity roofs in Sacramento used up 
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to 40% less energy for cooling than those with darker roofs. Computer models of Los 

Angeles show cooling benefits of planting more trees, combined with high-reflectivity 

surfaces, amounted to a savings of $100 million per year from producing less peak 

period electricity. The US Department of Agriculture Forest Service estimates that 

midday temperature reductions range from 1 to 5.5 oF for every 15% increase in the 

canopy cover. 

To overcome barriers that prevent the widespread adoption of heat island mitigation, the 

US EPA has teamed up with the Department of Energy, NASA, and LBNL to undertake 

the following: 

• Conduct detailed analyses to quantify the potential air quality benefits from 

strategically placed vegetation and reflective surfaces, 

• Develop "lessons learned" that will serve as guidelines for other cities interested 

in initiating similar types of programs and policies, 

• Identify the most effective means to implement measures aimed at reducing the 

urban heat island, and 

• Conduct outreach and educational activities to encourage other cities to 

implement measures intended to reverse the urban heat island effect. 

 

For its part, the District is proposing to develop a program that will advance the 

implementation of heat island mitigation measures in its jurisdiction, including the 

following actions: 

• Develop a model ordinance for heat island mitigation and promote its adoption by 

cities and counties, including providing incentive funding to seed projects. 

• Encourage practices conducive to heat island mitigations through informational 

campaigns and incentives. 

• Possibly include elements of heat island mitigation as a compliance option for 

facilities. 

• Support research that adds certainty to the emission reduction potential or 

benefits of heat island mitigation programs. 

8.2.5 Alternative Energy 

Alternative sources of energy could reduce or slow the growth of NOx emissions from 

utility power generation. The viability of any energy alternative would depend on how it 

compares in cost to utility-generated power. 

There are many possible sources of alternative energy in the San Joaquin Valley. The 

following is a listing of some of these “alternative fuel” sources, each of which of which 

is also a source of VOC emissions: 

• Landfill gas that is flared without energy recovery; 

• VOC and methane from confined animal facilities; 
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• Agricultural waste products, such as prunings, rice stalks, and orchard removal 

materials; 

• Biosolids generated in the Valley or in other regions; and 

• VOCs from oil and gas production plants and other industrial facilities that are 

incinerated using flares or thermal oxidizers. 

Projects that can transform these “waste streams” into alternative-energy fuel stocks 

can be any of the following: 

• Small-scale alternative energy projects that utilize locally available biomass that 

can be converted to methane gas, which can be used to fuel internal combustion 

(IC) engines or mini-turbines that drive electricity generators or which can serve 

as the hydrogen source for fuel cell power generation. 

• Biomass and Biosolids gasification produces flammable gas that can be used in 

combined-cycle power generation, which combine gas turbines and steam 

turbines to produce energy up to as much as 60% efficiency. 

• Still in the development stage is the use of biomass in biorefineries. Biomass 

can be transformed to component sugars that can be converted to fuels or other 

products, and biomass can also be converted to synthesis gas (hydrogen and 

carbon monoxide), which can be used for fuel or converted to other products. 

Advances in gas-to-liquid technologies using the cobalt-based Fischer-Tropsch 

(FT) process has led to the production of synthetic paraffin fuel (SPF), which is a 

promising hydrogen source for fuel cell power generation. This fuel type is being 

investigated for its potential in mobile applications of fuel cells. 

As part of its innovative strategies, the District proposes the following: 

• Promote alternative sources of energy that have demonstrable merits in terms of 

reducing ozone precursors. 

• Design and implement alternative energy programs with SIP creditability as an 

emerging control measure, following EPA guidelines. 

• Align District programs with initiatives that reduce greenhouse gas emissions. 

