PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION III – CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

-- REVISED --

PROPOSED 

2003 STATE AND FEDERAL STRATEGY FOR

THE CALIFORNIA STATE IMPLEMENTATION PLAN

SECTION III

CONSUMER PRODUCTS, VAPOR RECOVERY,

AND PESTICIDES

Release Date: August 25, 2003

Hearing Date: September 24-25, 2003
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION III – CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

TABLE OF CONTENTS

CHAPTER A. CONSUMER PRODUCTS ........................................................... III-A-1

CHAPTER B. FUELING AND VAPOR RECOVERY .......................................... III-B-1

CHAPTER C. PESTICIDES................................................................................ III-C-1
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION III – CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

Staff Contact List

Chapter Contact Email Phone

A: Consumer

Products Janette Brooks jbrooks@arb.ca.gov (916) 322-7072

B: Fueling and Vapor

Recovery Cindy Castronovo ccastron@arb.ca.gov (916) 322-8957

C: Pesticides Michael Benjamin mbenjami@arb.ca.gov (916) 323-2915
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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CONSUMER PRODUCTS

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CHAPTER A

Consumer Products
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CONSUMER PRODUCTS

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CHAPTER A. CONSUMER PRODUCTS

1. Category Description

As part of the 1988 California Clean Air Act, the California State Legislature gave

the Air Resources Board (ARB) the authority and responsibility to achieve the maximum

technologically and commercially feasible reactive organic gas (ROG) emission

reductions from consumer products.

A consumer product is defined as a chemically formulated product used by

household and institutional consumers. Consumer products include, but are not limited

to: detergents, cleaning compounds, polishes, floor finishes, cosmetics, personal care

products such as antiperspirants and hairsprays, home, lawn and garden products,

disinfectants, sanitizers, automotive specialty products, and aerosol paints. Other paint

products, such as furniture or architectural coatings, are not part of ARB’s consumer

products program because local air districts regulate them. Consumer products can

come in different product forms including aerosol, liquid, solid, or gel. California law

includes a provision that states that the ARB’s regulations cannot eliminate any product

form.

Consumer products are a significant source of ROG emissions in California and

contribute to the formation of both ozone and particulate matter pollution. Although

each consumer product may seem to be a small source of emissions, the cumulative

use of these products by nearly 35 million Californians results in significant emissions.

Consumer products accounted for approximately 267 tons per day (tpd) of ROG

emissions in the year 2000, which comprised about eight percent of the total man-made

ROG emissions statewide. ARB staff (staff) acknowledges that the ROG emissions

from consumer products are relatively less reactive when compared to some other ROG

emission sources. For example, on a pound for pound basis, the ROG emissions from

vehicle exhaust are estimated to lead to the formation of more than twice as much

ozone than the ROG emissions from consumer products. However, this does not mean

that consumer products should not be controlled. ROG emissions from consumer

products do lead to the formation of ozone and are a significant source of air pollution in

California. Further reductions in ROG emissions from consumer products and other

ROG sources are needed if ozone standards are to be achieved. 

As a result of several regulations adopted by the ARB over the last ten plus

years, emissions from consumer products and aerosol coatings have decreased, and

continued reductions are projected through 2005. Table III-A-1 lists the various

regulations adopted by the ARB with respect to consumer products. Each regulation

has been amended at least once since it was originally adopted. Table III-A-2 presents

current and projected emissions from consumer products reflecting the benefits of all

adopted regulations. Due to population growth and without additional controls, staff
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expects the trend of emissions reductions to reverse once the last of the already

adopted standards takes effect in 2005. With a projected 1.4 percent population

increase per year in California, consumer product emissions are expected to increase

by more than 3.5 tpd annually after 2005. 

Table III-A-1

California Consumer Products Regulations

Regulation Adoption Year

Antiperspirants and Deodorants 1989

Consumer Products 

Phase I Amendments

Phase II Amendments

Midterm Measures 

 Amendments I

Midterm Measures

 Amendments II

1990

1993

1996

1997

2000

Alternative Control Plan 1994

Aerosol Coatings 1995

Hairspray Credit Program 1997

Table III-A-2

Baseline Emissions for Consumer Products

(Statewide Emissions, Summer, tpd)

1990 2000 2005 2010 2015 2020

ROG 320 267 244 260 277 295

(South Coast Air Basin Emissions, Summer, tpd)

