State of California

AIR RESOURCES BOARD



### Final Draft

STAFF REPORT

ANALYSIS OF THE
SAN JOAQUIN VALLEY 2007 OZONE PLAN

Date of Release: 5/30/2007

Scheduled for Consideration: 6/14/2007

This report has been reviewed by the staff of the C alifornia Air Resources Board and approved for publication. Approval does not si gnify that the contents necessarily reflect the views and policies of the A ir Resources Board, nor does mention of trade names or commercial products const itute endorsement or

recommendation for use.

### (This page intentionally left blank.)PRINCIPAL AUTHOR

Jeff Lindberg, Planning Liaison to the San Joaquin Valley Unified Air Pollution

Control District Phone: (916) 322-2832 Email: jlindber@arb.ca.gov

PROJECT MANAGER

Ravi Ramalingam, P.E., Manager, Transportation Stra tegies Section

CONTRIBUTORS

Air Quality and Transportation Planning Kurt Karperos, P.E., Chief, Air Quality and Transpo rtation Planning Branch Jon Taylor, P.E., Manager, Motor Vehicle Assessment Section Kyriacos Kyriacou, Ph.D., Air Resources Engineer John Nguyen, Air Pollution Specialist Jamesine Rogers, Air Pollution Specialist Tom Scheffelin, P.E., Air Resources Engineer Earl Withycombe, P.E., Air Resources Engineer

Air Quality Data Karen Magliano, Chief, Air Quality Data Branch Mena Shah, Manager, Air Quality and Statistical Ana lysis Section Gayle Sweigert, Manager, Air Quality Analysis Secti on Steve Gouze, Air Pollution Specialist Larry Larsen, Ph.D., Staff Air Pollution Specialist

Air Quality Health Impacts Barbara Weller, Ph.D., Manager, Population Studies Section Hien Tran, Staff Air Pollution Specialist

Air Quality Modeling John DaMassa, Chief, Modeling and Meteorology Branc h Vernon Hughes, Manager, Atmospheric Modeling and Su pport Section Paul Allen, Staff Air Pollution Specialist Daniel Chau, Ph.D. Air Resources Engineer Cheryl Taylor, Air Resources Engineer Qi Ying, Ph.D, Air Resources Engineer

Emissions Inventory Martin Johnson, P.E., Staff Air Pollution Specialis t Larry Hunsaker, Air Pollution SpecialistACKNOWLEDGMENT

ARB staff thanks the staff of the San Joaquin Valle y Unified Air Pollution Control District for the high level of coordination between the agencies in the development of the technical elements of this plan.May 30, 2007 i Table of Contents

EXECUTIVE SUMMARY.................................................................. iii

I. BACKGROUND..................................................................... 1 A. Profile of the San Joaquin Valley

B. Ozone Health Effects C. Historical Air Quality D. Central California Air Quality Studies

II. AIR QUALITY PLANNING........................................................7 A. Air Quality Planning Background B. Recent Air Quality Planning Activities C. General Planning Requirements

D. California Clean Air Act Plans

III. PLAN EVALUATION..............................................................11 A. Overview of the San Joaquin Valley 2007 Ozone Pl an B. Emissions Inventory C. Air Quality Modeling

D. Reclassification to Extreme Nonattainment E. Control Strategy

F. Attainment Demonstration G. Reasonable Further Progress and Contingency Meas ures H. Transportation Conformity Budgets I. Additional Requirements for Extreme Nonattainmen t Areas

IV. ENVIRONMENTAL IMPACTS..................... ............................44

V. LEGAL AUTHORITY.............................................................44

VI. STAFF RECOMMENDATIONS................................................45

APPENDICES

Appendix A Emissions Inventory Output Tables

Appendix B Weight-of-Evidence Analysis – San Joaqui n Valley Air

Basin: Ozone

Appendix C Photochemical Modeling Protocol for Deve loping Strategies to

Attain the Federal 8-hour Ozone Air Quality Standar d in Central

California

Appendix D Proposed Updates to the Transportation C onformity Budgets

Identified in the San Joaquin Valley 2007 Ozone Pla nMay 30, 2007 ii 

### (This page intentionally left blank.)May 30, 2007 iii

EXECUTIVE SUMMARY

On April 30, 2007, the San Joaquin Valley Unified A ir Pollution Control District (District) adopted the 2007 Ozone Plan. T he 2007 Ozone Plan charts the

course to attainment of the federal 8-hour ozone ai r quality standard in the Valley. The staff of the Air Resources Board (ARB or Board) has reviewed the 2007 Ozone Plan and is recommending that the Board approve the

2007 Ozone Plan and submit it to the U.S. Environme ntal Protection Agency (U.S. EPA) as a State Implementation Plan (SIP) rev ision.

The topography of the San Joaquin Valley, combined with hot, dry summers, creates an environment very conducive to ozone form ation, especially in the southern end of the Valley which most frequently ex periences the highest ozone levels. This, combined with the physical environme nt and the emissions from cars, trucks, tractors, and industrial sources, res ults in some of the highest ozone levels in the nation. In 2006, Valley air quality monitors recorded 86 days over the federal 8-hour ozone standard, one day more tha n the South Coast Air Basin. The federal ozone standard is exceeded by 30 percen t, based on the 2006 design value.

California has led the nation in reducing public ex posure to harmful air pollution through the development of emission control regulat ions on both mobile and stationary sources. The rules and regulations in p lace today are already providing air quality improvement, measured by the 8-hour standard. However, progress indicators present a mixed picture. The a verage number of days exceeding the federal 8-hour ozone standard has dec lined nearly 20 percent between 1996 and 2006, yet maximum levels have been strikingly flat over the last 10 years, with the average federal 8-hour desi gn value declining by only 3 percent. Still, although the 8-hour design value has come down slowly, the areas – and populations – experiencing the highest ozone levels have decreased in size dramatically (Figure EX-1), and Valley resi dents experience those elevated levels on fewer days.May 30, 2007 iv Figure EX-1

Air quality modeling indicates that attainment of t he ozone standard in the Valley is heavily dependent on control of nitrogen oxides (NOx) emissions, and that NOx emissions must be reduced by 75 percent from to day’s levels in order for the region to reach attainment of the standard. Re ducing reactive organic gas (ROG) emissions will also help to reduce ozone, especially in the near-term, and will help bring many areas of the Valley into a ttainment of the 8-hour ozone standard more quickly. However, air quality modeli ng indicates that while important, ROG emission reductions do not have the same relative benefit as NOx emission reductions, especially in the areas wi th the worst air quality.

The U.S. EPA classifies the San Joaquin Valley as s erious nonattainment for ozone, with an attainment date of June 15, 2013. T o attain the standard by the 2013 deadline, the Valley would need to have all of the necessary NOx reductions in place by 2012. The majority of the e mission reductions needed to bring the Valley into attainment will come from the implementation of the State’s existing mobile source control program, as newer an d cleaner equipment and vehicles are put in place. This will provide a 28 percent reduction in NOx and a 10 percent reduction in ROG emissions between now a nd 2012 in the Valley. Even with this marked improvement, the Valley will still be short of the NOx goal by 66 percent and will be 15 percent short of the R OG goal in 2012.

A “serious” classification does not reflect the tru e magnitude of the ozone problem in the Valley or the increased stringency o f the 8-hour standard. Demonstrating attainment of the federal ozone stand ard by June 2013 as aMay 30, 2007 v

serious nonattainment area is not practical, given the scope of the problem and the need to rely on new technologies that will phas e in between 2011 and 2017. The federal Clean Air Act (Act) allows, and U.S. EP A recommends, that in these cases the area be reclassified to an appropriate hi gher classification such as severe-15, severe-17, or extreme, with attainment d ates in 2019, 2021, and 2024, respectively.

ARB and District staffs have identified additional opportunities to garner further reductions. ARB staff developed the proposed 2007 State Strategy 1 to provide significant new mobile source emission reductions i n the Valley, beyond the existing control program, on a very aggressive time line. On April 30, 2007, the District Governing Board adopted a plan which requi res additional controls on stationary and area-wide sources.

Both the proposed State Strategy and adopted Distri ct plan include commitments to develop new emission control regulations and exp and incentive programs as a mechanism to accelerate the conversion to newer, cl eaner technologies. The local strategy includes a suite of near-term regula tory measure commitments for significant early ROG reductions which will result in near-term air quality improvement throughout the Valley.

The Valley faces a fundamental technology constrain t in its effort to attain the

federal ozone standard. As discussed later in this document, even if every car, truck, and piece of construction and farm equipment met the cleanest adopted emission standards, the Valley would still need mor e reductions. Therefore, the

ARB and District staffs will need to continue to de velop longer-term concepts and new technologies to provide the final increment of reductions needed for the Valley to attain the standard. Under the Act, the Valley’s real-world need to rely on future technology is only allowable in SIPs for areas classified as extreme.

On April 30, 2007, the District adopted the San Joa quin Valley’s 2007 Ozone Plan and voted to request that U.S. EPA reclassify the Valley to an extreme

nonattainment classification. While the ultimate a ttainment date would be extended to 2024, full implementation of the 2007 O zone Plan would result in most regions in the Valley attaining the standard b efore then. Table EX-1

demonstrates that the emission reduction commitment s included in the San Joaquin Valley’s 2007 Ozone Plan will result in attainment of the federal ozone standard throughout the Valley by the final a ttainment date. The near-term emission reduction measures approved by t he District, combined with those proposed by ARB staff, will result in dramati c air quality improvement in the San Joaquin Valley. By 2023, only four sites in th e Valley will need emission reductions, beyond the proposed state measures, in order to attain the federal

ozone standard – and all sites will have seen marke d improvement to that point.

1 Available online at: http://www.arb.ca.gov/plannin g/sip/2007sip/2007sip.htmMay 30, 2007 vi Table EX-1 Setting and Meeting the Emission Reduction Target for Ozone Attainment (Summer Planning tons per day) San Joaquin Valley (2023)

NOx ROG 2006 Emissions Inventory 650 454 Carrying Capacity 160 342 Emission Reduction Target 490 112 Emission Reductions from Existing Program 355 43

Emission Reductions from New Local Measures 9 47

Emission Reductions from New State Measures 46 25 Long-Term Concepts 80 --

Total Reductions Identified 490 115

The 2007 Ozone Plan includes long-term commitments to achieve this last increment of emission reductions necessary to meet attainment goals in the San Joaquin Valley. As the State agency charged wi th ensuring California’s SIP compliance, ARB is ultimately responsible for ensur ing the necessary measures are identified no later than 2020 (three years prio r to the attainment year), and the emission reductions are achieved by 2023.

As part of the State Strategy under development, AR B staff is proposing to initiate a coordinated government, private, and pub lic effort to establish emission goals for critical mobile and stationary emission s ource categories. Following the setting of emission goals, ARB would start an ongoi ng public process to assess technology advancement opportunities for the critic al categories. ARB staff will periodically brief the Board at public meetings on emerging emission reduction opportunities, promising technologies, and the prog ress made in developing long-term emission reduction measures. As ARB staf f identifies feasible technology-forcing emission reduction measures, sta ff will propose those

measures to the Board for inclusion into the SIP.

The 2007 Ozone Plan, and the request for reclassifi cation, is controversial. Many members of the environmental community believe that a reclassification to extreme represents an unacceptable delay in attainm ent of the federal 8-hour ozone standard. Based on the air quality modeling conducted for the San Joaquin Valley, combined with known emission co ntrol technologies which will be available, the District believes, and ARB s taff concurs, that an extreme area attainment plan is the only one that realistic ally charts the course to clean air – which makes it the only federally approvable course of action.

While a reclassification to extreme is, in the Dist rict’s and ARB staff’s view, a practical and legal necessity, the District Board a pproved a dual path strategy for attainment. One path includes the commitments and timelines needed in a federally approvable SIP, and recognizes the constr aints placed on the District byMay 30, 2007 vii

State and federal law, policy, and guidance. The s econd path, which will parallel SIP implementation, includes important policy initi atives such as the use of increased, but as yet unsecured, incentive funding. Via the second path, the District is attempting to meet the standard before the 2024 extreme deadline.

ARB staff recognizes the significance of having the dual path approach in the 2007 Ozone Plan. However, only some of the include d actions reflect federally enforceable commitments and quantifiable emission r eductions. In this document, where the district has made an enforceabl e and quantifiable commitment, ARB staff has indicated such. Where th e District has committed to broader-reaching, yet equally important dual-path s trategies, ARB staff has indicated this as well. However, only the federall y approvable elements will be transmitted to U.S. EPA for inclusion in the Valley ’s SIP.