8.2.6 Energy Conservation 

By reducing energy consumption, which can be undertaken by virtually everyone in the 

San Joaquin Valley, the combustion of fuels to produce electricity or drive vehicles is 

lessened. Using less energy reduces emissions of NOx and VOC. It also means 

spending less for energy. A few examples of ongoing conservation programs that have 

direct relevance to air quality are the following: 

• Utility companies have energy conservation programs, including rebates for 

using energy efficient appliances and weatherization of homes and a tiered 

system of pricing, which encourage homeowners to stay below a certain level of 

energy use; 

• EPA’s Energy Star Program provides homeowners and businesses with tools 

and resources for undertaking projects that reduce energy bills and improve 
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comfort. The Energy Star label is awarded to products and facilities that have a 

demonstrated level of energy efficiency; 

• California State University, Fresno’s Center for Irrigation Technology conducts 

the Agricultural Pumping Efficiency Program, with funding from Pacific Gas and 

Electric Company through 2008; 

• Green building practices that are geared toward energy conservation, such as: 

site selection, building orientation, improved insulation, integrated structural 

insulation, and use of renewable energy options (solar space heating and 

cooling, solar water heating, purchase of green power, etc.); and 

• Reducing the use of agricultural equipment by employing global positioning 

systems (GPS) in field operations, and other conservation management practices 

that simultaneously reduce PM and ozone precursors while conserving energy. 

Recognizing that energy consumption will play an increasingly significant part in the 

Valley’s future growth, the District proposes to undertake an energy conservation 

program with the following recommendations: 

• Promote energy conservation through program mechanisms, such as identifying 

the availability of rebates and other incentives to green-certified homes and 

buildings; 

• Provide incentive funding for irrigation pumping efficiency programs and other 

farming technologies/practices that have a demonstrable air quality benefit (See 

Chapter 7); and 

• Design and implement energy conservation programs with SIP creditability as an 

emerging control measure, following EPA guidelines. 

• Promote city/county ordinances for installation of solar water heaters and/or solar 

voltaic cells. 

8.2.7 Enhanced Indirect Source Review 

“Indirect source” is the term used to refer to any facility, building, structure or 

installation, or combination thereof which generates or attracts mobile source activity 

that results in the emissions of any pollutant for which there is a state ambient air quality 

standard. The San Joaquin Valley Air Pollution Control District adopted the nation’s first 

indirect source review (ISR) rule, Rule 9510, on December 15, 2005. The District’s ISR 

rule, is designed to mitigate emissions associated with development projects that 

exceed two tons per year of NOx and PM10. Specifically, for the construction phase of 

a development project, Rule 9510 requires a 20% NOx reduction from the statewide 

average resulting from the use of construction equipment that is greater than 50 

horsepower. For the operational emissions, defined as the combination of the area and 

mobile emissions associated with the project, Rule 9510 requires 33% NOx reduction 

from the baseline, as computed using an APCO-approved model (e.g., URBEMIS). 

Onsite emission reduction measures or offsite mitigation fees can meet both sources of 

NOx reductions. 

At this point, the District is exploring all possibilities of gaining additional emission 

reductions from sources under its jurisdiction. Legal limitations in state law are also 
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being examined. The District invites comments and suggestions to further improve 

control options, within legal limitations set by state law. A future feasibility study to reevaluate this source category is planned. 

8.2.8 Episodic and Regionally-focused Control Measures 

Many nonattainment areas in the country have episodic control programs, most of which 

are voluntary. The Valley’s Spare the Air Program is one example. Advances in realtime air quality measurement and meteorological forecasting, however, have made it 

possible to apply regulatory controls in a more focused manner. Examples of this 

concept are the District’s Smoke Management Program and the “Don’t Light Tonight” 

program that implements Rule 4901 (Wood Burning Fireplaces and Wood Burning 

Heaters). Both programs use real-time meteorological measurements and emissions 

estimates to determine if next-day conditions are conducive to violations of ambient air 

quality standards. The District’s forecasters prepare and issue forecasts that can result 

in episodic and geographic prohibitions on prescribed burning, agricultural burning, and 

residential fireplace burning. 

Banking on the success of these programs, the District believes that episodic and 

regionally focused controls could be used in “surgically” controlling emissions during the 

worst days of the ozone season. The District will consider episodic controls and 

regionally-focused controls during each rule development project in order to optimize 

the benefits of each measure. Some of the source categories that may also be 

evaluated for possible episodic/regional controls are: 

• Recreational vehicles, including dirt bikes and power boats; 

• Non-essential structural painting and other activities; 

• Non-essential through-truck traffic in urban areas; 

• Industrial activities amenable to postponement; 

• Diversion of heavy duty diesel truck traffic to Interstate 5; and 

• Non-essential use of lawn care equipment. 

