2008 PM2.5 Plan

Chapter 2 

 

Meeting Federal Requirements for Healthy Air 
2008 PM2.5 Plan

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San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Chapter 2: Meeting Federal Requirements for Healthy Air 

2008 PM2.5 Plan 

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Chapter 2: Meeting Federal Requirements 

for Healthy Air

2.1 INTRODUCTION 

Pursuant to the federal Clean Air Act (CAA), the U.S. Environmental Protection Agency 

(EPA) sets primary air quality standards to protect public health and secondary 

standards to protect welfare. Achieving the primary federal standards protects public 

health, reduces the region’s health care costs, and improves the quality of life for Valley 

residents. This chapter describes PM2.5 health effects, EPA’s process for setting 

health-based standards, and how regions like the San Joaquin Valley work towards 

attaining those standards. 

 

2.2 HEALTH EFFECTS 

Any particles 10 microns or less are considered respirable. The potential health 

impacts of particle pollution is linked to the size of the particles, with the smaller 

particles having larger impacts. PM10 (which includes PM2.5) can reach the alveoli, the 

gas exchange zone deep in the lungs. PM2.5 is of special concern to health because it 

is easily inhaled deep into the lungs, where it can be absorbed into the bloodstream or 

remain embedded for long periods of time without the ability to be exhaled (ALA 2002). 

PM can result in airway inflammation, and finer particles may carry toxic and biological 

materials, which can be absorbed by the blood in the gas exchange tissues of the lungs 

and carried to other parts of the body. 

Numerous studies link PM to a variety of health effects, including aggravated asthma, 

increased respiratory symptoms (irritation of the airways, coughing, difficulty breathing), 

decreased lung function in children, development of chronic bronchitis, irregular 

heartbeat, nonfatal heart attacks, increased respiratory and cardiovascular 

hospitalizations, lung cancer, and premature death in people with heart or lung disease. 

Children, older adults, and individuals with heart or lung diseases are the most likely to 

be affected by PM. As discussed in Chapter 1, PM2.5 occurs as a variety of chemical 

compounds, and there are several possible precursors. The species of PM2.5 can be a 

factor in the type and severity of health impacts. 

The health impacts carry economic costs as well. In The Health and Related Economic 

Benefits of Attaining Healthful Air in the San Joaquin Valley, researchers Jane V. Hall, 

Victor Brajer, and Frederick Lurmann report that the economic benefits of meeting the 

federal standards for both PM2.5 and ozone (as compared to 2004 air quality) could 

save an average of nearly $1,000 per person per year Valley-wide for a total of more 

than $3 billion annually (2005 dollars). They report that attaining both standards may 

result in fewer premature deaths, fewer asthma attacks, fewer cases of bronchitis, fewer 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

Chapter 2: Meeting Federal Requirements for Healthy Air 

2008 PM2.5 Plan 

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hospital admissions, fewer lost productive work days, and fewer school absences. 

These effects are attributed to attaining both the PM2.5 and ozone standards, although 

many of the potential health impacts in Hall’s study may be linked to diesel particulates 

(a component of PM2.5). The Hall report shows (in Table V-2) the total cost of health 

impacts from only PM2.5 to be approximately $3.2 billion annually, almost 100 times 

higher than the cost of ozone health effects (Hall 2006). Hall’s study is the first of its 

kind for the San Joaquin Valley. Future studies will improve our understanding of air 

pollution effects and costs and affirm the importance of programs that bring the Valley 

into attainment of federal air quality standards. 

Health Effects of PM2.5 

 Aggravated asthma 

 Increased respiratory symptoms – irritation of the airways, coughing, difficulty 

breathing 

 Decreased lung function in children 

 Development of chronic bronchitis 

 Irregular heartbeat 

 Nonfatal heart attacks 

 Increased respiratory and cardiovascular hospitalizations 

 Lung cancer 

 Premature death in people with heart or lung disease 

Source: EPA, Particulate Matter: Health and Environment, www.epa.gov/air/particlepollution/health.html

ARB and ALA, Recent Research: Health Effects of Particulate Matter and Ozone Air Pollution, 

January 2004, http://www.arb.ca.gov/research/health/fs/PM-03fs.pdf 

 

As the Valley’s PM2.5 air quality improves, the health impacts will diminish. To 

communicate the variability of air pollution levels and potential health impacts, air quality 

agencies provide air quality forecasts and report a daily Air Quality Index (AQI), as 

specified by EPA. AQI levels and their corresponding colors communicate specific 

health advisories. Many Valley media outlets include the District’s AQI with their 

weather forecasts. Also, many schools throughout the Valley participate in the Air 

Quality Flag program sponsored by asthma coalitions, the District, and other local 

organizations. Through this program, multi-colored flags are flown each day to indicate 

the forecasted air quality. As of the end of the 2006-2007 school year, 184 schools 

throughout the Valley participated in this program. Over 40 schools in the southern 

portion of the Valley participate in a similar program operated by the Kern County 

Asthma Coalition. 