While the focus of the current planning effort for the San Joaquin Valley is ozone, it is important to remember that the Valley is also classified as nonattainment for the federal PM2.5 standard. The Valley now has a n ominal attainment date for the PM2.5 standard of April 2010. This attainment date may be extended from one to five years. The PM2.5 attainment plan must be submitted to U.S. EPA by April 5, 2008. Many of the control strategies need ed to bring the Valley into

attainment of the federal ozone standard will also provide progress towards

attainment of the PM2.5 standard. Like the 8-hour ozone standard, U.S. EPA guidance requires all of the emission reductions ne eded to attain the PM2.5 standard to be in place by the beginning of the yea r prior to the attainment year, in this case 2014 if the extension is granted. The District will adopt a PM2.5 attainment plan in the first half of 2008. As part of this effort, ARB staff is working with the District to both identify emission reducti on targets for attainment and to ensure the Valley comes into attainment with the fi ne particulate standard as expeditiously as practicable.May 30, 2007 viii 

### (This page intentionally left blank.)May 30, 2007 1

I. BACKGROUND

A. Profile of the San Joaquin Valley

Covering nearly 25,000 square miles, the San Joaqui n Valley (Valley) is one of the dominant features in California’s landscape. T he Valley is one of the fastest growing regions in California and is home to more t han 3.6 million people. The Valley has four large cities, Stockton, Modesto, Fr esno, and Bakersfield, with populations of greater than 200,000 people. Outsid e of these cities, the Valley has numerous smaller cities and towns, separated by large expanses of agricultural lands. While the Valley has large tra cts of agricultural land, the Valley is very urbanized, and as more and more land is converted from agricultural to non-agricultural land uses, this ur banization will continue.

Open to the Sacramento-San Joaquin River Delta in t he north, the San Joaquin Valley is surrounded by the Sierra Nevada Mountains to the east, the Pacific Coast Range to the west, and the Tehachapi Mountain s to the south. Airflow patterns in the San Joaquin Valley tend to move fro m north to south and are dammed by the surrounding mountain ranges.

The climate and geography of the San Joaquin Valley create the optimal conditions for creating and trapping air pollution. The Valley is characterized by hot, dry summers, with normal temperatures in the n ineties, and heat waves periodically exceeding 100 degrees Fahrenheit. Win ters in the San Joaquin Valley are cool and damp, with frequent periods of dense fog. In both summer and winter, the major airflow patterns tend to resu lt in long mixing times for emitted pollutants, especially in the central and s outhern portions of the Valley.

These stagnant weather patterns make the Valley vul nerable to forming ozone and fine particulate matter air pollution and imped e the region’s ability to disperse it. The ozone season in the San Joaquin Valley spa ns a six-month period—May through October. The Valley has ozone levels more than 30 percent above the federal standard, which make it among the most heav ily impacted regions in the nation. Approximately two out of every three days in this period has an

exceedance of the national ozone standard at one or more sites within the Basin—reflecting the challenge of attaining the sta ndard throughout the Valley.

B. Ozone Health Effects

Ozone is a highly reactive gas that forms in the at mosphere through complex reactions between chemicals directly emitted from m otor vehicles, industrial plants, consumer products and many other sources. It forms in greater quantities on hot, sunny, calm days, making the summer season the key exposure period.May 30, 2007 2

Considerable research over the past 35 years has in vestigated how people respond to inhaling ozone. These studies have cons istently shown that ozone

can lead to inflammation and irritation of the tiss ues lining the human airways. This causes the muscle cells in the airways to spas m and contract, thus reducing the amount of air that can be inhaled. Symptoms an d responses to ozone exposure vary widely, even when the amount inhaled and length of exposure is the same. Typical symptoms include cough, chest ti ghtness, and increased asthma symptoms. Ozone in sufficient doses can als o increase the permeability (“leakiness”) of lung cells, making them more susce ptible to damage from

environmental toxins and infection.

Medical studies of large populations have found tha t ozone exposure is associated with an increase in hospital admissions and emergency room visits, particularly for persons with lung problems such as asthma and chronic obstructive pulmonary disease. Several studies hav e also associated ozone exposure with increased premature mortality. ARB a nalysis indicates that hospitalizations for respiratory related illnesses, not including premature mortality, resulting from ozone levels over the fed eral standard costs Valley residents on average 18 million dollars per year.

The following charts are examples of our reason for concern over the health effects of air pollution in the San Joaquin Valley (Figure 1). The rates for asthma

in children and the rates for deaths from cardiovas cular causes are listed for the San Joaquin Valley and compared to the State as a w hole. Childhood asthma

rates are from the California Health Interview Surv ey, 2003 data.

Figure 1

Childhood Asthma Rates (2003)

13.0 15.8

0.0 3.0 6.0 9.0 12.0 15.0 18.0

Statewide San Joaquin ValleyPercentMay 30, 2007 3 C. Historical Air Quality

The Valley is currently classified as serious nonat tainment for the federal 8-hour ozone standard, and is designated as nonattainment for the federal PM2.5 standard. Unlike many other ozone nonattainment ar eas of the State, the ozone problem in the San Joaquin Valley is not dominated by one large urban area. Instead, it is the result of a number of moderately sized population centers, located along the main, northwest-southeast axis of the Valley.

The rules and regulations in place today were large ly developed to reduce exposures to 1-hour ozone levels. The average numb er of days exceeding the now-revoked federal 1-hour standard dropped more th an 75 percent over the past decade. Even with this progress, the 1-hour o zone design value in the San Joaquin Valley has declined by only 11 percent over that same time period (Figures 2 and 3).

Trends for 8-hour ozone levels for the San Joaquin Valley as a whole have also been strikingly flat over the last 10 years. While the average number of days exceeding the federal 8-hour ozone standard has dec lined nearly 20 percent between 1996 and 2006, the average federal 8-hour d esign value has dropped by only 3 percent.

Figure 2

San Joaquin Valley
Federal Ozone Design Values* (1990-2006)

0 0.02 0.04 0.06 0.08 0.1 0.12 0.14 0.16 0.18 0.2

1990 1994 1998 2002 2006

YearOzone Concentrations (ppm)

* The Federal 8-hour ozone design values are represented by the "3-year average of the 4th high" 8-hour value. The Federal 1-hour ozone design values are represented by the "3-year 4th high" 1-hour value. Federal 8-hour Design Value Federal 1-hour Design ValueMay 30, 2007 4 Figure 3

San Joaquin Valley
Federal Ozone Exceedance Days (1990-2006)

0 30 60 90 120 150

1990 1994 1998 2002 2006

YearExceedances Days Federal 8-hour Standard

Federal 1-hour Standard

Because the Valley encompasses a very large geograp hic area, looking at subregions with similar geography and weather conditio ns helps provide a better understanding of air quality improvements and chall enges. Generally, the number of days exceeding the level of the 8-hour st andard is low in the northern region, but dramatically increases from the central to the southern region of the Valley. High ozone concentrations are widespread a nd commonly occur in the urbanized Merced, Fresno, and Bakersfield regions, and as well as in the downwind areas of Parlier, Sequoia National Park, a nd Arvin.

Over the past 10 years, air quality has improved th roughout the Valley. On average, there were fewer days over the standard be tween 2004 and 2006 than between 1994 and 1996 (Figure 4), with the exceptio n of the monitor at Sequoia and Kings Canyon National Park which shows slightly more days over the standard, on average. So, while the fourth highest ozone levels have remained relatively consistent, the number of days on which elevated levels occur has

decreased.May 30, 2007 5 Figure 4

Average Number of 8-hour Ozone Exceedance Days

0 10 20 30 40 50 60 70 80 90 100

Northern

SJV Central

SJV Southern

SJV Sequoia ArvinNum ber of Exceedance Days

1994-1996 2004-2006

Ozone exceedances in downwind areas such as Arvin a nd Sequoia National Park are a special concern. Arvin is a community o f 15,000 people located

southeast of Bakersfield at the foot of the Tehacha pi Mountains. The air quality monitor located near Arvin is the site recording th e San Joaquin Valley’s highest 8-hour ozone levels. The 2006 design value 2 , as monitored at the Arvin site, is 0.110 parts per million (ppm), over 30 percent abov e the level of the standard of 0.084 ppm. This compares to 17 percent above the s tandard in Fresno and 18 percent in Bakersfield. Generally, the number o f exceedance days at Arvin surpasses any other site in the Valley with the pos sible exception of sites located in Sequoia National Park, downwind of the Fresno ar ea. The air quality monitor in Arvin records an exceedance 85 percent of the ti me when there is an exceedance anywhere in the San Joaquin Valley.

Air quality planning in the San Joaquin Valley is f urther complicated because the Valley is also designated nonattainment for the fed eral PM2.5 standard. PM2.5 tends to be high during the wintertime. While the Valley does meet the current 24-hour PM2.5 standard of 65 ug/m3, the design valu e for the annual PM2.5 standard is approximately 25 percent above th e standard of 15 ug/m3. Attainment of the annual standard is the most signi ficant near-term challenge in the San Joaquin Valley. The San Joaquin Valley Uni fied Air Pollution Control District (District) is currently developing a PM2.5 attainment plan, which will be brought to the District Governing Board in early 20 08. In addition, the Valley has a significant number of days above the new 24-hour standard of 35 ug/m3, which

became effective at the end of 2006 and will be the subject of a future planning cycle.

2 The Federal ozone design values are represented by the "3 year average of the 4th high"

monitored 8-hour ozone level.May 30, 2007 6 D. Central California Air Quality Studies

The Central California Air Quality Studies are comp rised of two programs, the California Regional Particulate Air Quality Study ( CRPAQS) and the Central California Ozone Study (CCOS). These studies are a collaborative effort between the public and private sector designed to: 1) develop an improved understanding of ozone and particulate matter in ce ntral California; and, 2) provide decision-makers with the tools needed to id entify equitable and efficient

control methods.

The studies are a comprehensive multi-year effort o f meteorological and air quality monitoring, emission inventory development, data analysis, and air quality simulation modeling. Combined, the two studies ref lect an investment of nearly 50 million dollars, coupled with extensive in-kind support from study sponsors, extending over a 15-year period. The resulting dat a and analytical tools are providing the most advanced scientific understandin g available for State Implementation Plan development.

CCOS consists of a field program, data analysis, em ission inventory development, and modeling. The CCOS field program was conducted during the summer of 2000. Emission inventory development, da ta analysis, and modeling are on-going projects. The entire effort is expect ed to be completed by 2011. ARB and the central California air pollution contro l districts are using the results of CCOS to prepare the ozone SIPs for nonattainment areas in central California. CCOS provides the most important scientific buildin g blocks for the Valley’s current ozone planning effort.

CRPAQS is intended to evaluate the Valley’s particu late matter challenges with respect both to the national and State air quality standards for particulate matter smaller than 10 micrometers in diameter (PM10) and for particulate matter smaller than 2.5 micrometers (PM2.5). The San Joaq uin Valley routinely experiences high levels of particulate matter, and currently exceeds the federal annual PM2.5 standard. CRPAQS was designed to addr ess annual particulate levels as well as fall and winter episodic conditio ns. Data was collected for 14 months (December 1999 through February 2001) throug hout the Valley and surrounding regions. CRPAQS will provide the scien tific foundation upon which PM2.5 SIP planning efforts will be built.May 30, 2007 7

II. AIR QUALITY PLANNING

A. Air Quality Planning Background

The federal Clean Air Act Amendments of 1990 (CAA o r Act) establish the planning requirements for those areas that routinel y exceed the health-based National Ambient Air Quality Standards (NAAQS). Th ese nonattainment areas must adopt and implement a SIP that demonstrates ho w they will attain the standards by specified dates. Federal law holds ea ch state responsible for implementing the provisions of the Act.

In the air quality management process, many regulat ory authorities in California work together to reduce air pollution levels. Each of these agencies is responsible for achieving emission reductions from a part of the inventory. The State has primary regulatory authority over on-road vehicles sold and operated in California, consumer products, pesticide emissions, and certain off-road vehicles and equipment sold or operated in the State. The U .S. EPA has regulatory authority over on-road vehicles sold outside of Cal ifornia, large new farm and construction equipment, locomotives, ocean-going ve ssels, and aircraft. The regional air pollution control districts have prima ry authority over stationary emission sources, including industrial and commerci al equipment. The regional air districts also develop locally approved air qua lity plans which, upon approval by the ARB and submission to U.S. EPA, become the r egion’s SIP.