1990 2000 2005 2010 2015 2020

ROG 142 117 105 108 116 121

2. Existing Control Program

ARB has adopted five regulations affecting consumer products. The first

regulation reduced ROG emissions from antiperspirants and deodorants in 1989. This

was followed in 1990 by the first phase of regulations for 16 other consumer product

categories. The regulations have been amended several times including, Phase I in

1993, Phase II in 1996, Midterm Measures I in 1997, and Midterm Measures II in 2000,
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and contain a total of nearly 200 emission limits affecting 82 categories of consumer

products. In 1995, ARB adopted a separate regulation that included mass emission

limits for 35 categories of aerosol coatings. The aerosol coatings regulation was

recently amended to replace the mass limits with photochemical reactivity limits for

36 aerosol coating categories. Photochemical reactivity limits are designed to restrict

the amount of ozone likely to be formed from reactions of the reactive organic

compounds used in each aerosol coating product. On the other hand, mass emission

standards limit the quantity of ROG emissions from a given product. Both methods are

effective control strategies. As a result of these measures, emissions from regulated

categories have been reduced 50 percent, and in total, statewide consumer product

emissions will have been reduced by over 130 tpd ROG (37 percent reduction) in 2005,

compared to uncontrolled levels with growth. 

This 130 tpd reduction from consumer products comes despite the fact that a

significant portion of consumer product emissions is not easily available for reduction.

Categories of consumer products comprising approximately 100 tpd ROG have not yet

been regulated. Of these emissions, approximately 22 tpd are represented by very

small categories, each emitting less than 0.1 tpd, which makes setting cost-effective

limits difficult. Multi-purpose solvents comprise 20 tpd of the 100 tpd total. Consumers

purchase these products for the solvent effect; therefore, replacing a hydrocarbon

solvent with water or exempt solvents may not always be a viable option. Nevertheless,

we are currently conducting a survey for this category to determine if reductions in

either mass or reactivity are feasible. Further, the remaining 58 tpd are comprised of

other categories, such as rubbing alcohol, which are difficult to regulate due to health or

efficacy concerns. Another complicating factor is that emissions from all categories of

consumer products, both regulated and unregulated, are growing yearly because of

California’s burgeoning population. 

ARB has attempted to provide manufacturers with compliance flexibility in the

regulations by incorporating market-based components such as the Innovative Products

Exemption (IPE) provision (1990), Alternative Control Plan (ACP) (1994), and Hairspray

Credit Program (1997). The IPE allows manufacturers to market products with a higher

percentage of ROG than the regulation limit as long as they can demonstrate that, due

to some characteristic of the product formulation, design, delivery system or other

factor, the use of the product will result in less ROG emissions than a representative,

complying product. The ACP employs the concept of emissions averaging to provide

additional flexibility when formulating consumer products. The Hairspray Credit

Program allows manufacturers to generate emission reduction credits by introducing

low-ROG based hairspray prior to the effective date of a regulatory limit or by

formulating products with a ROG content lower than the regulatory limit. Manufacturers

could then use credits to defer compliance with other consumer products emission

limits, so long as emission reduction obligations are met in the aggregate. 
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3. Proposed Strategies

As part of the revised SIP for the South Coast, ARB would evaluate two

measures to reduce the emissions associated with consumer products. The strategies

ARB staff proposes to pursue are listed in Table III-A-3.

Table III-A-3

Proposed Strategies for Consumer Products

Strategies Timeframe

Action Implementation

CONS-1 Set New Consumer Products

Limits for 2006

2003 - 2004 2006

CONS-2 Set New Consumer Products

Limits for 2008 – 2010

2006 - 2008 2008 - 2010
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a. CONS-1: Set New Consumer Products Limits for 2006

Time Frame: Adopt 2003-2004; Implement 2006

Responsible Agency: ARB

Proposed Strategy:

Adopt new consumer product category limits in 2003-2004 and implement these

new limits in 2006.

To adopt new limits for addressing emissions growth from consumer products,

staff plans to target previously unregulated categories or regulated categories that staff

has not evaluated for further emissions reductions during the last five years. Additional

reductions may be achieved through both mass-based and reactivity-based limits.

Using survey data from the 2001 calendar year, staff will consider proposal of new

mass-based or reactivity-based limits in the 2003 to 2004 timeframe for implementation

in 2006.

In order to ensure ARB reaches a consumer product emission reduction goal of

at least five tpd ROG statewide by 2006 (about two tpd in the South Coast) to mitigate

the projected emissions increase due to growth, staff proposes to evaluate solvents and

many other regulated or unregulated categories. However, staff would pursue

additional reductions beyond the target if they prove to be technologically and

commercially feasible.