8.2.9 Advanced Emission Reduction Options (AERO) 

Since the formation of the San Joaquin Valley Air Pollution Control District, the District 

has imposed Reasonably Available Control Technology (RACT) and at least one 

generation of Best Available Retrofit Control Technology (BARCT) on virtually all of the 

stationary sources in the San Joaquin Valley Air Basin. As the District has continued to 

implement its clean air strategy, some industries have recently implemented fourth and 

fifth generations of BARCT. In developing the Draft 2007 Ozone Plan, District staff 

have investigated every known source of emission reductions, and proposed a long list 

of measures to pursue, including regulations to address mobile sources and another 

generation of regulatory controls on stationary sources. Additionally, the Air Resources 
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Board (ARB) has published a list of planned control measures addressing source 

categories under their jurisdiction. 

In spite of the long list of historical and proposed measures, there remains a significant 

need for additional reductions. Attaining the eight-hour ozone standard requires 

emission reductions of approximately 75% from 2005 levels. Because of this need, the 

District will seek to reduce emissions from source categories and industries that have 

been previously controlled, and for which emission reductions are relatively expensive. 

To obtain additional emission reductions in the most cost effective manner possible, 

especially for facilities that have been heavily regulated, the District is proposing to 

develop rules that offer options for providing emission reductions. The District is 

considering the development of a set of regulatory compliance options under the 

general program title “AERO – Advanced Emission Reduction Options.” 

AERO Overview

A. Why do we need to consider AERO? 

In brief, the next generations of stationary source emission control regulations are 

expected to be very expensive, and are expected to provide relatively small reductions. 

Additionally, future controls are expected to interfere more with operations than previous 

“end-of-the-stack” pollution controls, possibly requiring replacement of process 

equipment rather than retrofits. As always, resources to finance emission controls on 

stationary source equipment are limited. Finally, the District has limited authority to 

reduce emissions from the Valley’s largest source category, mobile sources. 

B. How would AERO help? 

AERO would (1) help to lower the cost of emission reductions, (2) achieve more 

reductions for a given investment, and (3) provide a mechanism for stationary source 

operators to help achieve much needed mobile source emission reductions. AERO 

would also assure that alternative reductions are recognized in the State 

Implementation Plan (SIP). 

C. What would AERO do? 

As currently envisioned, AERO would set emission reduction goals for stationary 

sources based on advanced technologies, and it would specify several options that 

operators could use to comply. The specified emission reduction options would include 

control of the subject equipment, mitigation fees, specified offsite reductions, and 

alternative onsite approaches. All of these options would be well in excess of previously 

established RACT and BARCT levels. Each option will have adequate provisions to 

ensure reductions are surplus, enforceable, quantifiable, and permanent. 
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D. How would AERO be implemented? 

Some of the District’s new prohibitory rules and rule amendments would include AERO 

provisions. These rules would focus on achieving percentage reductions rather than 

specific emission concentrations. Options would include: 

• Installing and operating advanced technologies (e.g. a control device achieving a 

specific capture and destruction efficiency) 

• Paying a fee into a “Clean Air Investment Fund” that the District will use to 

achieve the target reductions in emissions. The target reductions would help to 

meet SIP commitments but not necessarily be "equivalent" to reductions from 

any specific technology 

• Other specific offsite or onsite alternatives identified in the rule (e.g., replacing 

forklifts at the operators facility or at another facility) 

Rather than specify in the Draft 2007 Ozone Plan which rules/categories would have 

AERO provisions, the District proposes to consider AERO provisions for each stationary 

source control measure during the rulemaking process. District staff will work with 

interested stakeholders during each rulemaking project to identify the AERO eligibility of 

the source category/industry and the specifics of the appropriate alternative controls. 

E. AERO Guiding Principles 

1. For projects with high-cost reductions, allow operators multiple compliance 

options to facilitate more cost effective and feasible ways to provide emission 

reductions. 

2. The “add-on” control techniques proposed to achieve emission reductions at 

the stationary source should be technically feasible and not cost prohibitive 

for the subject stationary source equipment. 

3. AERO should provide more reductions than normal compliance. 

4. AERO reductions should be equivalent to reductions from normal compliance 

methods in terms of creditability (i.e., the reductions will be surplus, 

enforceable, quantifiable, permanent), environmental justice, and 

environmental impacts. AERO would employ the guidance developed for the 

Moyer Program and similar programs to assure that emission reductions are 

creditable. 