Ultimately, State law 3 designates the ARB as the State's air pollution co ntrol agency for all purposes set forth in federal law, i ncluding the preparation of the SIP. State law further specifies that the ARB must adopt the nonattainment area plan approved by a local district, unless the ARB finds, after a public hearing, that the locally adopted plan will not mee t the requirements of the CAA. 4
The provisions and commitments in a U.S. EPA-approv ed SIP are federally enforceable. The CAA also allows interested partie s to sue U.S. EPA, the State, or local agencies to compel implementation of an ap proved SIP and other provisions of the Act.

B. Recent Air Quality Planning Activities

Over the past decade, the San Joaquin Valley Unifie d Air Pollution Control District, ARB, and other State and local agencies h ave adopted a series of regulations and measures to improve air quality in the Valley. New mobile source standards, reformulated gasoline, and multip le consumer products regulations have been adopted and are being impleme nted today. And, while California continues to face serious air quality ch allenges, it is important to recognize the progress made as a result of Californ ia’s landmark air pollution control programs.

3 California Health and Safety Code (HSC) section 39 602.

4 HSC Section 41650(a).May 30, 2007 8 Ozone Standard

0.08 parts per million for 8 hours

, not to be exceeded, based on the annual fourth highest concentration averaged over three years. 1. 2004 Extreme Ozone Plan

In October 2004, the San Joaquin Valley Unified Air Pollution Control District adopted the 2004 Extreme Ozone Attainment Plan (200 4 Plan). The 2004 Plan

addressed the now-revoked federal 1-hour standard. U.S. EPA never took action on the 2004 Plan. Still, the emission reduction me asures identified in the 2004 Plan are being implemented and will provide si gnificant progress towards reducing emissions of NOx and ROG, the two primary precursors to ozone
formation.

2. 2006 PM10 Plan

The District has implemented a successful PM10 atta inment plan which has resulted in the Valley coming into attainment of th e federal PM10 standard. The San Joaquin Valley recently attained the federal PM 10 standard, based upon three years of complete, quality-assured monitored air quality data for 2003-2005. The U.S. EPA concurred, and on October 30, 2006, published a finding of attainment 5 of the PM10 standard for the Valley. The 2006 dat a continues to support this finding.

C. General Planning Requirements

1. 8-hour Ozone Planning

In July 1997, U.S. EPA promulgated a new air quality standard for ozone that provides additional protection

from the harmful health effects of this pollutant. The ozone standard was revised to protect against longer pollutant exposure periods by requiring that ozone concentrations not exceed specified levels over an 8-hour period instead of a 1-hour period. In April 2004, U.S. EPA finalized Phase 1 of the ozone implementation rule. 6 This rule set forth the classification scheme for nonattainment areas and continued obliga tions with respect to the existing 1-hour ozone requirements. As described b y the Phase 1 rule, the San Joaquin Valley Air Basin is classified as a serious nonattainment area with an attainment date of June 15, 2013.

On December 22, 2006, after hearing arguments for a nd against limited aspects of the Phase 1 rule, the U.S. Court of Appeals for the District of Columbia Circuit vacated the rule, and sent it back to U.S. EPA for further proceedings. On

5 Federal Register: October 30, 2006 (Volume 71, Numb er 209, pages 63641-63664)

6 Federal Register: April 30, 2004 (Volume 69, Numbe r 84, pages 23951-2400)May 30, 2007 9

March 22, 2007, the U.S. Department of Justice peti tioned the Court for a rehearing by the entire Court. While the ultimate outcome of this rule may have impacts on areas with lesser air quality problems, ARB staff expects the impacts on the San Joaquin valley will be minimal.

On November 9, 2005, U.S. EPA supplemented its Phas e 1 implementation rule

with a Phase 2 rule. 7 The Phase 2 rule outlines the emission controls a nd planning elements that nonattainment areas must add ress in their implementation plans, including:

 air quality modeling that demonstrates attainment of the 8-hour ozone standard;

 adopted control strategies capable of meeting atta inment, and contingency

measures in the event the controls fall short of ac hieving needed reductions;

 reasonable further progress plans;

 demonstration that all reasonably available contro l technology (RACT) has been applied to existing sources;

 transportation conformity emission budgets to ensu re transportation plans and projects are consistent with, and will not hind er attainment;

 a weight-of-evidence analysis;

In order to demonstrate attainment of the 8-hour oz one standard by the Valley’s formal attainment date, all of the emission reducti ons needed for attainment must be in place by the beginning of the full ozone seas on prior to 2024. For example, with a June 15, 2024 attainment date, the necessary emission reduction strategies must be in place by the beginning of the 2023 ozone season.

2. PM2.5 Planning

The San Joaquin Valley is also designated nonattain ment for the federal fine particulate matter (PM2.5) standard. PM2.5 plans a re due to U.S. EPA in April 2008. Recent air quality monitoring data sho ws that the San Joaquin Valley

Air Basin attains the 1997 24-hour PM2.5 standard o f 65 micrograms per cubic meter (ug/m3) of air. The Valley exceeds the annua l standard of 15 ug/m3. However, U.S. EPA recently strengthened the 24-hour standard, lowering the acceptable levels to 35 ug/m3 over a 24-hour period

.

NOx is one of the primary contributors to PM2.5 for mation in the Valley. As such,

the NOx reductions identified in the 2007 Ozone Pla n will provide substantial progress towards attainment of the PM2.5 standard. The District and ARB staffs have begun to identify the magnitude of emission re ductions needed to bring the Valley into attainment of the PM2.5 standard by 201 5. To the extent that the

NOx emission reductions identified in the 2007 Ozon e Plan need to be supplemented, the District and ARB will explore opp ortunities to achieve direct PM2.5 emission reductions, particulate precursor re ductions from sources such

7 Federal Register: November 29, 2005 (Volume 70, Nu mber 288, pages 71612-71705)May 30, 2007 10

as mobile agricultural equipment, as well as additi onal precursor reductions through increased use of financial incentives.

D. California Clean Air Act Plans

The California Clean Air Act requires all areas tha t violate the State 8-hour ozone standard to achieve a 5 percent annual reduction in ozone precursors, but allows the option of adopting all feasible measures where this is not possible. Areas must demonstrate every three years that they are ma king steady progress towards attainment. Thus far, all districts, inclu ding the San Joaquin Valley APCD, have relied on the all feasible measures opti ons to show progress.

Appendix E of the Valley’s 2007 Ozone Plan addresse s California Clean Air Act planning requirements. Appendix E will not be subm itted to U.S. EPA as part of

the 8-hour ozone SIP.May 30, 2007 11

III. PLAN EVALUATION

A. Overview of the San Joaquin Valley 2007 Ozone Pl an

The San Joaquin Valley Unified Air Pollution Contro l District adopted its 2007 Ozone Plan on April 30, 2007. This plan chart s the course towards

attainment of the federal 8-hour ozone standard in the San Joaquin Valley no

later than the deadline for an extreme nonattainmen t area. The 2007 Ozone Plan contains a dual path strategy, one path constr ained by the requirements contained in federal law and regulation on an extre me timeline, the other charting actions to beat that timeline. ARB staff supports this “beat-the-SIP” approach; however, as did the District, we recognize that Cal ifornia must submit a federally approvable plan, meeting all of the requirements of the Clean Air Act. The discussion below focuses on the federally approvabl e SIP elements, which ARB staff are proposing the Air Resources Board approve and forward to U.S. EPA.

Attaining the ozone standard in the San Joaquin Val ley will require continued efforts at all levels of government. ARB staff wil l continue to track promising new emission reduction technologies. This will include technologies to ensure that new sources are as clean as possible and will lever age technology development to keep existing equipment operating at its intende d levels. U.S. EPA will need

to continue to reduce emissions from sources under its authority. In the San Joaquin Valley, this will require additional re ductions from the on-road trucks registered outside of California and locomotives mo ving goods up and down the Valley, plus continued progress to clean up the off -road equipment under its

control.

Substantial emission reductions will be achieved in the near-term through the use of programs which speed up the transition to cleane r mobile sources. However, as the adopted mobile source controls reach full im plementation by 2020, new technologies will be needed to further reduce both mobile and stationary source emissions. Further, as mobile sources continue to get cleaner, stationary and area-wide sources will own a greater share of ozone forming emissions. The District has experience implementing first-of-their -kind emission control regulations. This will need to continue as cleaner industrial and commercial technology becomes available.

B. Emissions Inventory

An emissions inventory is a critical tool used to e valuate, control, and mitigate air pollution. At its core, an emission inventory is a systematic listing of the sources of air pollutants along with the amount of pollutan ts emitted from each source or category over a given time period. Emission invent ories are estimates of the air pollutant emissions that are released into the envi ronment – they are not direct ambient concentration measurements. The following are examples of key

sources of air emissions:May 30, 2007 12

• Stationary Sources – power plants and oil refineri es;

• Area-wide Sources – consumer products and resident ial fuel combustion for heating homes;

• On-Road Sources – passenger vehicles and heavy-dut y trucks;

• Off-Road Mobile Sources – aircraft, trains, ships, recreational boats, construction equipment and farm equipment;

• Non-anthropogenic (Natural) Sources – biogenic (or vegetation), geogenic (petroleum seeps) and wildfires

This section summarizes emissions in the San Joaqui n Valley during 2006 and projects emissions for 2014, 2020, and 2023. More detailed emissions data are presented in Appendix B of the San Joaquin Valley 2 007 Ozone Plan. The 2006 inventory reflects adopted District and ARB regulat ions through December 2006. Forecast (future year) emissions are based on adopt ed air regulations with both current and future compliance dates.

The San Joaquin Valley 2007 Ozone Plan uses two typ es of inventories: a modeling inventory used as an input to the air qual ity model and a summerseason planning inventory used to guide policy-make rs in their efforts to identify solutions to the ozone challenge. These inventorie s use the same baseline assumptions and data sources. The primary differen ce is in how the inventories are aggregated for use. A modeling inventory refle cts where and when the emissions are occurring in the region being examine d. The planning inventory is aggregated by source type and industry sector, and reflects the emissions on a typical summertime day. The following discussion f ocuses on the planning inventory used in the San Joaquin Valley 2007 Ozone Plan.

The planning emissions inventory is divided into fo ur major categories: stationary, area-wide, off-road mobile, and on-road mobile sources. These are the sources over which air quality regulators have influence. The summer season inventory is used for ozone because it refle cts the activity levels and conditions that occur when higher ozone levels occu r in the Valley.

In addition to the four major source categories, th e modeling inventory includes non-anthropogenic emissions. In the San Joaquin Va lley, these generally include wildfire emissions (if a fire occurred on a n episode day) and emissions from vegetation. It is critical to include these e missions in the air quality modeling exercise, as they play an important role i n understanding ozone formation in the Valley.

1. Summary of Emission Sources

Emission sources in the San Joaquin Valley are dive rse. The San Joaquin Valley is an important transportation corridor for moving goods and people inside the State and beyond. In addition, it is one of th e most productive agricultural regions in the world, as well as home to industrial and commercial activities. AllMay 30, 2007 13

of these sources contribute to the concentrations o f pollutants in the Valley. Table 1 shows the San Joaquin Valley’s ozone precur sor emissions split by source category.

Table 1 San Joaquin Valley Air Basin

Baseline Emission Trends (Summer Planning tons per day)

ROG NOx

Source Category 2006 2023 Change (%) 2006 2023 Change (%)
Stationary &

Area-wide a 277 308 11% 128 113 -12%

On-Road Mobile

Vehicles b 99 42 -58% 361 102 -72%

Off-Road

Vehicles and Equipment b 74 59 -21% 161 80 -50%

Total c 450 409 -9% 650 295 -55%

a – Baseline emissions with SJV Controls Measures a dopted through 2006. b – State Measures adopted through 2006. c – Numbers may not add up exactly due to rounding.