As part of this effort, staff is proposing to evaluate the various unregulated

solvent categories that may contain up to 100 percent ROG. These product categories

include multi-purpose removers, graffiti removers, electronic cleaners, adhesive

removers, and other packaged solvents. Within the solvent categories, we intend to

investigate the feasibility of using reactivity-based strategies to reduce the ozone

forming potential of the products. However, we also propose to evaluate mass-based

strategies, which may include reducing the ROG content of the products by

reformulating with water or exempt solvents, using low vapor pressure ROG, or by

replacing propellants with exempted hydrocarbons or compressed gases. Staff is

conducting a detailed survey to obtain 2001 sales and formulation data to better

understand the variety of products available, the basic functions of these products, and

potential reformulation alternatives.

ARB may also seek reductions from many of the smaller regulated or currently

unregulated categories of consumer products. For example, toilet/urinal care products,

several categories of personal care products, such as nail polishes, certain hair styling

aids, and other cleaning products that are not currently regulated will be evaluated to
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CONSUMER PRODUCTS

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determine if it is feasible to establish ROG limits. Some other categories we may

consider are special purpose adhesives, footwear care products, and other products

that were not included in the 1997 Consumer and Commercial Products Survey.

Potential Emission Reductions:

The potential emission reductions for this measure are 5 tpd ROG statewide by

2006, growing to 5.3 tpd ROG by 2010 and 6.1 tpd ROG by 2020. For the South Coast,

the potential emission reductions are 2.2 tpd ROG by 2006, growing to 2.3 tpd ROG by

2010 and 2.5 tpd ROG by 2020.

SIP Commitment for Measure CONS-1

South Coast 2003 SIP Commitment:

ARB staff proposes to commit to bring this measure to the Board between 2003

and 2004. The measure as proposed to the Board will, at a minimum, achieve 2.3 tpd

of ROG reductions in the South Coast Air Basin in 2010.

Commitments for Future SIPs:

As other areas of the State develop attainment SIPs that require additional

emission reductions to show progress and/or attainment, we will work with the

appropriate local air districts to determine which State and/or federal measures are

appropriate to include for federal approval.
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b. CONS-2: Set New Consumer Products Limits For 2008 – 2010 

Time Frame: Adopt 2006-2008; Implement 2008-2010

Responsible Agency: ARB

Proposed Strategy:

Adopt new consumer product category limits in 2006 and 2008. Implement these

new limits in 2008 and 2010.

To adopt new limits for consumer products in 2006, ARB staff will need to update

inventories detailing product ingredients and product sales. Staff plans to conduct a

survey in 2004 for the 2003 calendar year. Survey categories would include those with

limits effective by January 1, 2003, as well as previously unregulated categories. From

data collected in the 2003 calendar year survey, staff would consider adoption of new

mass-based or reactivity-based limits in 2006, for implementation in 2008.

To adopt new and/or lower limits for consumer products in 2008, staff will need to

further update inventories detailing product ingredients and product sales. We plan

another survey in 2006 for the 2005 calendar year. Categories would include products

with limits effective between 2003 and 2005 and all aerosol coatings. Based on the

survey results, ARB staff will evaluate both mass-based and reactivity-based control

options for adoption of new limits in 2008, with implementation by 2010.

There are several possible approaches that will be evaluated for reducing ROG

from consumer products in the 2006-2010 timeframe. One possible regulatory

approach would be to adopt mass-based limits based on reformulation. In addition,

mass or reactivity-based limits may be set for new categories and for small categories

that have grown significantly (in terms of product sales) over the last five to ten years.

Reactivity limits would be set for those categories where mass-based limits may not be

a feasible option. Some solvent categories, for example, are purchased by consumers

for their solvent effect. A reactivity-based limit in these categories would allow

manufacturers to reformulate using less reactive compounds that would maintain the

product’s efficacy and result in a reduction of the formation of ozone. The feasibility of

adopting a single limit for a product category could also be evaluated. For example, if

technologically and commercially feasible, all products within a category, irrespective of

product form, could meet the same limit whether the products were dispensed from a

pump spray, squeeze bottle, or aerosol can. Staff will also evaluate the technical and

commercial feasibility of adopting general emission limits to cover broad ranges of

consumer products to keep up with industry changes to product lines. Another

approach that could be evaluated is to limit the use of hydrocarbon propellants. Lower

limits may be set while still allowing the use of hydrocarbon propellants, such as in post-
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foaming products or by blending with exempt propellants. Specific exemptions

contained in the regulation may be re-evaluated to see if they are still warranted.