When conditions warrant, the District also issues health advisories. This information 

and the daily AQI are available on the District’s website at 

www.valleyair.org/aqinfo/forecast.htm. The daily AQI, available for each of the 8 Valley 

counties, is also available in both English and Spanish on the District’s toll free number, 

1-800-SMOG-INFO. 
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Chapter 2: Meeting Federal Requirements for Healthy Air 

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Figure 2-1 AQI Values and Corresponding Air Quality, Colors, and Health 

Advisories 

Air Quality Index 

(AQI) Values

Air Quality Colors Health Advisory 

When the AQI 

is in this range:

...air quality 

conditions are:

...as symbolized 

by this color:

... the health advisory is: 

0 to 50 Good Green None. 

51 to 100 Moderate Yellow Unusually sensitive people should 

consider reducing prolonged or 

heavy exertion. 

101 to 150 Unhealthy for 

Sensitive 

Groups 

Orange People with heart or lung disease, 

older adults, and children should 

reduce prolonged or heavy 

exertion. 

151 to 200 Unhealthy Red People with heart or lung disease, 

older adults, and children should 

avoid prolonged or heavy exertion. 

Everyone else should reduce 

prolonged or heavy exertion. 

201 to 300 Very Unhealthy Purple People with heart or lung disease, 

older adults, and children should 

avoid all physical activity outdoors. 

Everyone else avoid prolonged or 

heavy exertion. 

2.2.1 Other Effects of PM2.5 

In addition to affecting health, air pollution also affects public welfare. PM can be 

transported long distances to create regional haze, with PM2.5 from sources hundreds 

of miles away contributing to visibility problems at remote locations, such as the Sierra 

Nevada Mountain Range or national parks. As PM settles out of the air, it can make 

lakes and streams acidic, change an ecosystem’s nutrient balance, and affect 

ecosystem diversity. PM can affect vegetation by damaging foliage, disrupting the 

chemical processes within plants, reducing light adsorption, and disrupting 

photosynthesis. This can impact green spaces as well as crops. PM can also stain and 

damage stone and other materials. As the Valley progresses towards attainment of 

EPA’s health-based standards, there will also be less impact to public welfare. 

 

2.3 HEALTH-BASED STANDARDS 

Since the federal PM10 standards were established in 1987, a large number of studies 

have been published on PM health effects, such as premature mortality, hospital 
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admissions, and respiratory illnesses. Based on health studies, PM2.5 is considered to 

be more adverse to human health than any other pollutant. Based on human health 

and environmental considerations, the State and the federal government each set 

ambient air quality standards for PM2.5. An air quality standard includes pollution 

concentration levels, guidelines for calculating the attainment tests for designation and 

classification, and other requirements. This section outlines the types of standards, the 

current levels of the standards, and how the standards are set. 

2.3.1 State Standards 

California standards are set to protect public health. The California ambient air quality 

standards are considerably more stringent than the federal standards and are more 

protective of human health. California has no specific dates by which state air quality 

standards must be attained. State implementation plans (SIPs), such as this PM2.5 

plan, focus on federal standards. California Health and Safety Code (CH&SC) Section 

39602 says, “Notwithstanding any other provision of this division, the state 

implementation plan shall only include those provisions necessary to meet the 

requirements of the [federal] Clean Air Act.” As such, SIPs are limited to those 

measures necessary to attain the federal standards. However, progress towards 

federal standards also brings areas closer to the lower, State standards. ARB set the 

first state standard for PM2.5 in 2002. The level of this standard is shown in Table 2-1. 

2.3.2 Federal Standards 

The EPA’s “primary standards” are set to protect public health with a margin of safety. 

Federal “secondary standards” are established to protect public welfare in issues such 

as crop damage, material degradation, haze, and environmental effects. The primary 

and secondary standards for PM2.5 are equivalent. 

When EPA reviews the national ambient air quality standards (NAAQS) for a pollutant 

such as PM2.5, it develops a "criteria document," a compilation and scientific 

assessment of health and environmental effects studies. EPA develops a staff paper on 

the information available that is compiled by technical staff who interpret the most 

relevant information in the criteria document to be used in making policy decisions. The 

staff paper also contains staff recommendations to the EPA Administrator regarding any 

revisions to the standards needed to protect public health and welfare. 