Mobile sources, including commercial trucks, passen ger vehicles, tractors and construction equipment currently account for nearly 80 percent of the NOx emissions in the San Joaquin Valley. By 2023, the existing control program drops this to 62 percent. Of this, heavy-duty comm ercial trucks are the leading source, accounting for 44 percent of the total NOx emissions Valley-wide. Mobile agricultural equipment and passenger vehicles, the number two and three sources, account for about 9 percent of the total N Ox emissions in the Valley. The future year emission inventory projections show reductions are expected to occur due to the on-going mobile source emission co ntrol program. Table 2 shows the top 10 sources of NOx emissions in the Sa n Joaquin Valley.May 30, 2007 14 Table 2 San Joaquin Valley Air Basin Top 10 NOx Emission Sources* (Summer Planning tons per day)

Source Category 2006 2015 2023

HEAVY DUTY DIESEL TRUCKS 285 141 75

FARM EQUIPMENT (COMBINES AND TRACTORS) 60 34 17

PASSENGER VEHICLES 58 28 16

Light Trucks, Minivans and SUVs 27 13 8

Passenger Cars 20 9 5

Medium Duty Trucks 12 7 4

MANUFACTURING AND INDUSTRIAL (BOILERS, IC ENGINES) 39 44 48

OFF-ROAD EQUIPMENT (CONSTRUCTION AND MINING) 35 20 12

OFF-ROAD EQUIPMENT (OTHER) 34 21 15

Oil Drilling and Workover Rigs 21 13 8

Industrial Equipment 4 2 1

Transport Refrigeration Units 3 4 4

Commercial 3 2 1

Cargo Handling Equipment 1 1 1

Airport Ground Support Equipment 1 1 1

Other 3 2 1

LOCOMOTIVES 22 21 22

AGRICULTURAL IRRIGATION PUMPS 16 5 5

OIL AND GAS PRODUCTION (COMBUSTION) 11 10 10 COGENERATION (ELECTRICITY GENERATION AND HEAT RECOVERY) 9 8 8

TOTAL OF TOP 10 569 333 227

TOTAL OF SJV 650 398 295

TOP 10 PERCENT OF TOTAL 88% 84% 77%

* Numbers may not add up exactly due to rounding.

Emission sources of ROG are more diverse. Of the t op 10 ROG sources in the San Joaquin Valley (Table 3), only two individual c ategories are larger than 10 percent of the total inventory – passenger vehic les and composting currently account for 14 percent and 13 percent, respectively . All other ROG sources, including dairy cattle waste, prescribed burning, o il and gas production, and recreational boats make up less than 10 percent eac h when viewed individually.

When viewed at the larger level, stationary and are a-wide emission sources account for more than 60 percent of the total ROG e missions. On-road mobile sources make up one-quarter of the ROG emissions. The balance is made up of

off-road mobile sources such as construction and fa rming equipment. In the future, mobile source ROG emissions are expected to decline, as more of the vehicles and equipment in operation meet the most s tringent emission standards required. ROG emissions from stationary and area-w ide sources are expected to grow in the future, as economic growth outpaces the benefits of the current generation of emission control equipment. ROG emis sions from waste disposalMay 30, 2007 15

and composting alone are expected to increase by mo re than 20 tons per day

between now and 2023. The 2007 Ozone Plan sets out commitments to reduce composting emissions. 8

Table 3 San Joaquin Valley Air Basin Top 10 ROG Emission Sources* (Summer Planning tons per day)

Source Category 2006 2015 2023

PASSENGER VEHICLES 62 35 24

Passenger Cars 29 13 8

Light Trucks, Minivans and SUVs 26 16 11

Medium Duty Trucks 8 6 5

OTHER (WASTE DISPOSAL/COMPOSTING) 57 71 80

LIVESTOCK WASTE (DAIRY CATTLE) 40 33 41 OIL AND GAS PRODUCTION (EVAPORATIVE LOSSES/FLARING) 28 25 23

CONSUMER PRODUCTS 24 26 30

HEAVY DUTY DIESEL TRUCKS 20 12 8

RECREATIONAL BOATS 20 17 17

Pleasure Boats 16 14 14

Personal Water Craft 4 3 3

PESTICIDES 18 18 18 FOOD AND AGRICULTURE (CROP PROCESSING AND WINERIES) 13 12 13

ARCHITECTURAL COATINGS (PAINTS AND THINNERS) 11 12 13

TOTAL OF TOP 10 294 262 268

TOTAL OF SJV 450 402 409

TOP 10 PERCENT OF TOTAL 65% 65% 66%

* Numbers may not add up exactly due to rounding.

2. Estimating Emissions

As mentioned previously, emission inventories are e stimates of the pollutant emissions that are actually released into the envir onment. California uses computer models to estimate the emissions from on- and off-road mobile sources. Stationary source emissions data is deriv ed directly from District permitting activities. Area-wide emissions are est imated based on emission factors and information on expected activity from t hese diverse sources and undergo routine reevaluation to ensure that they re main up to date and accurate.

All emission estimates take into account expected g rowth in activity, state-of-thescience emission data, and currently adopted emissi on control rules and regulations. The growth assumptions used to estima te future emissions are

8 On March 15, 2007, the San Joaquin Valley Unified Air Pollution Control District adopted Rule 4565 - Biosolids, Animal Manure, And Poultry Litter Operations, satisfying the commitment to address emissions from this source (see New Local M easures Discussion, below).May 30, 2007 16

critical elements in any attainment demonstration p lan -- they directly impact the

amount of emission reductions needed to reach the e missions target.

Stationary source emissions are derived from Distri ct permit data. Area-wide and off-road source emissions are estimated jointly by ARB, the District, and in the case of pesticide usage, by the California Departme nt of Pesticide Regulation (DPR). Emission reductions from both AR B and District regulations adopted by December 2006 are included in the emissi on forecasts.

The mobile source emission inventories used in the 2007 Ozone Plan represent many improvements in the models that are used to es timate emissions from both on-road and off-road sources. Using the new models , our estimates of the emissions generated by mobile sources have increase d relative to those used in earlier SIPs. These higher estimates do not indica te that actual in-the-air emissions are increasing – on the contrary, actual emissions from cars and

trucks have declined and will continue to decline r apidly over time. This progress comes because of State and federal requirements for cleaner engines and fuels, and despite significant growth in population and ve hicle usage.

Ozone-related emissions in the Valley are generally consistent with the overall downward trend statewide. Although motor vehicle m iles traveled in the basin continue to increase, on-road vehicle emissions are dropping because of more stringent vehicle emission standards and fleet turn over. This trend will be strengthened between 2000 and 2020 as newer, lower- emitting vehicles become a larger percentage of the fleet. Likewise, as new engines and equipment replace older, more polluting models, emissions wil l decline more steeply. The issue before us is not whether, but how quickly emi ssions from the mobile source

fleet can be reduced.

(a) EMFAC2007

EMFAC2007, California's updated on-road motor vehic le emission factor model, was used to generate the on-road mobile source emis sion inventory for the 2007 Ozone Plan. EMFAC2007 represents a comprehens ive review and revision of the on-road inventory when compared to EMFAC2002, which was used in previous San Joaquin Valley plans. The maj or changes reflected in EMFAC2007 include updated information on emissions from heavy-duty diesel in-use engines, smog check testing, corrections to estimated fuel emissions, and more accurate vehicle population numbers. Transpor tation activity data was provided by the eight Valley Councils of Government (COGs) from their Regional Transportation Plans.

(b) OFFROAD2007

The 2007 Ozone Plan reflects improved estimates of engines and equipment population, usage, emission rates, and equipment de terioration for mostMay 30, 2007 17

categories of off-road mobile sources. The invento ry also includes revised estimates of evaporative emissions. The extensivel y revised ship and train emission inventories that were developed for ARB’s Goods Movement Emission Reduction Plan have also been incorporated into the OFFROAD2007 model.

(c) Updated Pesticide Emission Estimates

The DPR has provided updated emission estimates for pesticide use in the San Joaquin Valley. On April 4, 2007, DPR staff publis hed a memorandum 9 outlining

revisions to the emission estimation calculations f or ROG emissions from agricultural pesticide usage. These revised invent ories reflect changes to the emission estimating methodology to include updated emission factors and the inclusion of an application use factor.

The proposed pesticide emission reduction measures under development by DPR staff are calculated using the updated emission estimates. Table 4 summarizes the estimated pesticide emissions calcul ated with the revised estimation methodology.

Table 4

Revised Pesticide Emissions Source Category 2005 2006 2008 2011 2014 2017 2020 2023 Agricultural and

Commercial Structural

Pesticides Emissions a 22.9 -- 22.2 21.7 21.4 21.2 21.0 20.9

Agricultural and

Commercial Structural

Pesticides Emissions b 17.9 17.9 17.9 17.9 17.9 17.9 17.9 17.9

a. – As identified in Appendix B to the San Joaquin Valley 2007 Ozone Plan. b. – As updated by the California Department of Pes ticide Regulation and included in Appendix A to this report.

(d) Emission Reduction Credits

New Source Review (NSR) rules require new and modif ied major stationary

sources that increase emissions in amounts exceedin g specified thresholds to provide emission reduction offsets to mitigate the emissions growths. Emission reduction offsets represent either on-site emission reductions or the use of banked emission reduction credits (ERCs). ERCs are voluntary, surplus emission reductions, which are registered, or banke d, with the District for future

use as offsets.

9 California Department of Pesticide Regulation Memo randum. Date: April 6, 2007. Subject: Pesticide Volatile Organic Compound Emission Adjust ments for Field Conditions and Estimated Volatile Organic Compound Reductions–Initial Estima tes. Available online at: http://www.cdpr.ca.gov/docs/dprdocs/methbrom/comp_m odeling.htmMay 30, 2007 18

According to U.S. EPA policy, ERCs banked before a plan’s emission inventory baseyear (2002 for this plan) must be explicitly tr eated as emissions in the air. This plan does this by including projected ERC use in the emission inventory growth factors for stationary sources. This plan’s projection for ERC use and total growth in stationary source emissions, betwee n 2002 and 2023, is shown in

Table 5.

Table 5 San Joaquin Valley Projected ERC Use and Total Stationary Source Growt h 2002-2023

(Summer Planning tons per day) Pollutant Expected ERC Use Expected Growth

NOx 20.5 20.8

ROG 36.1 37.6

Projected ERC use is roughly equal to total growth expected for each pollutant. The District does take a conservative approach in e stimating ERC usage, by assuming that all ERCs used will be from pre-baseye ar ERCs. The District will need to very closely monitor pre-baseyear ERC usage and stationary source growth, especially in non-permitted source growth a nd permitted sources for which growth offsets are not required, to ensure th at the sum of the two does not exceed total permitted and non-permitted growth. I f all of the ERCs used are pre-baseyear ERCs, there will be extremely little m argin (0.3 tpd NOx between 2002 and 2023) for non-permitted stationary source growth or growth at permitted sources which do not require offsets.

ARB staff recommends that the District consider set ting the pre-baseyear ERC usage caps, as discussed in Appendix D of the 2007 Ozone Plan, at not more than 75 percent of expected stationary source growt h, in order to ensure that there is adequate room for growth in non-permitted sources. This is consistent with the caps on pre-baseyear ERC usage in the 2004 1-hour Ozone SIP for the San Joaquin Valley.

3. Future Improvements to the Emissions Inventory

(a) Off-road Mobile Agricultural Equipment

As illustrated later in this document, ARB staff ha s not quantified the benefits of an off-road mobile agricultural equipment emission reduction measure. ARB staff plans to develop this emission reduction meas ure as part of the proposed State Strategy. Off-road mobile agricultural equip ment currently accounts for 60 tons per day of NOx emissions in the Valley. As ol der equipment turns over, these emissions are expected to decline to 34 tpd b y 2015. Part of the measure development effort will involve ARB staff acquiring a better understanding of the activity and population profile of off-road mobile agricultural equipment use in theMay 30, 2007 19

Valley, including where, when, and how this equipme nt operates. This understanding will improve the emissions inventory estimates and serve as the

basis for a new emission reductions measure to be d eveloped.

(b) Non-point Source Industrial Natural Gas Combust ion

ARB staff recommends that the District explore oppo rtunities to refine the emissions inventory for non-point source industrial natural gas combustion. In November 2006, District staff revised the emission estimation methodology 10 for this category. District staff estimates that combu stion of natural gas in non-point source industrial heaters, boilers, and burners res ulted in NOx emissions of more than 32 tpd in 2006, based on the California Energy Commission estimation of industrial natural gas usage in the Valley. Emissi ons from this category are expected to increase to more than 40 tpd NOx by 202 3. Some of this equipment may be subject to existing district rules. If so, the benefits of these rules might not be reflected in the current emissions inventory estimation.

4. Model Emission Inventory

Modeling emission inputs are commonly known as “gri dded inventories” or “modeling inventories.” Even though the basic sour ce of emissions data for planning and modeling purposes are the same, there are a variety of things that

cause differences between emission estimates used f or planning and modeling.