Potential Emission Reductions:

The potential emission reductions for this measure are 20 to 35 tpd ROG

statewide by 2010, growing to 23 to 40 tpd by 2020. For the South Coast, the potential

emissions reductions are 8.5 to 15 tpd ROG by 2010, growing to 9.7 to 17 tpd ROG by

2020.

SIP Commitment for Measure CONS-2

South Coast 2003 SIP Commitment:

ARB staff proposes to commit to bring measures to the Board between 2006 and

2008. The measures as proposed to the Board will, at a minimum, achieve between

8.5 tpd and 15 tpd of ROG reductions in the South Coast Air Basin in 2010.

Commitments for Future SIPs:

As other areas of the State develop attainment SIPs that require additional

emission reductions to show progress and/or attainment, we will work with the

appropriate local air districts to determine which State and/or federal measures are

appropriate to include for federal approval.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION III – CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY

III-B-1

CHAPTER B

Fueling and Vapor Recovery
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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CHAPTER B. FUELING AND VAPOR RECOVERY

1. Category Description

ARB and districts share responsibility for controlling emissions from the storage

and transfer of gasoline. ARB certifies prototype vapor recovery systems. District rules

and State law require that only ARB-certified systems be used for gasoline storage,

transfer, and refueling operations. Districts inspect and test the vapor recovery systems

upon installation during the permit process and conduct regular inspections to check

that systems are operating as certified. ARB provides districts with these inspection

procedures and test methods. 

ARB is also responsible for controlling air toxics that pose harm to public health.

For this reason, air toxics from gasoline storage and transfer also fall under the State’s

authority to control air toxic emissions.

The storage and transfer of gasoline for vehicle refueling is a significant source of

ROG emissions in California. Vapor recovery systems are used to capture vapors

during the transfer of gasoline between storage tanks and tanker trucks and during the

refueling of vehicles at gasoline pumps. Storage tanks can either be sited above

ground or underground.

Transfers of gasoline for pleasure craft refueling can be a significant source of

emissions, particularly during the summer months when the potential for ozone

formation is highest. Emissions can be released when the operator transfers the nozzle

from the vessel to the dispenser, tries to overfill or “top off” the vessel, or when the

vessel “spits back” fuel from overfill. 

When working properly, the emission reduction benefits of these systems are

significant. Unfortunately, in many cases, systems have not worked in the field to

control emissions at the certified level, and consequently, significant emission

reductions have been forgone. In recent years, ARB and the districts have taken many

steps to improve the performance and reliability of vapor recovery systems, including

ARB’s adoption of the Enhanced Vapor Recovery (EVR) program in 2000. ARB staff

believes there are additional opportunities to reduce emissions from gasoline storage,

transfer, and vehicle refueling.

Emissions from petroleum marketing have dropped significantly since 1980 as a

result of the installation of vapor recovery systems. In 2000, petroleum marketing

operations still accounted for about 40 tpd of ROG emissions in the South Coast, but

emissions are projected to drop as the enhanced vapor recovery program is

implemented. Table III-B-1 presents baseline emissions projected for fueling and vapor

recovery operations.
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Table III-B-1

Baseline Emissions for Fueling and Vapor Recovery Operations

(South Coast, Summer, tpd)

2000 2005 2010 2015 2020

ROG 42 22 22 23 23

2. Existing Control Program 

Vapor recovery systems have been used in California to control ROG for over

20 years. State law enacted in 1975 required ARB to “adopt procedures for determining

the compliance of any system designed for the control of gasoline vapor emissions

during gasoline marketing operations, including storage and transfer operations, with

performance standards, which are reasonable and necessary to achieve or maintain

any applicable ambient air quality standard.” Since then, ARB has adopted the

certification and test procedures to ensure vapor recovery systems meet minimum

standards.

Phase I Vapor Recovery

As each gasoline transfer will lead to displaced vapors, vapor recovery is used

throughout the gasoline marketing chain. Phase I vapor recovery is applied to gasoline

transfer operations involving cargo tank trucks. The first transfer occurs when the cargo

tank is filled with product at the loading rack of a refinery terminal or a bulk plant. While

the cargo tank is filled, gasoline vapor from the cargo tank is recovered and normally

condensed back to liquid fuel. The vapor recovery units at the terminal or bulk plant are

certified under ARB procedures. There is also an ARB certification procedure for cargo

tanker trucks. ARB assists districts by conducting certification tests at terminals and

bulk plants. Phase I vapor recovery also includes the transfer from the cargo tank to the

gasoline dispensing facility, or service station. Phase I vapor recovery is required

throughout California and in most other states.