Both the criteria document and staff paper are based on thousands of peer-reviewed 

scientific studies and are part of an extensive scientific assessment process that 

includes rigorous scientific peer review and public comment. Before these documents 

become the basis for policy decisions, they undergo repeated, detailed reviews by the 

scientific community, industry, public interest groups, the general public, and the Clean 

Air Scientific Advisory Committee, a Congressionally mandated group of independent 

scientific and technical experts.1

 As part of its mandate, the Clean Air Scientific 

 

1 EPA’s December 7, 2006 changes to the NAAQS review process modified the role of CASAC in the standard-setting process.
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Advisory Committee also makes recommendations to EPA on the adequacy of the 

standards. By reaching the federal health-based standards for PM2.5, we will greatly 

reduce the negative health impacts of this pollutant. 

EPA adopted the first national air quality standards for the fine fraction of particulates, 

PM2.5, in July 1997 (62 FR 38651-38701). EPA set the annual PM2.5 standard at 15 

μg/m3

 and the 24-hour PM2.5 standard set at 65 μg/m3. EPA designated the Valley as 

nonattainment for PM2.5 based on ambient air quality data collected from 2001-2003. 

The Valley’s 2004-2006 air quality is within the 1997 24-hour standard, but not the 

annual standard. The District must show how the Valley will attain the 1997 PM2.5 

standards in the 2008 PM2.5 Plan. 

On October 17, 2006, EPA issued its final rule to revise the PM10 and PM2.5 NAAQS in 

the Federal Register (71 FR 61143-61233). This rule revoked the annual PM10 

standard and retained the existing 24-hour PM10 standard of 150 μg/m3

. EPA also 

retained the existing annual PM2.5 standard of 15 μg/m3

, but lowered the 24-hour 

PM2.5 standard to 35 μg/m3. EPA will designate areas under the new standard by 

November 2009, effective April 2010, and state implementation plans for the 2006 

standards will be due to EPA in the 2012-2013 timeframe. Areas must attain the 2006 

standards within five years of the effective date of EPA designations (which should be 

finalized effective 2009-2010), though up to a five year extension is possible. Although 

the plan focused on the 2006 PM2.5 standards is not due to EPA until 2012-2013, the 

control measures in the 2008 PM2.5 Plan will help bring the Valley closer to the 2006 

standard, and feasibility measures in the plan may result in control measures that might 

be used in future PM2.5 Plans. 

Both the 1997 and 2006 PM2.5 NAAQS are shown in Table 2-1. 

Table 2-1 Federal and State Ambient Air Quality Standards for PM2.5 

Standard Level of the Standard 

24-hour 65 μg/m3 Federal 

(1997) Annual 15 μg/m3

24-hour 35 μg/m3 Federal 

(2006) Annual 15 μg/m3

24-hour NA California 

Annual 12 μg/m3

 

2.4 DESIGNATIONS AND REQUIREMENTS 

On January 5, 2005 (70 FR 943-1019), EPA promulgated air quality designations for all 

areas for the national ambient air quality standards (NAAQS) for fine particles, signed 
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on December 14, 2004 and effective April 5, 2005. The San Joaquin Valley Air Basin is 

designated nonattainment for the 1997 PM2.5 NAAQS, and the PM2.5 State 

Implementation Plan (SIP) is due to EPA by April 5, 2008. 

Unlike the 8-hour ozone and PM10 standards, the PM2.5 NAAQS does not use a 

nonattainment area classification system (i.e., moderate, serious, severe, and extreme). 

While CAA Subpart 1, Section 172(a)(1) allows for a classification system, a 

classification system is not required. Not using a nonattainment classification system 

simplifies the attainment year as well as other planning requirements. The 1990 CAA 

Amendments do not include any subpart for PM2.5 because the PM2.5 standards were 

not yet established at that time. Therefore, the nonattainment area plan provisions in 

CAA Section 172 of subpart 1 apply. CAA 172(c) requires RACT, RACM, RFP, 

contingency measures, emission inventory, and NSR, and these requirements are 

discussed in further detail in the Clean Air Fine Particle Implementation Rule, Final Rule

(72 FR 20586-20667). Consistent with CAA Section 172(b), SIPs are due within 3 

years of area designations, so SIPs for the 1997 PM2.5 standards are due by April 5, 

2008 (72 FR 20599). Federal CAA requirements for PM2.5 plans are summarized in 

Table 2-2. 

All areas are to attain the standard as expeditiously as practicable, but by an initial 

attainment deadline of April 5, 2010 (based on 2007, 2008, and 2009 data, making 2009 

the compliance year). Areas demonstrating that attainment is impracticable by 2009 

can receive an extension of up to five years, making the final attainment deadline April 

5, 2015 (based on 2012, 2013, and 2014 data, with 2014 as the compliance year). To 

be granted an extension, areas must: 

 Submit an attainment demonstration showing that attainment by 2009 is 

impracticable due to the severity of the nonattainment problem, the lack of 

available control measures, and any other pertinent information. 