Where air quality planning strategies are generally developed using seasonal emission estimates for air quality planning or poli tical boundary regions, air quality models require hourly estimates of emission s for each grid cell in a modeling domain. In addition, because base year mo del simulations are required to meet specific performance criteria in t he base year, the base year modeling inventory estimates must also be most repr esentative of the actual emissions that occurred during the days and hours t hat are being simulated. The need for greater spatial and temporal resolution in volves taking into consideration, for example, temperature effects on evaporative or biogenic emissions and emission upsets that might have occur red at large sources.

During the July 30-August 2, 2000 base case, a larg e wildfire produced ozone precursors that affected air quality in the San Joa quin Valley. Wildfire emissions were only included in the modeling of the base case . Because there is no method to predict where, when and how large future wildfires will occur, wildfire emissions were not included in the base year (2002) and future year model projections.

10 See Emissions Inventory Methodology – 050 – Indust rial Natural Gas Combustion , available

online at: http://www.valleyair.org/Air_Quality_Plans/Emission sMethods/MethodForms/Mthd_IndustrialNGC ombustion_SJV_2005.pdfMay 30, 2007 20 C. Air Quality Modeling

The Act requires the use of air quality modeling to relate ozone levels to emissions and meteorology in a region, and to simul ate future air quality based on changes in emissions. Air quality modeling uses day-specific emission inventories, combined with meteorological and air q uality measurements, to establish this relationship. The air quality model ing conducted for the Valley, as approved in the 2007 Ozone Plan, provides ROG to NO x carrying capacity diagrams which can be used to determine the relativ e efficacy of both ROG and NOx reductions. Rather than using air quality mode l predicted ozone concentrations results directly, U.S. EPA Guidance calls for using models to develop relative reduction factors (RRF). The RRF is calculated as the ratio of future-year to reference-year model-simulated conce ntrations at a specific location (i.e. based on estimates of forecasted, fu ture year emissions and baseyear emissions). The reference year for RRF calcul ations is 2002. The impact that future-year emission changes might have on ref erence-year pollutant design values is assumed to be proportional to the effect that the associated emission inputs used for modeling have on model-simulated co ncentrations. This is one of the reasons why multiple days are used in the calcu lation of RRFs, since the reference year design value is not day-specific. T hus, to estimate a future-year design value at a site, the 2002 reference-year, si te-specific design value is multiplied by the RRF that is derived from modeling

.

ARB staff conducted the modeling used in support of the San Joaquin Valley 2007 Ozone Plan with input from the Valley Air Dist rict, other northern California air districts, and the academic community. In part icular, ARB staff drew heavily on the input and involvement of the CCOS Technical Committee, the Bay Area Modeling Advisory Committee, and the SIP Gridded In ventory Coordination Group. More information on the air quality modelin g conducted by ARB staff can be found in Appendix C to this report, in Appendix F of the San Joaquin Valley 2007 Ozone Plan, and on-line at:

http://www.arb.ca.gov/eos/SIP_Modeling/

1. Ozone Episode

A key air quality modeling decision is the selectio n of a modeling episode. The modeling episode is an actual time period(s), or ba se-case, where extensive information on emissions, meteorological conditions , and air quality data have been studied and which are representative of exceed ance conditions.

Two modeling episodes were selected for use in the San Joaquin Valley 2007 Ozone Plan: July 29-August 2, 2000 and July 9-13, 1 999. Another episode in September 2000 was considered, but to date, model p erformance has been poor and consequently this episode has not been used. E pisodes in 2000 were partially chosen because they fall within the inten sive CCOS monitoring periodMay 30, 2007 21

where a comprehensive data set to use in modeling i s available. The 1999 episode was chosen because the Bay Area and Sacrame nto Metropolitan Air Quality Management Districts believed ozone levels during that episode were representative of their concentrations. In additio n to selecting the model, the

CCOS Technical Committee and Northern California SI P/Transport working group considered and approved these episodes.

For both the 1999 and 2000 episodes, the model-simu lated ozone levels were near design values at key air monitoring sites. In general, modeling of these episodes met performance standards, but some concen trations were underpredicted at sites in the Valley. During the July – August 2000 episode, meteorology was generally representative of ozone e xceedance days. A comparison of this episode to historical cases indi cates that some days of the episode were extreme meteorological and pollutant e vents. For July 1999, statistical analyses also showed that meteorology w as especially conducive to forming ozone. According to U.S. EPA guidance, the se pollutant and meteorological characteristics make them good candi dates for modeling. For these episodes, typical meteorological features tha t have been seen in the past, such as, slope, eddy, and marine flows were evident . The episodes did represent the transport and dispersion that have be en observed historically in Central California. Additional detail on the episo de selection can be found in Chapter three of the Valley’s 2007 Ozone Plan.

2. Air Quality Model

The U.S. EPA-accepted “Comprehensive Air Quality Mo del with Extensions” (CAMx) modeling system was chosen to es timate the amount of

emissions reductions needed to achieve the 8-hour o zone standard. A meteorological model, the Mesoscale Model version 5 (MM5), was used to generate the meteorological fields for the CAMx mod el. Modelers chose the [California] Statewide Air Pollution Research Cente r (SAPRC) chemical mechanism for the final run, which is slower comput ationally than other mechanisms but treats the chemical production of oz one in more detail. The choice of the modeling system was a consensus among the modelers and

stakeholders in Central California. Discussion of these choices in models occurred through the Central California Ozone Study

.

3. Model Performance

Appendix F of the 2007 Ozone Plan describes the mod eling conducted by ARB staff and includes a detailed model performance ana lysis. The model performance analysis documentation provided to the District by ARB staff summarizes model performance procedures and results for meteorological modeling, as well as air quality modeling for the J uly 1999 and July-August, 2000, episodes. The model performance evaluations are based on U.S. EPA guidance, as well as recommendations from published academicMay 30, 2007 22

literature. The model performance documentation al so provides a summary of the performance analysis and provides a tabular lis ting of complete graphical and statistical results, which can downloaded via file transfer protocol at:

ftp://eos.arb.ca.gov/pub/outgoing/model_protocol2

4. Weight-of-Evidence

ARB staff conducted the weight-of-evidence (WOE) an alysis the District staff relied upon. Appendix F of the San Joaquin Valley 2007 Ozone Plan includes ARB staff’s initial draft of the WOE analysis. App endix B of this staff report updates this analysis and summarizes the analyses t hat comprise the WOE assessment for the San Joaquin Valley nonattainment area.

5. Attainment Emissions Target

Air quality modeling helps to establish the attainm ent emission target, a key piece of information that policy-makers need in ord er to assess the magnitude of the challenge and to develop appropriate solutions. The Valley’s 2007 Ozone Plan uses modeling for future year 2020 to establish the carrying capacity. The 2020 modeling indicates that ozone l evels in the San Joaquin Valley are much more constrained by the availabilit y of NOx, especially in the southern region. The air quality modeling indicate s that NOx emissions must be reduced by 75 percent from current levels. Similar ly, ROG emissions must be reduced nearly 25 percent. Greater ROG reductions would not substantially change the NOx reductions needed. For example, inc reasing the ROG reductions by an additional 50 percent would only d ecrease the NOx reductions needed by 5 percent. While not the critical ozone precursor in the most heavily impacted downwind sites, early ROG reductions will result in significant improvement in air quality throughout the Valley. ARB modelers took background ozone levels into consideration when est ablishing the attainment target. Table 6 shows the current emission levels, the attainment emission target used in the 2007 Ozone Plan, and the emission reduc tions which need to be

achieved in order to attain the federal ozone stand ard.

Carrying capacities for ozone reflect absolute ROG and NOx emissions in a given area and are largely independent of the year in which they occur, with two notable exceptions: ROG reactivity and spatial chan ges in emissions. The reactivity profiles for ROG species (i.e. the relat ive contribution of high vs. low reactivity ROG species) varies as new controls are implemented and older emission sources, primarily motor vehicles, are rem oved from service. However, reactivity and spatial changes tend to occur over a long time periods, so when the modeled years are close together chronologicall y, the impact of these changes is minimal. With that exception, carrying capacities can generally be viewed as independent of the year in which the abso lute emission levels are

achieved.May 30, 2007 23 Table 6 Setting the Ozone Emission Reduction Target (Summer Planning tons per day)

San Joaquin Valley (2023)

NOx ROG

2006 Emissions Inventory 650 450

Carrying Capacity 160 342

Emission Reduction Target 490 108

(2006 Emissions Inventory) – (Carrying Capacity) = (Emission Reduction Target)

2006 Emissions Inventory = Amount of ozone-forming emissions. Carrying Capacity

= Pollutant emissions limit that ensures air quali ty standards are met. Emission Reduction Target = Amount of emissions that must be reduced to meet the standard.

D. Reclassification to Extreme Nonattainment

The control strategy discussed below reflects an ex treme non-attainment area SIP. Because the magnitude of the air quality challenge in the San Joaquin Valley, and the limits on existing emis sion control technologies, the San Joaquin Valley Unified Air Pollution Control Di strict is left with only one federally approvable option: to request reclassific ation to extreme nonattainment. The ARB is the primary regulatory authority for the majority of the NOx emissions in the Valley. As such, a reclassification to extr eme is largely driven by the timing and magnitude of mobile source emission reductions which can be achieved.

While ARB staff’s proposed State Strategy is very a ggressive, it does not provide

all the NOx emission reductions needed for attainme nt in the Valley. ARB staff therefore performed a broad brush analysis to see w hether the shortfall could be covered by assuming complete replacement of mobile source fleets with the cleanest new technology standards phasing in from 2 007-2017. Cost was not a constraining factor in this analysis. ARB staff co nsidered the constraints of legal authority, since SIP measures addressing sources no t under our authority to control cannot be approved.

In our analysis, shown in Table 7, we made the foll owing assumptions: in 2020 the Valley would have no passenger vehicles older t han 10 years; all diesel trucks would meet the extremely stringent 2010 stan dards; and all diesel construction and farm equipment would meet the most stringent Tier 4 standards.May 30, 2007 24 Table 7 All New Fleets Analysis Unconstrained by Cost (Summer Planning tons per day)

Source Remaining NOx 2020

Emissions (tpd) a

Passenger vehicles 5

Diesel trucks 43 Construction and other equipment 5 Farm equipment 7

Locomotive 5 Ships and harbor craft 1

Aircraft 5 Stationary/area-wide sources 103
Subtotal of remaining emissions from above categories 173

All other NOx sources 22
Total of all remaining emissions 195 Carrying capacity 160

a. – Includes the emission reduction benefits of th e 2007 Ozone Plan, as approved by the San Joaquin Valley Unified Air Pollution Control Distri ct on April 30, 2007.

In the above table, the top four rows are italicize d to indicate the categories for which we assume that all vehicles and equipment mee ts the cleanest adopted

emission standards. Because the ARB does not have emission standard setting authority for aircraft, stationary sources or area- wide NOx sources, the emissions reported above for those categories come directly f rom the standard emission inventory for 2020. Included in the category “all other NOx sources” are commercial gas trucks, motorcycles, buses, motor ho mes, ships and commercial boats, off-road recreational vehicles and gas power ed off-road equipment.

The result of the all-new-fleet scenario was a NOx emission level of 195 tons per day compared, to a carrying capacity of 160 tons pe r day. Close to half of the remaining emissions, 103 tons per day, are from sta tionary and area-wide sources. Based on these types of analyses, long-te rm concepts that include new technologies for both mobile and stationary sources will be needed. This makes reclassification to extreme necessary in ARB staff’ s view.

Lacking all of the emission reductions needed by 20 20 to close the gap for attainment in 2021, the San Joaquin Valley is left with only one realistic option: to request that U.S. EPA reclassify the San Joaquin Valley nonattainment area to

an extreme classification. While an extreme classi fication has impacts on industrial growth, it also allows the San Joaquin V alley to take advantage of the full suite of tools allowed by the Act, including t he use of new emission control techniques which are expected to develop in the fut ure. The impacts of reclassification are borne locally, so the decision to be reclassified is one whichMay 30, 2007 25

should properly be made by the local air quality ag ency. The District Governing Board resolution adopting the 2007 Ozone Plan inclu des a request for U.S. EPA to reclassify the Valley to extreme nonattainment.

E. Control Strategy

Many actions already taken by the District, ARB, an d U.S. EPA have reduced emissions in the San Joaquin Valley. These actions include the adoption of controls on stationary sources as well as reduction s in tailpipe emissions from motor vehicles and off-road equipment.