Phase II Vapor Recovery

Phase II vapor recovery controls emissions resulting from gasoline transfer from

the gasoline dispensing facility to vehicles. This is the vapor recovery equipment that

many of us operate routinely when filling up our cars. The two main types of Phase II

vapor recovery systems are balance and assist. The balance systems can be identified

by the long bellows or boot on the nozzle. The end of the bellows must make a good

seal when the nozzle is dispensing fuel into the vehicle. This is important to ensure the

vapor pushed out while filling the vehicle tank is routed back through the nozzle to the
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

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underground vapor space. Assist system nozzles, in contrast, are often “bootless.” The

vapors are collected through a series of holes in the spout which vacuum up the vapors

during a refueling. This requires use of an active vapor pump. Some assist systems

also have processors to manage the underground vapor space pressure. Two currently

certified systems operate with vapor incinerators on or near the vent pipe in order to

reduce emissions.

Benzene Airborne Toxic Control Measure

In 1987, ARB adopted an airborne toxic control measure (ATCM) for benzene.

This measure requires use of Phase II vapor recovery at all gasoline dispensing

facilities in California, except those with very low throughput. Previous to

implementation of the ATCM, Phase II vapor recovery was required only if specified in a

district rule as an ROG control measure. Usually, those districts were in nonattainment

of the ambient ozone standard. Thus, the ATCM resulted in the expansion of Phase II

vapor recovery in all districts within California and reduced exposure to benzene while

fueling vehicles.

On-Board Refueling Vapor Recovery

In 1994, U.S. EPA set vehicle-based or onboard refueling vapor recovery

(ORVR) standards to control refueling emissions as required under the federal Clean Air

Act. In 1995, ARB adopted the federal ORVR regulations, with minor modifications, to

promote a consistent vehicle design for all 50 states and reduce the testing burden for

vehicle manufacturers. ORVR works by routing refueling vapors to a carbon canister on

the vehicle. The routing of the vapor to the canister requires a few hardware changes to

the vehicle. The fuel tank vent line must be rerouted from the vehicle fill-pipe to the

canister, and a seal must be established at the fill-pipe to ensure the vapor is not

emitted at the fill-pipe outlet. Vehicle manufacturers use different designs to meet these

requirements, but there are two basic types of fill-pipe seals. The most common is a

“liquid” seal, which is formed by the gasoline itself as it enters the fill-pipe, which has

been reduced in diameter to ensure a good seal. The other type is a “mechanical” seal,

which is similar to a gasket that seals closely to the nozzle. 

After U.S. EPA adopted the ORVR requirements, concerns were raised

regarding compatibility of Phase II vapor recovery and ORVR. The main concern was

that since vapor was not returned to the underground storage tank when fueling an

ORVR vehicle, air would be drawn into the underground vapor space as liquid was

dispensed. Gasoline evaporation would lead to vapor growth and possible excess

emissions.
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Enhanced Vapor Recovery

In 2000, ARB adopted enhanced vapor recovery (EVR) requirements to improve

equipment reliability and achieve additional emission reductions. New requirements

include more stringent standards and new equipment specifications for both Phase I

and Phase II vapor recovery systems. The new standards will reduce spillage and

gasoline evaporation from gasoline nozzles, make vapor recovery systems compatible

with the ORVR systems on motor vehicles, and require computerized monitoring

equipment for vapor recovery systems to self-diagnose and alert operators when repairs

are needed. These requirements are being phased-in over the next several years. In

addition to these regulatory changes, ARB is working with districts to improve inspection

and compliance test procedures to aid in the enforcement of vapor recovery regulations.

3. Proposed Strategies

ARB would evaluate a number of measures to reduce the evaporative emissions

associated with fuel storage, transport, and vehicle refueling. The strategies ARB staff

proposes to pursue are listed in Table III-B-2. ARB is also proposing a measure to

control evaporative emissions from cargo tanker trucks, as described in Chapter B of

Section II.