5. AERO program documents will show all analysis, input data, sources, and 

assumptions. 

6. The AERO program will include a backstop mechanism. As part of the AERO 

program, the District will adopt a backstop regulation that will engage if the 

alternative reductions do not continue. The backstop regulation would assure 

that the AERO program as a whole achieves emission reductions equivalent 

to traditional command and control regulations. 

7. Reductions necessary to comply with federal RACT requirements are not 

eligible for AERO. 
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District Authority to Impose Mitigation Fees

Note that this preliminary analysis narrowly considers the District’s authority to levy 

emissions fees to raise funds for incentive programs. This analysis does not consider 

whether State Implementation Plan (SIP) credit could be approved for the reductions 

generated by the incentive program using the funds identified here. The question of SIP 

approval for the incentive programs is being addressed through a separate dialogue 

and process, and this analysis does not seek to address or resolve those issues. Also 

note that this analysis is preliminary and is not meant to be conclusive or exhaustive. 

The key question is, does the District have authority to levy emission fees on a source 

even if the source is meeting all requirements of federal prohibitory rules? California 

law provides broad authority to the air districts to levy fees on sources (including indirect 

and area sources) in order to fund district programs that are “related to” the regulation of 

the sources paying the fees. The outer limit of this authority is the California 

Constitution’s prohibition against collecting a “special tax” without a two-thirds vote of 

the electorate. Thus, the cases on this topic have tried to distinguish between 

permissible regulatory fees and unlawful special taxes. 

We believe the District may legally levy such emission fees, provided it carefully tailor its 

fee program to demonstrate that: (1) fees collected from a particular source category 

are used to reduce pollution of the same type emitted; (2) that the fees paid by any 

particular source were related to the contribution of that source to the air pollution 

problem; and (3) that the fees paid by sources under the program were earmarked and 

used only to generate the designated reductions (and were not placed in a general 

revenue pool). However, such a broad emission fee program does not appear to have 

yet been attempted by any California district, and its legality would require breaking new 

ground in interpreting the applicable fee statutes. 

Although case law makes clear that the determination of whether a regulatory fee is 

also an unlawful special tax is an inexact science and that the determination is made on 

a case-by-case basis, the cases do provide a guide to how the courts might treat a 

District rule that imposed a emissions-based fee on sources to fund District incentive 

programs. 

First, it is clear that the broader the use to which the funds are put, the more 

likely that a court would view the fee as a tax. It would be important that the 

District used the levied fees to mitigate pollution that is fully fungible with the 

pollution created by the source targeted by the rule so that the fees could be 

viewed as offsetting the burden that those sources are creating through their 

activities. In this regard, a District fee program may want to segregate funds 

raised through source-specific fees to be used in only those parts of the incentive 

program that produce reductions in the appropriate pollutants. 
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Second, the District would carefully document that the fees are reasonably 

related to the burden created by the source. Apportioning the fees by each 

source’s level of emissions would seem to ensure that this relationship exists, 

and the court has already found that such an apportionment scheme is lawful. 

Finally, the District must also ensure that a tracking system is in place to 

demonstrate the reasonable costs of the incentive programs using any fees 

levied. The accounting system should not only demonstrate that the costs of the 

incentive program projects undertaken are reasonable, but should also show that 

the fees paid by the source were earmarked for those projects. 

Although it appears that no emissions fee similar to the one explored here has been 

imposed by any district in the past, it does not appear that there is any explicit obstacle 

in statutes or case law to the District attempting to do so. As long as the District’s 

program met the requirements noted above, it appears the key issue would be whether 

the incentive programs funded by the fees are sufficiently “related to” the sources’ 

permits to fall within the statutory authority of the district to impose fees. That precise 

question does not appear to have been addressed yet by the courts and would likely 

involve setting new legal precedent if it was challenged by industry. 

Categories Being Considered for AERO

As discussed above and as referenced in the Candidate Control Measures in Appendix 

I, source categories that were previously regulated and for which further controls are 

very expensive are candidates for AERO. During the rulemaking process for each 

control measure, there will be an opportunity to consider whether a category is 

appropriate for AERO. The District is seeking public comment on the scope and 

concepts for AERO. 
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