California’s on-going mobile source control program will provide the majority of the NOx emission reductions needed to bring the Val ley into attainment of the federal ozone standard. By 2023, ozone precursor e missions from on-road motor vehicles are expected to decline by nearly 70 percent, while off-road vehicles and equipment emissions will decline by mo re than 40 percent. Emissions from stationary and area sources are proj ected to increase slightly, 5 and 3 percent, respectively.

The existing mobile source emission control program does not provide all of the necessary emission reductions needed to meet the de adlines established by U.S. EPA. ARB and District staffs have identifi ed aggressive new emission control strategies which will result in marked impr ovement of air quality. These strategies focus on cleaning up the existing mobile source fleet, through regulatory actions and financial mechanisms. While the majority of the NOx emission reductions will come from mobile sources, the 2007 Ozone Plan also includes an aggressive suite of near-term ROG reduc tion measures. Combined, the near-term strategies would provide significant additional emission reductions

benefits. Table 8 illustrates the emission reducti ons which would be achieved through implementation of the 2007 Ozone Plan.

Table 8 NOx Emission Inventory with the Benefits of the San Joaquin Valley 2007 Ozone Plan (Summer Planning tons per day)

2006 2023

(with Proposed Near-term Measures) Percent

Reduction

On-road Mobile 361 79 78%

Off-road Mobile 161 58 64%Stationary and Areawide 128 104 19%

TOTAL 650 240 63%

ARB staff believes that the combined control strate gy provides enforceable measures and commitments that meet the applicable r equirements for approval.May 30, 2007 26 1. New Local Measures

(a) Rule Development Commitment

The San Joaquin Valley Unified Air Pollution Contro l District’s approved

2007 Ozone Plan contains a suite of commitments to develop rules to control ROG and NOx emissions for implementation by 2012. The six NOx control rules will reduce emissions by six tons per day in the 20 12 ozone season and 8.2 tons per day by 2023. The 14 ROG emissions control rule s will achieve reductions of 26.5 tons per day and 46 tons per day by 2023.

Table 9 lists the District’s emission reduction mea sure commitments, the

emission benefits of these measures at each milesto ne year, and the rule adoption timelines as identified in Chapter Six of the District’s Plan.May 30, 200727Table 9Summary of the Near-term Rule Development Commitments* in the 2007 Ozone Plan(Summer Planning tons per day)ProjectedNOx Reductions by 20__ YearProjectedVOC Reductions by 20__ YearCM#MeasureNameProductCompletionDateComplianceDateReductionStart0811121417202308111214172023S-GOV-1Composting BiosolidsRule 2007 1Q 2008 2008 2 3.4 3.4 3.9 4.0 4.1 4.1S-AGR-1Open BurnRule2007 2Q2010 2Q20072010200720101.1 2.4 2.4 2.4 3.5 3.5 3.4 1.3 2.8 2.8 2.8 2.8 2.82.7S-SOL-11SolventsRule 2007 3Q 2010 2010 0.0 1.3 1.32 1.39 1.46 1.53 1.62S-COM-5Gas TurbinesRule 2007 3Q 2010 2010 0.0 0.6 0.6 0.61 0.64 0.660.68S-IND-24Soil DecontaminationRule 2007 3Q 2008 NA 0.0 0.0 0.0 0.0 0.0 0.0 0.0S-IND-6Polystyrene FoamRule 2007 3Q 2010 2011 0.0 0.0 0.10 0.10 0.11 0.12 0.35S-PET1&2Gasoline Storage &TransferRule 2007 4Q 2009 2009 0.0 0.9 0.92 0.99 1.03 1.07 1.08S-PET-3Aviation Fuel StorageRule 2007 4Q 2010 2010 0.0 0.05 0.05 0.05 0.05 0.05 0.05S-COM-1Large BoilersRule 2008 3Q 2011 2011 0.0 0.0 0.69 0.72 0.75 0.770.8S-COM-2Medium BoilersIncentivesRuleBackstop2008 3Q 20202012 fromincentives0.0 0.0 0.51 0.51 0.51 0.51 0.51S-COM-7Glass MeltingRule 2008 3Q Varies 2008 1.2 1.2 1.6 1.7 1.8 1.9 2.0S-SOL-20Graphic ArtsRule 2008 4Q 2011 2011 0.0 0.0 0.07 0.07 0.08 0.08 0.08S-COM-9Residential WaterHeatersRule 2009 1Q Attrition 2011 0.0 0.2 0.25 0.40 0.550.70 0.85S-GOV-5Composting GreenWasteRule 2009 1Q 2012 2012 0.0 0.0 9 10 10 11 11S-IND-21FlaresRule 2009 2Q NA NA 0.00.00.00.00.00.00.00.00.00.00.00.00.00.0S-IND-14Brandy & Wine AgingRule 2009 3Q NA NA 0.00.00.00.00.00.00.00.00.00.00.00.00.00.0S-SOL-1Architectural CoatingsRule 2009 4Q 2012 2012 0.0 0.0 2 2.1 2.1 2.2 2.3S-AGR-2CAFORule 2010 2Q 2011 2011 0.0 6.8 6.7 18.9 20.4 21.5 22.9S-SOL-6AdhesivesRule 2010 3Q 2012 2012 0.0 0.0 0.11 0.17 0.12 0.13 0.15Total ProjectedNOx Reductions by 20__ YearTotal ProjectedVOC Reductions by 20__ Year0811121417202308111214172023NA (Not Available)* For the purposes of implementing the 2007 Ozone Plan, the District is committed to adoptand implement control measures that will achieve, in aggregate, the emission reductionsspecified in Table 9.2.3 4.4 6.0 6.3 7.8 8.0 8.2 3.3 15.3 26.5 40.5 42.244.5 46.3May 30, 2007 28 (b) Innovative Strategies

In addition to traditional rules, the Valley Plan i ncludes several strategies which

could result in additional NOx and ROG reductions. These strategies include development of programs which will promote air qual ity friendly behavioral changes, including commitments to develop a green c ontracting “model ordinance,” to expand the Spare-the-Air efforts, to develop a heat-island mitigation model ordinance, and to promote alternat ive energy and energy efficiency within the Valley. The District will al so explore ways to achieve even greater emission reductions from land development a ctivities.

The Valley Plan includes a commitment to explore th e expanded use of episodic emission control programs as a mechanism to reduce ozone levels on days when air quality is expected to be poor. Episodic controls utilize real-time meteorological and air quality data to forecast air quality on the following day. An example of an episodic control program is the Distr ict’s Rule 4901 “Wood Burning Fireplaces and Wood Burning Heaters.” This “check before you burn” program moves a step beyond informational “don’t li ght tonight” programs by prohibiting the use of wood-burning residential fir eplaces when particulate matter levels are expected to be elevated. Episodic and r egionally-focused controls will be considered as a part of each rule rulemaking exe rcise. The Valley Plan does not include quantified emission reduction commitmen t for these types of controls

at this time.

The Valley Plan also includes a commitment to consi der amending other prohibitory rules to require facilities which are a lready subject to controls to achieve even greater emission reductions through th e Advanced Emission Reduction Options (AERO) program. The AERO program would set emission reduction goals for stationary sources which are ba sed on advanced technologies.

The AERO program will be implemented through indivi dual rulemaking efforts, at which time the appropriate level of advanced contro l goal would be determined. The AERO program is primarily a compliance flexibil ity tool, which will provide stationary source operators with flexibility to ach ieve additional emission

reductions in a manner that fits into their individ ual business plan. The 2007

Ozone Plan does not take credit for the benefits of AERO provisions as part of

the attainment demonstration.

The emission reduction goals would be met through s everal possible options: application of the advanced controls upon which the regulation is based, achieving on- or off-site emission reductions by co ntrolling other emission sources (such as replacing on-site forklifts), or t hrough the payment of a fee to the District’s Community Clean Air Fund (CCAF). Fu nds placed into the CCAFMay 30, 2007 29

would support emission reductions achieved through the District’s incentive

programs.

Finally, the 2007 Ozone Plan includes a commitment to achieve emission reductions through the adoption of a mandatory empl oyer-based trip reduction program. This program will require employers with 100 or more employees to establish a ride sharing program which will reduce NOx and ROG emissions. The rule would discourage single occupant vehicle c ommutes, by making ridesharing or other mass transit options more appe aling. Table 10 lists the emission benefits the District is committing to ach ieve from the employer based trip reduction program.

Table 10

Mandatory Employer-based Trip Reduction Program

Estimated Emission Reductions (tpd)

2008 2011 2012 2014 2017 2020 2023

NOx 0.0 0.23 0.24 0.25 0.26 0.27 0.28

ROG 0.0 0.61 0.62 0.64 0.65 0.66 0.68

(c) Incentive Programs – Secured Funding

The District proposal differentiates incentive-base d emission reductions into two types: those for which the funding has been secured , and those which could be achieved if new sources of funding are identified. In the attainment demonstration, the 2007 Ozone Plan only includes th e benefits of incentive programs for which funding has been secured. Table 11 lists the incentive based

emission reductions the District commits to achieve as part of the 2007 Ozone Plan. These emission reductions are funded through a combination of Indirect Source Review fees, Developer Mitigation Contract f ees, and Department of Motor Vehicle Surcharge fees. Carl Moyer Program r eductions are not credited here, as they are included in the ARB baseline adju stments identified in Appendix B, Table B-2, of the 2007 Ozone Plan.

Table 11 NOx Reductions Achieved by District Incentive Measures with Assured Funding a

Year NOx Reductions

(tpd)

2012 1.4

2020 0.7

2023 0.6

a. – The Reductions achieved with through the Carl Moyer Program are not included in the

reductions listed here since ARB includes

these reductions in the baseline emission projections.May 30, 2007 30

ARB staff believes that the emission reductions ach ieved through the Carl Moyer Program represent the “Gold Standard” for an incent ive-based emission reduction program. When the District follows the C arl Moyer Program Guidelines, no additional effort should be needed t o ensure that the emission

reductions achieved are SIP creditable. The Distri ct staff is required to use the Carl Moyer Program Guidelines when expending funds from the Carl Moyer program. However, as the District addresses non-Ca rl Moyer Program funding, additional documentation may be necessary. The 200 7 Ozone Plan includes a commitment to strengthen the District’s incentives program in order to ensure that the incentive program is SIP creditable.

The District will strengthen their program through the development of additional emission reduction calculation protocols where need ed, the enhancement of auditing and enforcement of contracted emission red uctions, and the tracking and periodic reporting of the benefits of the proje cts funded through the District’s incentive program.

The District has the discretion to use the Carl Moy er Program Guidelines when expending funds from other sources. ARB staff enco urages the District staff to use the protocols developed under the Carl Moyer Pr ogram Guidelines where applicable. However, recognizing that special circ umstances may arise where the Carl Moyer Program may not provide guidance or the District needs additional flexibility to address specific sources, the District can develop and implement specific protocols which allow non-Carl M oyer Program funds to address specific District needs. ARB staff will pr ovide technical assistance in the development of these additional protocols, as neede d.

2. Proposed New State Measures

Cleaning up the mobile NOx sources in the San Joaqu in Valley is the most critical component of the emission control effort t o reduce both ozone and PM2.5 concentrations in the Valley. Vehicles and equipme nt operating in California are subject to the most stringent tailpipe emission sta ndards in the world. ARB has a long history of adopting successful programs to red uce emission from mobile sources. These regulations will result in fewer em issions as vehicles and equipment units meeting the cleanest emission stand ards enter into service. However, the benefits of these cleanest engines are only realized as new engines enter service and older engines are retired , and diesel engines have very long useful lives. In order to expedite the u se of engines meeting the cleanest emission control standards, ARB staff is p roposing a comprehensive list

of emission control measures to reduce both NOx and ROG emissions throughout the State.