Table III-B-2

Proposed Strategies for Fueling and Vapor Recovery 

Strategies Timeframe

Action Implementation

FVR-1 Increase Recovery of Fuel Vapors

from Aboveground Storage Tanks 2003 2007

FVR-2 Recover Fuel Vapors from

Gasoline Dispensing at Marinas 2006 - 2009 2006 - 2010

FVR-3 Reduce Fuel Permeation Through

Gasoline Dispenser Hoses 2004 2007
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a. FVR-1: Increase Recovery of Fuel Vapors from Aboveground

Storage Tanks

Time Frame: Adopt 2003; Implement 2007

Responsible Agency: ARB

Table III-B-3

Baseline Emissions for Aboveground Storage Tanks1

(South Coast, Summer, tpd)

2000 2005 2010 2015 2020

ROG 0.1 0.1 0.1 0.2 0.2

Proposed Strategy:

Regulations controlling the transfer and marketing of fuel in California were

initiated in the 1970s in two phases. Phase I regulates gasoline transfer from cargo

tank to dispensing facility storage tank, and Phase II regulates gasoline transfer from

the dispensing facility to the motor vehicle.

EVR for facilities with underground storage tanks was approved by the Board in

March 2000 and is being implemented. The purpose of EVR is to seek additional

emission reductions by increasing the stringency of performance standards and

specifications and to improve the performance and reliability of vapor recovery

equipment. The approved EVR regulations do not apply to vapor recovery systems

used on aboveground storage tanks (ASTs). Therefore, the Board is developing a new

EVR rulemaking package specific to vapor recovery systems for this category. Vapor

recovery systems for aboveground tanks are currently certified by ARB with an allowed

90 percent control efficiency versus 95 percent proposed for EVR.

This regulation would address the increasing number of aboveground storage

tank dispensing systems used at private and public facilities and some retail sites.

There has been an increasing demand for ASTs for fleet operators in both the public

and private non-retail sectors, such as emergency response operations, public works,

school districts, marinas, car rental agencies, and car dealerships. This demand has

been due to increased compliance costs associated with underground storage tank

 1 The current inventory does not differentiate between UST and AST dispensing facility emissions. Therefore, the

baseline inventory is estimated. Data on AST emissions would be collected over the next year.
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operations. ARB staff is therefore proposing to apply as many of the current EVR

standards as feasible to ASTs, including an increase in overall system efficiency from

90 to 95 percent vapor recovery. If ARB’s data collection and testing determine that this

measure is technically feasible, staff would schedule this for ARB consideration as a

rule in 2003.

Potential Emission Reductions:

Assuming that one percent of the statewide gasoline throughput is dispensed via

ASTs and that these tanks are equipped with vapor recovery systems operating at

90 percent efficiency, then the current emissions are about 0.3 tpd statewide (about 0.1

tpd in the South Coast). Updated inventories will be used to refine emission estimates.

By reducing Phase I and Phase II transfer and vent emissions, this strategy would

reduce emissions by about 0.2 tpd statewide (0-0.1 tpd in the South Coast). However,

fugitive emissions for aboveground storage tanks are expected to be higher than for

underground storage tanks and amenable to control. Therefore, reductions could be

even greater. The proposed regulation increases the certification evaluation period,

which will more effectively ensure that vapor recovery systems operate properly.

SIP Commitment for Measure FVR-1

South Coast 2003 SIP Commitment:

ARB staff proposes to commit to bring this measure to the Board in 2003. The

measure as proposed to the Board will, at a minimum, achieve between 0 and 0.1 tpd of

ROG reductions in the South Coast Air Basin in 2010.

Commitments for Future SIPs:

As other areas of the State develop attainment SIPs that require additional

emission reductions to show progress and/or attainment, we will work with the

appropriate local air districts to determine which State and/or federal measures are

appropriate to include for federal approval.
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b. FVR-2: Recover Fuel Vapors from Gasoline Dispensing at Marinas

Time Frame: Adopt 2006-2009; Implement 2006-2010

Responsible Agency: ARB

Table III-B-4

Baseline Emissions for Marinas: Vapor Recovery2

(South Coast, Summer, tpd)

2000 2005 2010 2015 2020

ROG 0.1 0.1 0.1 0.1 0.1

Proposed Strategy:

Unlike vehicle fueling emissions controlled by vapor recovery systems, vapors

released during marina fueling are uncontrolled. As marina gasoline is dispensed

primarily during the summer months, these ROG emissions are contributing to smog

levels during the ozone season.

The South Coast District considered vapor recovery controls at marinas in the

1980s, but did not pursue the rule due to technical difficulties and cost. Existing

certified vapor recovery systems cannot be easily applied at marinas as the storage

tank is usually located uphill and quite a distance away from the gasoline dispenser.