 Show that the area will attain the standard by an alternative date that is as 

expeditious as practicable. A full extension to 2015 is not automatic, and some 

areas may obtain shorter extensions. 

 Must demonstrate that all local control measures that are reasonably available 

and technically feasible for the area are currently being implemented. 

 Show that implementation of all RACM and RACT local control measures for the 

area were considered (72 FR 20601). 

Once the federal government sets a standard, states and air districts with nonattainment 

areas are required to adopt plans, rules, and programs that reduce emissions to bring 

the area into attainment of the standard. In California, air pollution control districts 

and/or air quality management districts are responsible for developing the overall 

attainment strategy in their respective geographic areas. Plans, such as the 2008 

PM2.5 Plan, are the first step in the local process. To develop a plan, areas evaluate 

air quality data, emissions inventory data, and computer modeling results to determine 

the rules and programs that are needed to reach the federal standards by the deadlines 

specified in the CAA. The rules and programs in a plan are then implemented over time 
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to reduce the emissions that go into the air, reducing unhealthful concentrations of air 

pollutants and helping areas reach federal air quality standards. 

The state reviews all of the air quality plans for the state’s nonattainment areas and, if 

they meet federal requirements, approves them and sends them on to EPA for approval 

into the California SIP. During the regional planning process, ARB develops and 

applies air quality models, conducts and funds air quality research, develops emissions 

inventories, develops emission control measures for statewide applicability, and 

provides other assistance to local air districts. 

Periodic plan revisions may be necessary to ensure reasonable further progress and to 

reflect the latest science. Once an area’s ambient air quality data meets the federal 

standard, the area will request a finding of attainment. Then a maintenance plan and 

other requirements must be met before an area can be officially redesignated to 

attainment. 

References 

American Lung Association (ALA) (2002). ALA Fact Sheet Particulate Matter Air Pollution. 

<www.lungusa.org/air/pm_factsheet99.html>. 

Hall, Jane V; Brajer, Victor; and Lurmann, Frederick W. (March 2006). “The Health and Related Economic 

Benefits of Attaining Healthful Air in the San Joaquin Valley.” Institute for Economic and Environmental 

Studies. 

 
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Chapter 2: Meeting Federal Requirements for Healthy Air 

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Table 2-2 Federal Requirements for PM2.5 Nonattainment Areas 

General 

Requirements 

Federal 

CAA 

PM2.5 

Implementation 

Rule 

Description 

2008 

PM2.5 

Plan 

Attainment 

Demonstration 

Due Date 172(b) 72 FR 20599 

PM2.5 SIPs are due to EPA by April 5, 

2008, which is three years from the 

designation date. 

NA 

Attainment 

Date 172(b)(2) 72 FR 20601 

Nonattainment areas should reach 

attainment as expeditiously as 

practicable, but no later than 5 years 

from the designation date, except that 

the Administrator may extend the 

attainment date for a period of no 

greater than 10 years from the 

designation date, considering the 

severity of nonattainment and the 

availability and feasibility of control 

measures. 

Chapter 9 

RACT/RACM 172(c)(1) 72 FR 20609-

20633 

SIP provisions should provide for the 

implementation of reasonably available 

control measures (RACM), including, at 

minimum, reasonably available control 

technologies (RACT). 

Chapter 6, 

Chapter 7 

RFP 172(c)(2) 72 FR 20633-

20642 

SIP provisions must provide for 

reasonable further progress. Chapter 8 

Contingency 

Provisions 172(c)(1) 72 FR 20642-

20645 

The SIP must provide for the 

implementation of specific measures 

that would take effect without further 

action by the State and that would be 

undertaken if the area fails to make 

RFP or attainment on time. 

Chapter 9 

Emissions 

Inventory 172(c)(3) 72 FR 20647-20651 

The SIP must include a 

comprehensive, accurate, current 

inventory of actual emissions from all 

sources of the relevant pollutants in the 

area. 

Appendix 

B 

NSR 172(c)(4-

5) 72 FR 

The SIP must identify and quantify the 

emissions of pollutants that will be 

allowed (in accordance with section 

173(a)(1)(B), from the construction and 

operation of major new or modified 

stationary sources in the area. The 

SIP must require permits for new or 

modified stationary sources. 

Appendix 

D 

Other 

measures 172(c)(6) 72 FR 20599 

The SIP must include enforceable 

emission limitations and other such 

control measures and techniques, 

including schedules for compliance to 

provide for attainment by the applicable 

attainment date. 

Chapter 6