Table 12 summarizes the estimated benefits of ARB s taff’s proposed measures in the San Joaquin Valley. ARB staff is proposing to commit to the total emission reductions benefits of the proposal in 2020 and 202 3 in the San Joaquin Valley.May 30, 2007 31

The potential emission reduction benefits of indivi dual measures are provided for informational purposes only. The emission reductio n benefits of the proposed State Strategy in 2014 will be considered, and reco mmended as a State commitment, in the context of the Valley’s PM2.5 at tainment plan. Additional details on the individual measures being proposed b y ARB staff, and on the estimated benefits of those measures, are available in the proposed 2007 State Strategy, which is available on-line at:

http://www.arb.ca.gov/planning/sip/2007sip/2007sip .htmMay 30, 2007 32 Table 12 Expected Emission Reductions from Proposed New SIP Measures San Joaquin Valley (Summer Season, tons per day)

2020 2023 Proposed New SIP Measures NOx ROG NOx ROG

Passenger Vehicles 2.7 4.1 2.1 3.3

Smog Check Improvements (BAR) 2.4 2.2 2.1 1.9
Expanded Vehicle Retirement 0.3 0.3 0.04 0.1
Modifications to Reformulated Gasoline Program -- 1.6 -- 1.3

Heavy-Duty Trucks 30.2 3.3 21.2 2.3

Cleaner In-Use Heavy-Duty Trucks 30.2 3.3 21.2 2. 3

Goods Movement Sources 15.6 1.2 16.4 1.3

Auxiliary Ship Engine Cold Ironing & Clean Techno logy -- -- -- -- Cleaner Main Ship Engines and Fuel -- -- -- --

Port Truck Modernization -- -- -- --

Accelerated Intro. of Cleaner Line-Haul Locomotiv es 15.6 1.2 16.4 1.3 Clean Up Existing Harbor Craft -- NYQ -- NYQ

Off-Road Equipment 7.0 1.0 5.4 0.6

Cleaner In-Use Off-Road Equipment (over 25hp) 7.0 1.0 5.4 0.6
Cleaner In-Use Agricultural Equipment NYQ NYQ NYQ NYQ

Other Off-Road Sources 0.4 8.7 0.6 11.4

New Emission Standards for Recreational Boats 0.4 3.8 0.6 5.3 Expanded Off-Road Rec. Vehicle Emission Standards -- 4.9 -- 6.1 Additional Evaporative Emission Standards -- NYQ -- NYQ
Vapor Recovery for Above Ground Storage Tanks -- NYQ -- NYQ

Area-wide Sources -- 6.1 -- 6.3

Consumer Products Program -- 3.6 -- 3.8

Pesticides: DPR 2008 Pesticide Plan -- 2.5 -- 2.5

Emission Reductions from Proposed New Measures 56 24 46 25

NYQ = Not Yet Quantified. BAR = Bureau of Automoti ve Repair. DPR = Dept. of Pesticide Regulation Locomotives measure relies on U.S. EPA rulemaking a nd industry agreement to accelerate fleet turnover. Note: Emission reductions reflect the combined imp act of regulations and supportive incentive program s. Emission reduction estimates for each proposed meas ure are shown for informational purposes only. Act ual emission reductions from any particular measure may be greater than or less than the amounts shown.

3. Proposed New Federal Measures

The San Joaquin Valley 2007 Ozone Plan does not inc lude federal commitments for new emission reductions. However, the proposed State Strategy takes advantage of new emission standards for on- and off -road engines and equipment which will be in place in the near future . The proposed State Strategy also takes advantage of Tier 4 locomotive emission standards that U.S. EPA hasMay 30, 2007 33

proposed to implement by 2017. 11 The ARB staff has proposed developing a suite of measures and agreements with the railroads to ensure that the cleanest locomotives in the industry’s fleets are operated i n California on an expedited timeline. U.S. EPA must work to develop these stan dards in a timeframe which

will allow the benefits to be achieved in the Valle y as expeditiously as possible.

4. Long-term Measures

In order to attain the federal 8-hour ozone standar d, the Valley needs to achieve a 75 percent reduction in NOx emissions and a 25 pe rcent reduction in ROG emissions, valleywide. The near-term measure commi tments in the 2007 Ozone Plan, as a whole, will reduce NOx emissions by 63 p ercent and ROG emissions by 25 percent.

Combined, the near-term NOx emission reduction comm itments adopted by the District and under consideration by ARB staff will not provide all of the NOx emission reductions necessary for the Valley to att ain the federal ozone

standard. Federal law 12 allows areas classified as extreme nonattainment o f the federal ozone standard to take advantage of improve ments in emission control technologies and techniques which are expected to d evelop in the future. This provision allows areas with the most extreme air qu ality challenges to develop approvable SIPs, even where 100 percent of the nece ssary reductions cannot be achieved cost effectively with today’s technologies . In order to demonstrate attainment, the 2007 Ozone Plan relies on the use o f advanced technologies to

achieve the last increment of emission reductions.

More than 80 tons per day of the necessary NOx emis sion reductions remain to be achieved, beyond what known technologies will re liably achieve. It is impractical to presumptively apportion those reduct ions by primary regulatory authority. Both the ARB and District staffs must w ork diligently to identify and take advantage of all effective emission control te chnologies as those technologies as quickly as they become available.

The District’s 2007 Ozone Plan has two components, future study measures and long-term concepts, which will help identify and pr omote the technologies and programs needed to achieve additional emission redu ctions on both mobile and stationary sources. ARB staff has also identified long-term measures which may

result in additional emission reductions.

(a) Future Study Measures

The District has identified a suite of future study measures which, upon completion, could result in opportunities for addit ional emission reductions. These study measures seek to explore where and how additional emission

11 Federal Register: April 3, 2007 (Volume 72, Number 63, pages 15937-16151)

12 Clean Air Act Amendments Section 182(e)(5)May 30, 2007 34

reductions may be achieved through another round of prohibitory rules. The District is committing to release a study report by the dates listed in Table 13, which may recommend a future amendment to the regul atory implementation

schedule to include those additional measures ident ified as fruitful.

Such study measures include the internal combustion engine study and the two boiler studies. In all cases, the District should strive to adopt new rules within one year of completion of study measures, where the studies indicate that emission reductions could be achieved. For study m easures where additional emission reductions are not available, the District should periodically revise those studies, to take advantage of technology as quickly as it becomes available.May 30, 2007 35 Table 13 District Stationary Source Feasibility/Future Study Implementation

Schedule

CM# Measure Name Product Completion

Date

S-COM-6 ICE Electrification\Pump Efficiency Incenti ves FS 2008

S-GOV-6 Prescribed Burning FS 2008

Program Review Open Burning Biomass Incentive FS 2008

S-PET-13 Oil Production Sumps FS 2009

S-PET-16 Heavy Crude Oil Components FS 2009

S-COM-4 Solid Fuel Fired Boilers FS 2009

S-COM-3 Small Boilers FS 2010

S-IND-12 Wine Fermentation & Storage FS 2010

S-IND-5 Asphalt Roofing FS 2010

S-PET-18 HOTS & Gauge Tanks FS 2010

S-AGR-4 Pesticide Fumigation Chambers FS 2011

S-COM-11 Dryers FS 2011

S-GOV-4 Asphalt Paving FS 2011

S-IND-13 Bakeries FS 2011

S-COM-6 IC Engines – Standards Review FS 2012

S-GOV-2 POTW Water Treatment FS 2012

S-IND-23 Reduction of Animal Matter FS 2012

S-PET-22 Refinery Turnaround Units FS 2012

S-PET-23 Refinery Vacuum Devices FS 2012

S-PET-24 Refinery Wastewater Separators FS 2012

FS – Feasibility/Future Study: Not currently quant ifiable. FS reports will be released by the comple tion date, which may recommend an amendment to the Plan Regula tory Implementation Schedule to include additional regulatory measures identified as fruitful and have the potential of achieving reductions committed to in the

Black Box.

(b) Incentive Programs – Unsecured Funding

The primary driver of emission reductions in the “b eat-the-SIP” strategy is through the use of additional incentive monies. AR B staff supports use of incentives to accelerate the air quality progress. However, the federal regulation and policy constrains what can be included in a fed erally approvable SIP. Despite these constraints, ARB staff believes that securing funding and getting cleaner vehicles and equipment into service quickly will improve air quality throughout the Valley.

Chapter 7 of the 2007 Ozone Plan outlines the Distr ict staff’s incentive-based emission reduction “action plan” which would be emp loyed as funding becomes available. Using economic incentives to facilitate fleet clean-up has the potential to achieve greater emission reductions, well before they would occur with natural turnover. The District staff has experience implem enting several emission reduction incentive programs, including the State f unded Carl Moyer Program.May 30, 2007 36

ARB staff believes that, where possible, District i ncentive funding should not be limited to mobile equipment. Where possible and co st effective, the District should explore funding ultra-clean stationary sourc e technology. Funding the use of cutting-edge stationary source emission cont rol technologies would help demonstrate that these technologies are effective i n real-world applications. Development of these newer and more advanced techno logies could support another round of regulatory development, needed to achieve the final increment of emission reductions in the Valley.

U.S. EPA does not allow regions to use emission red uction estimates from unsecured incentive money as part of an approvable attainment demonstration. In addition to having secure funding, EPA requires that emission reductions achieved through an incentive program must be quant ifiable, surplus to regulatory requirements and inventory estimation as sumptions, permanent over the life of the project, and enforceable by the Dis trict. Emission reductions meeting these requirements are considered to be “SI P creditable.” Identifying new funding streams, and implementing the requireme nt that emission reductions must be surplus to regulatory requiremen ts, will help drive the development and implementation of new advanced tech nologies.

Since prospective funding does not meet U.S. EPA SI P accountability criteria, the District plan does not take credit, in the atta inment demonstration, for emission reductions achieved through prospective fu nding. However, once funding has been secured, the incentive measures id entified will provide additional near-term emission reductions. Long-te rm, these will help achieve the

last increment of emission reductions needed for at tainment. As this money is secured, the District staff will work with the publ ic, U.S. EPA, and ARB to ensure

that the emission reductions are SIP creditable.

Sections 7.6 and 7.7 of the 2007 Ozone Plan outline the District’s strategy to strengthen their current and future incentive progr ams. These sections were approved by the District and recognize the need to ensure that implementation of the publicly funded incentive programs is transpare nt. These sections will serve as the guiding principles and strategies the Distri ct staff will follow in developing new funding sources to support their beat-the-SIP a pproach. The District is not submitting sections 7.6 and 7.7 for inclusion in th e San Joaquin Valley SIP.May 30, 2007 37 (c) Long-term Concepts

Chapter 11 of the 2007 Ozone Plan outlines three lo ng-term strategy components: alternative energy sources, advanced r etrofit/replacement technologies, and smart growth/land use. Developme nts in these three arenas could lead to increased emission reductions, reduce d vehicle travel, and a further clean-up of the remaining vehicles and equipment.

(d) Proposed Long-term State Measures

A discussion of the ARB staff’s proposed long-term measures can be found in Chapter 3 of the proposed 2007 State Strategy.

(e) Contingencies for New Technologies

Additional provisions apply to extreme areas that i nclude new technologies in their attainment plans. These attainment demonstra tion plans can rely on future advances in emission reduction technologies (referr ed to as new technologies) if the State, among other things:

• submits enforceable commitments to develop and ado pt contingency measures if the anticipated technologies do not ach ieve the planned reductions;

• demonstrates that the contingency measures shall b e adequate to produce emission reductions sufficient to achieve a ttainment and reasonable further progress.

These contingency measures to back-up the new techn ology provisions are not due until three years before implementation of thes e new technology provisions.

After adoption of the State Strategy, ARB staff pro poses to initiate a coordinated government, private, and public effort to establish emission goals for critical mobile and stationary emission source categories. Following the setting of emission goals, ARB will start an ongoing public pr ocess to assess technology advancement opportunities for the critical categori es. ARB staff will periodically brief the Board at public meetings on emerging emis sion reduction opportunities, promising technologies, and the progress made in de veloping long-term emission

reduction measures. As ARB staff identifies feasib le technology-forcing emission reduction measures, staff will propose those measur es to the Board for inclusion

into the SIP.

No later than 2020, ARB and the District will prepa re a revision to the 8-hour Ozone SIP that (1) reflects any modifications to th e 2023 emission reduction target based on updated science, and (2) identifies any additional strategies,May 30, 2007 38

including the implementing agencies, needed to achi eve the necessary emissions reductions by 2023. If the specific meas ures developed to satisfy the long-term obligation affect on-road motor vehicle e missions, we will work with the air districts and transportation planning agencies to revise the transportation conformity budgets accordingly.

F. Attainment Demonstration

The emission reduction measures identified previous ly, including long-term measures, will provide the necessary emission reduc tions to demonstrate attainment of the federal standard by 2023. Table 14 demonstrates that the required emission reductions will be achieved by im plementing the commitments for new and long-term measures proposed in the Stat e Strategy and approved in the San Joaquin Valley’s 2007 Ozone Plan.