Under this strategy, ARB staff proposes to determine if new technology may be

feasible and cost-effective in reducing ROG emissions from gasoline dispensing

operations at marinas. The State Water Resources Control Board (SWRCB) is also

considering new requirements for marinas and has already distributed a marina survey

that includes requests for information pertinent to estimating air emissions. Survey data

for 80 percent of the marinas statewide indicate that approximately 0.10 percent of the

total statewide throughput, or about 14 million gallons of gasoline annually, are

dispensed at marina fueling facilities. 

 

2 ARB’s current official inventory assumes that gasoline dispensed for off-road purposes is uncontrolled and represents two percent

of statewide throughput, but does not identify the emissions associated with marinas specifically. This table contains preliminary

estimates of emissions at marinas, assuming negligible growth in gas consumption at marinas in the next 20 years.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION III – CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY

III-B-9

Potential Emission Reductions:

The potential emission reductions associated with this proposal are expected to

be between 0.1 to 0.2 tpd statewide (0-0.1 tpd in the South Coast) based on the

following assumptions: 0.10 percent of the total statewide throughput is dispensed at

marinas. If 80 percent control of these emissions were achieved, the emission

reduction would be about 0.13 tpd.

SIP Commitment for Measure FVR-2

South Coast 2003 SIP Commitment:

ARB staff proposes to commit to bring this measure to the Board between 2006

and 2009. The measures as proposed to the Board will, at a minimum, achieve

between 0 and 0.1 tpd of ROG reductions in the South Coast Air Basin in 2010.

Commitments for Future SIPs:

As other areas of the State develop attainment SIPs that require additional

emission reductions to show progress and/or attainment, we will work with the

appropriate local air districts to determine which State and/or federal measures are

appropriate to include for federal approval.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION III – CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY

III-B-10

c. FVR-3: Reduce Fuel Permeation Through Gasoline Dispenser Hoses

Time Frame: Adopt 2004; Implement 2007

Responsible Agency: ARB

Table III-B-5

Baseline Emissions for Gasoline Dispenser Hose Permeation

(Statewide, Annual Average, tpd)

2000 2005 2010 2015 2020

ROG 3 NQ NQ NQ NQ

Note: Emissions have only been estimated for 2000. Future year emissions will

be estimated during measure development.

Proposed Strategy:

Emission controls for vapors generated from motor vehicle fueling were initiated

in the 1970s. ARB's EVR program, adopted in March 2000, constitutes a major

overhaul of the vapor recovery program with numerous new standards and

specifications aimed at increasing durability and reliability of vapor recovery equipment.

However, permeation emissions from dispenser hoses were not targeted in the EVR

program.

Gasoline dispensing hoses used at marinas have stricter standards for hose

permeability due to water quality concerns. The goal of FVR-3 is to determine the

applicability of applying the stricter permeability standard for marine gasoline hoses to

dispenser hoses at service stations. Specifically, this measure would review current

permeation requirements for gasoline dispenser hoses and, if feasible, establish lower

permeation requirements.

Potential Emission Reductions:

Emission reductions of up to 1.7 tpd ROG statewide (0-0.7 tpd ROG in the South

Coast) may be achievable if the lower permeation limit associated with marine hoses

can be applied to gasoline dispenser hoses at service stations. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION III – CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

FUELING AND VAPOR RECOVERY

III-B-11

SIP Commitment for Measure FVR-3

South Coast 2003 SIP Commitment:

ARB staff proposes to commit to bring this measure to the Board in 2004. The

measure as proposed to the Board will, at a minimum, achieve between 0 and 0.7 tpd of

ROG reductions in the South Coast Air Basin in 2010.

Commitments for Future SIPs:

As other areas of the State develop attainment SIPs that require additional

emission reductions to show progress and/or attainment, we will work with the

appropriate local air districts to determine which State and/or federal measures are

appropriate to include for federal approval.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION III – CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

PESTICIDES

III-C-1

CHAPTER C

Pesticides
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION III – CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

PESTICIDES

III-C-2

CHAPTER C. PESTICIDES

1. Category Description

Pesticides are industrial chemicals produced specifically for their toxicity to a

target pest. Any living organism that causes damage or economic loss or transmits or

produces disease may be a target pest. Pests can be animals (e.g., insects or mice),

unwanted plants (e.g., weeds), or microorganisms (e.g., plant diseases and viruses).