From today’s emission levels, reaching the emission targets for attainment will necessitate NOx emission reductions of 490 tons per day (see table 5, above). The existing emission control program will yield 35 5 tons per day of NOx reductions between today and 2023. The San Joaquin Valley 2007 Ozone Plan, including ARB staff’s proposed new measures, would generate another 55 tons per day of NOx reductions by 2023. This leaves an additional 80 tons per day of NOx emissions to be addressed by long-term, new tec hnology measures. The existing and proposed new measures will achieve all of the ROG reductions needed, without the reliance on new technologies.May 30, 2007 39 Table 14 Meeting the Ozone Emission Reduction Target (Summer Planning tons per day)

San Joaquin Valley (2023)

NOx ROG

Emission Reduction Target 490 108

Emission Reductions from Adopted SIP Measures 355 41

Emission Reductions from

New Local Measures 9 47

Emission Reductions from

New State Measures 46 25

Long-Term Measures 80 --

Total Reductions 490 113

Emission Reductions from Adopted SIP Measures = Emissions reduced from measures adopted through 2006.

Emission Reductions from New Measures = Emissions reduced from measures in the State Strategy or new local measures adopted after 2006. Long-Term Measures

= Emissions reduced from measures adopted after 20 20 that rely on new or evolving technology, as allowed in section 182(e)(5 ) of the Clean Air Act.

1. Requirements for Failure to Attain by the Applic able

Deadline

The Act requires that, should the Valley not attain the federal 8-hour zone standard by 2024, the SIP include contingency measu res which take effect without further action by the State. 13 The State’s mobile source emission reduction program will achieve additional emission reduction benefits as older

dirtier mobile sources are removed from service aft er the Valley’s attainment

deadline. Those additional benefits achieved are a vailable to meet the attainment-year contingency requirements. ARB staf f is proposing to commit the

benefit of the State’s mobile source emission reduc tion program in 2024 for attainment-year contingency measures.

The Act also requires that areas classified as seve re or extreme nonattainment of the federal ozone standard include In the SIP proce dures to levy a fee for failure

to attain. 14 The District has an adopted a rule 15 implementing these

13 Section 172(c)(9) of the 1990 Clean Air Act Amendm ents.

14 Section 185 of the 1990 Clean Air Act Amendments.

15 San Joaquin Valley Unified Air Pollution Control D istrict Rule 3170 – “Federally Mandated

Ozone Nonattainment Fee.”May 30, 2007 40

requirements, which goes into effect automatically if the Valley does not attain the ozone standard by the 2024 deadline.

G. Reasonable Further Progress and Contingency Meas ures

The Clean Air Act requires that areas classified mo derate or greater, demonstrate that progress towards attaining the fed eral standard will not be delayed. This Reasonable Further Progress (RFP) re quirement ensures that areas do not delay implementation of emission contr ol programs until immediately before the attainment date. RFP requir ements vary by

nonattainment classification. Nonattainment areas classified serious and above, including the San Joaquin Valley, must demonstrate an 18 percent reduction in

ROG and/or NOx emissions from the 2002 baseline ROG inventory by 2008. In the years that follow, they must demonstrate, on av erage, an additional 3 percent per year reduction in ROG and/or NOx emissions unti l their attainment year.

The Act also requires that nonattainment areas prov ide for contingency

measures which take effect without further action i f an area fails to achieve the reductions required to demonstrate RFP. U.S. EPA h as interpreted this to mean that the contingency measures must be from measures that have already been adopted.

The District staff analysis of RFP and contingency measures, set out in Chapter 10 of the Valley’s 2007 Ozone Plan, demonst rates that all of the emission reductions needed to meet the RFP and prog ress related contingency measure requirements will come from the existing em ission control program.

ARB staff concurs that RFP and contingency measures requirements are met through currently adopted rules and regulations. T able 15 sets out the RFP and contingency measure demonstration conducted by ARB staff. This demonstration includes the impacts of the revised p esticide emissions, which were not available in time for inclusion in the pub lication and adoption of the 2007 Ozone Plan by the District. As such, ARB staf f is proposing to submit this

RFP demonstration to U.S. EPA for inclusion in Cali fornia’s SIP for the San Joaquin Valley. Details on the calculation procedu res can be found in Appendix D to the proposed State Strategy, and is a vailable on-line at:

http://www.arb.ca.gov/planning/sip/2007sip/apr07dr aft/revdrftappd.pdfMay 30, 2007 41 Table 15 San Joaquin Valley RFP and Contingency Measure Summary

Milestone year

2008 2011 2014 2017 2020 2023 (for 2024 attainment)

ROG or NOx percent reduction required from 2002

levels 18% 27% 36% 45% 54% 63%

ROG percent reduction projected from existing program 2002 levels used to

meet RFP 8.9% 13.3% 13.7% 14.5% 14.0% 12.7%

NOx percent reduction projected from existing program from 2002 levels

used to meet RFP 9.1% 13.7% 22.3% 30.5% 40.0% 50.3%

Total ROG and/or NOx percent reductions from existing program used to meet

RFP 18% 27% 36% 45% 54% 63%

RFP percent reduction requirements met? Yes Yes Yes Yes Yes Yes

Total NOx or ROG percent

reductions used to meet contingency requirements 2.5% 3% 3% 3% 3% 3%

Contingency measure requirements met? Yes Yes Yes Yes Yes Yes

H. Transportation Conformity Budgets

The District’s 2007 Ozone Plan establishes county-l evel on-road motor vehicle emission transportation conformity budgets for each milestone year, as well as for the attainment year. The emissions budgets ref lect the latest planning assumptions and were developed using EMFAC2007. Th ese new conformity budgets are listed in Table 16. Detailed calculati ons used to derive the transportation conformity budgets can be found in C hapter 9 and Appendix C of the San Joaquin Valley 2007 Ozone Plan.

Two updates to the San Joaquin Valley on-road trans portation conformity budgets are being proposed by ARB staff: new on-roa d mobile source activity estimates for Madera County which was not available in time for inclusion in the 2007 Ozone SIP; and a technical correction to the S an Joaquin County transportation conformity budgets for 2008 to fix a data input error discovered subsequent to District Governing Board action. Tab le 16 includes the impact of these updates. Appendix D to this report discusses these updates in greater

detail.May 30, 2007 42

With the proposed updates identified above, the emi ssion budgets established in the Valley’s 2007 Ozone Plan fulfill the requiremen ts of the Act and U.S. EPA regulations to ensure that transportation projects will not interfere with progress, and attainment of, the federal 8-hour ozone standar d.

Table 16 Transportation Conformity Budgets a (Summer planning tons per day)

2008 2011 2014 2017 2020 2023 County

sub-area ROG NOx ROG NOx ROG NOx ROG NOx ROG NOx ROG NOx

Fresno 18.6 58.5 15.5 47.9 12.9 37.2 11.1 29.1 8.0 16.9 7. 8 15.7

Kern (SJV) 18.1 93.9 15.7 79.4 13.5 64.1 11.6 49.5 8.5 18.4 8. 1 24.8

Kings 3.9 18.3 3.4 15.9 2.8 12.3 2.3 9.4 1.7 5.3 1.6 4.7

Madera b 4.4 14.6 3.7 12.2 3.1 9.7 2.6 7.7 1.9 4.8 1.9 4.5

Merced 7.4 35.5 6.2 28.8 5.1 22.3 4.2 17.1 2.9 9.9 2.8 9.0

San Joaquin 13.9 b 40.0 b 12.1 34.7 10.1 27.8 8.6 21.3 6.3 12.7 6.3 11.9

Stanislaus 10.5 26.7 9.0 22.3 7.5 17.2 6.5 13.4 4.9 8.0 4.6 7. 1

Tulare 10.5 23.4 9.2 20.9 7.7 16.6 6.7 13.1 5.2 8.4 4.8 7. 4

a. – The budgets were derived using EMFAC2007 with updated vehicle population and vehicle miles traveled data where available. The budget was estab lished by taking the EMFAC results, subtracting by County, emission reductions from District and ARB c ontrol measures and rounding up to the nearest tent h if the hundredths place was “1” or higher.

b. – Revised per discussion above. Please see Appe ndix D for additional details.

I. Additional Requirements for Extreme Nonattainmen t Areas

1. Major Source Permitting Requirements

The Act requires that areas classified as extreme n onattainment revise their permitting requirements to be applicable to sources with the potential to emit 10 tons per year of ozone forming emissions. The 2 007 Ozone Plan includes a

commitment to submit to U.S. EPA a revised New Sour ce Review rule which meets the requirements for an extreme area, within one year of District Board approval of the plan. See Chapter 2 of the 2007 Oz one Plan for more detail.May 30, 2007 43 2. Clean Fuels Requirements

The Act also has requirements for the use of clean fuels or advanced technology

in all electric utilities and industrial or commerc ial boilers which emit more than 25 tons per year of NOx. Existing District rules 16 meet implement this requirement. More information is available in Chap ter 2 of the Valley’s 2007

Ozone Plan.

16 San Joaquin Valley Unified Air Pollution Control D istrict Rules 4305, 4306, and 4352.May 30, 2007 44

IV. ENVIRONMENTAL IMPACTS

The California Environmental Quality Act (CEQA) req uires that State and local agency projects be assessed for potential significa nt environmental impacts. Air quality plans are “projects” that are potentially s ubject to CEQA requirements. The District staff found that the plan would not ha ve a significant effect on the environment and prepared an Initial Study/Negative Declaration. The District Governing Board approved this Initial Study/Negativ e Declaration on April 30, 2007. 17

V. LEGAL AUTHORITY

The federal Clean Air Act Amendments (the Act) requ ire states to provide for the attainment of national ambient air quality standard s. The primary tool to be used in the effort to attain national ambient air qualit y standards is a plan that any state with one or more nonattainment areas must develop, which provides for implementation, maintenance and enforcement of the standards—the State Implementation Plan (section 110(a)(1)). Section 1 10(a)(2)(A) of the Act broadly

authorizes and directs states to include in their S IPs:

"...enforceable emission limitations and other cont rol measures, means, or techniques (including economic incentives such as f ees, marketable permits, and auctions of emissions rights), as well as schedules and timetables for compliance, as may be necessary or appropriate to m eet the applicable requirements of the Act."

State law charges the ARB with coordinating State, regional, and local efforts to

attain and maintain both State and national ambient air quality standards. The direct statutory link between ARB and the mandates of the Clean Air Act is found in section 39602 of the Health and Safety Code (HSC ). This provision states:

"The state board is designated the air pollution co ntrol agency for all purposes

set forth in federal law.

The state board is designated as the state agency r esponsible for the preparation of the state implementation plan required by the Cl ean Air Act (42 U.S.C., Sec. 7401, et seq.) and, to this end, shall coordinate t he activities of all districts necessary to comply with that act.”

State law also limits what the ARB may submit as a SIP revision. HSC section 39602 goes on to state,

“Notwithstanding any other provision of this divisi on, the state implementation plan shall only include those provisions necessary to meet the requirements of

the Clean Air Act."

17 San Joaquin Valley Unified Air Pollution Control D istrict resolution number 07-04-11a.May 30, 2007 45

ARB will exclude from the SIP submittal any provisi ons of the San Joaquin Valley 2007 Ozone Plan that relate solely to the Ca lifornia Clean Air Act requirements.

VI. STAFF RECOMMENDATIONS

As described in this report, ARB staff has reviewed San Joaquin Valley’s 8-Hour

Ozone Attainment Plan 2007 and consulted extensivel y with District staff during

this review.

ARB staff finds that the San Joaquin Valley’s 2007 Ozone Plan meets all applicable requirements. We believe that implement ation of this plan would clearly reduce ozone levels throughout San Joaquin Valley and benefit public

health and result in attainment of the 8-hour ozone standard by June 2024. Therefore, we recommend that the Board take the fol lowing actions:

(1) Adopt the local elements of the 2007 San Joaqui n Valley 2007 Ozone Plan as a revision to the California SIP, including the local control strategy, the updated emission inventories, the updated attai nment demonstration, and the updated motor vehicle emission budgets.

(2) Direct the Executive Officer to submit the loca l plan elements to U.S. EPA

as a revision to the California SIP.

The San Joaquin Valley 2007 Ozone Plan relies on em ission reductions to be achieved from the proposed State Strategy for Calif ornia’s 2007 SIP. The State Strategy is scheduled to be considered by ARB on June 21, 2007, and thus at the June 14, 2007 hearing ARB will be considerin g the 2007 Ozone Plan before the State Strategy has been approved. There fore, final ARB action on the San Joaquin Valley’s 2007 Ozone Plan would be conti ngent upon ARB’s subsequent adoption of commitments, as part of the State Strategy, to achieve

the emission reductions from State measures.