Many pesticide products contain volatile organic compounds (VOC), either as an

active ingredient or other ingredient. The chemical formulation and application method

for pesticides affect the amount of VOC emitted. In the South Coast, pesticides are

used primarily to treat structures, as well as agricultural products. Integrated pest

management practices, other voluntary actions, and regulatory action on methyl

bromide in response to health and environmental concerns have all contributed to a

significant reduction in reactive emissions from pesticides in the South Coast since

1990, as shown in Table III-C-1. Emissions from pesticides in other regions of

California may vary significantly from the trend shown below. 

Table III-C-1

Baseline Emissions for Pesticides

(South Coast, Annual Average, tpd)

1990 1995 2000 2005 2010 2015 2020

ROG 8.2 3.0 2.8 2.0 1.7 1.7 1.7

2. Existing Control Program

The Department of Pesticide Regulation (DPR) is the California agency

responsible for regulating pesticides for commercial/structural and agricultural uses.

DPR can establish regulations to reduce both toxic and criteria pollutant emissions from

pesticides using the best practicable control techniques available. Control measures

may be implemented by several methods, including regulatory actions, local permit

conditions, and product substitution or cancellation.

Pesticides are also regulated under federal law. Congress, under the Federal

Insecticide, Fungicide, and Rodenticide Act (FIFRA), gave the U.S. EPA authority to

provide federal control of pesticide distribution, sale, and use. All pesticides used in the

United States must be registered (licensed) by the U.S. EPA. Registration helps to

ensure that pesticides will be properly labeled and will not cause unreasonable harm to

the environment.
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION III – CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

PESTICIDES

III-C-3

Pesticides available for sale to household and institutional consumers have been

regulated under ARB’s consumer product authority since 1995. Currently, ARB has

adopted VOC limits for insecticide products targeted for crawling insects, flying insects,

fleas and ticks, and wasps and hornets. ARB also regulates other pesticide products,

such as non-selective herbicides and insect repellants. By 2005, when the final tier of

adopted VOC limits for consumer pesticides becomes effective, ARB will have obtained

VOC reductions of approximately 60 to 70 percent from the regulated household

pesticide categories.

As part of the 1994 SIP, DPR committed to reduce VOC emissions from

pesticides in certain federal ozone nonattainment areas of the State. The reductions

were to be gradually achieved through a shift in the application practices and types of

pesticides used. In the South Coast, VOC emissions from pesticide use have declined

dramatically; as a result, we propose to retain the existing SIP commitment. As part of

the SIP development process for other areas, ARB and DPR will work with each region

to identify any additional strategies that are needed based on the nature of the problems

in that particular region. 

3. Proposed Strategy

a. PEST-1: Implement Existing Pesticide Strategy

Time Frame: Implement 1996-2010

Responsible Agency: DPR 

Proposed Strategy:

DPR has broad authorities under State law to control the use of pesticides for the

purposes of protecting human health and the environment, including improving air

quality (Food & Agriculture Code §§14102, also §§12781, 12824-12828, 12976-12977,

12991-12995, 12996-12999, 13101 and 13102.)

As described in the 1994 SIP and U.S. EPA’s notice approving that plan, DPR

committed to reduce VOC emissions from pesticides through voluntary measures, with

a regulatory backstop. Specifically, DPR committed to adopt and submit to U.S. EPA by

June 15, 1997, any regulations necessary to reduce VOC emissions from agricultural

and commercial structural pesticides by specific percentages of the 1990 base year

emissions, by specific years, and in specific nonattainment areas. For the South Coast,

the commitment is to reduce VOC emissions from pesticides to a level 20 percent below

1990 base year emissions by the attainment year. 
PROPOSED 2003 STATE AND FEDERAL STRATEGY FOR CALIFORNIA SIP

SECTION III – CONSUMER PRODUCTS, VAPOR RECOVERY, AND PESTICIDES

PESTICIDES

III-C-4

Potential Emission Reductions for 2003 South Coast SIP:

Based on today’s estimate of 1990 South Coast Air Basin emissions at 8.2 tpd

VOC, the target level is 6.6 tpd VOC emissions remaining in 2010. Current emissions

are already below the target level and 2010 emissions are projected at 1.7 tpd. These

projections are reflected in the baseline inventory for the 2003 South Coast SIP.

4. Long-Term Advanced Technologies Strategies

ARB will seek to achieve additional ROG reductions from pesticides, beyond

those identified in the existing SIP commitment, for areas with a demonstrated regional

need for such benefits. As part of the development of the San Joaquin Valley Ozone

SIP, DPR is taking the lead in working with interested stakeholders to determine how

pesticide emissions can be further reduced by the attainment deadline.